|Received:||5/24/2005 2:49:35 PM|
|Organization:||Members Advantage Credit Union|
|Agency:||Federal Trade Commission|
|Rule:||Disclosures for Non-Federally Insured Depository Institutions under the Federal Deposit Insurance Corporation Improvement Act (FDICIA)|
Comments:We are writing in regards to the tremendous additional burden that your regulations/disclosures would impose upon us. We take serious issue with such creeping bureaucracy. Our credit union has $22 million in total assets, and principally represents SBC, AT&T, Cook County Sheriffs Department, and 200 small employee groups. We have been privately insured since before June 19, 1994. In 1994, the credit union complied with the requirements of the Federal Deposit Insurance Corporation Improvement Act of 1991 (FDICIA), by mailing three sequential notices to our then-current members, seeking their signed acknowledgments recognizing the credit union’s lack of federal share insurance. Unfortunately, the records supporting our compliance with FDICIA in 1994 have been destroyed as required under the credit union’s records retention policy. We believe that your agency’s proposed requirement to obtain such notices over again, due to the lack of proof of our earlier compliance, would impose an excessive regulatory burden and cost on the credit union. Given the lack of regulatory guidance by the FTC over the last 14 years, we feel the time period for all forms of compliance with the acknowledgment provisions should commence with the future effective date of any rule promulgated by the FTC. Thank you for your consideration.