| Comment Number: | 515567-00089 |
| Received: | 6/9/2005 2:17:28 PM |
| Organization: | Southeastern Ohio Credit Union, Inc. |
| Commenter: | Marsha Leasure |
| State: | OH |
| 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:
Secretary: Our credit union has $12.2 million in total assets and principally represents the state employees in the Cambridge area in Guernsey County and school and hospital employees in Washington County, Ohio. 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 acknowledgements recognizing the credit union's lack of federal share insurance. During the second half of 1994, the credit union mailed approximately 4,200 notices at a cost of about $3,500.00. Since that time, we have made every effort to comply with the acknowledgement 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. This extra expense would greatly impact our bottom line. 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 that commerce with the future effective date of any rule promulgated by the FTC. Thank you for your consideration. Respectfully submitted, Marsha Y. Leasure, Manager Southeastern Ohio Credit Union, Inc. 66737 Old Twenty-One Road Cambridge OH 43725