| Comment Number: | 515567-00107 |
| Received: | 6/13/2005 4:42:35 PM |
| Organization: | Los Angeles Firemen's Credit Union |
| Commenter: | Mike Mastro |
| State: | CA |
| 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 13, 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: Los Angeles Firemen’s Credit Union (LAFCU) serves 21,416 members that are active/retired paid, professional fire fighters (and their immediate families) within the state of California. LAFCU became privately insured before June 19, 1994. On behalf of LAFCU and our members, I would like to express my comments on the following areas of the Proposed Rule for FDICIA Disclosures, Matter No. R411014: Acknowledgement of Disclosures In 1994, in order to comply with FDICIA, we requested signed acknowledgement from approximately 15,000 members stating that they knew LAFCU was not federally insured and that the federal government did not guarantee they would get their money back if LAFCU failed. Since 1994, all new members have been required to sign acknowledgements containing the same disclosure. Due to a lack of guidance on retaining these records, they have been destroyed in accordance with LAFCU’s record retention policy. If required to obtain signatures from all of our current members would impose a significant burden to LAFCU both operationally and financially. Therefore, we request that the FTC exempt all credit unions privately insured on June 19, 1994, from securing signed acknowledgement from all members. Federal Trade Commission/Office of the Secretary Conspicuous Disclosures LAFCU is very concerned about the FTC’s proposal that would require privately insured credit unions to disclose it insured status on all forms of advertising. We provide a multitude of advertising items to our members such as calendars, pens, measuring tapes, letter openers, etc. which do not lend themselves to this disclosure. We do see the logic in such a disclosure on printed materials for savings account investments (however, not on loan promotional materials). We would request that the final rule contain language requiring such disclosure only on printed or electronic materials (websites, etc.) that mention savings account investments or their rates. Thank you for your attention to these important matters. Respectfully, Michael L. Mastro President/CEO MLM:sd