| Comment Number: | 515567-00019 |
| Received: | 6/1/2005 7:10:31 PM |
| Organization: | Financial Horizons Credit Union |
| Commenter: | Barbara Reuter |
| State: | NV |
| Agency: | Federal Trade Commission |
| Rule: | Disclosures for Non-Federally Insured Depository Institutions under the Federal Deposit Insurance Corporation Improvement Act (FDICIA) |
| Docket ID: | 3084-AA99 |
| No Attachments |
Comments:
June 01, 2005 Proposed Rule for FDICIA Disclosures, Matter No. R411014 Federal Trade Commission/ Office of the Secretary Room H-159 (Annex A) 600 Pennsylvania Avenue, N.W. Washington, D.C. 20580 Secretary: Our credit union has $73,565 in total assets and principally represents rural Nevada with a community membership base. Also, the credit union has 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. During the second half of 1994, the credit union mailed approximately 3840 notices at a cost of about $2,000.00. Since that time, we have made every effort to comply with the acknowledgment of disclosure requirement of FDICIA with respect to new members joining the credit union. 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. Respectfully submitted, Barbara S Reuter President/CEO