CUNA Comment Letter

Treasury Core Competencies

September 10, 2010

Department of the Treasury
Office of Financial Education and Financial Access
1500 Pennsylvania Avenue, NW
Washington, DC 20220

Re:  Financial Education Core Competencies

To Whom It May Concern:

The Credit Union National Association (CUNA) appreciates the opportunity to comment on the Financial Literacy and Education Commission's (Commission's) request for comment regarding the development of financial education core competencies. Specifically, the Commission seeks input on the appropriateness and adequacy of proposed fundamental concepts and accompanying competencies. By way of background, CUNA is the largest credit union trade organization in the country, representing approximately 90 percent of our nation's nearly 7,700 state and federal credit unions, which serve approximately 93 million members. CUNA partners with and provides support to the National Endowment for Financial Education (NEFE) to assist in its financial education efforts.

Summary of CUNA's Views

Discussion of CUNA's Views

General Comments

We applaud the Commission's work in the area of financial literacy and education. The current inadequacy of financial literacy on the national level has been highlighted by the recent economic recession.

CUNA is a strong supporter of financial education in the form of classroom curriculum. Our efforts include partnership with NEFE, whose goal is to "provide consumers with the tools necessary to manage their money wisely and empower them to turn their financial education into action." While classroom financial education is crucial, we believe that in order to effect positive change on a large-scale, financial education efforts must also focus on other aspects of an individual's daily life—such as education in the workplace.  Furthermore, as described in the chart of recommendations below, we believe it is vital that parents and guardians exhibit positive financial responsibility—whether in the form of teaching or mentoring, or simply by behavior.

In articulating the core competencies discussed below, the Commission has taken care to avoid making reference to specific types of financial institutions, which we appreciate and we encourage the Commission to continue its approach.

Comments Regarding Proposed Core Concepts and Competencies

Following its review of the National Strategy, the Commission determined that it is necessary to develop core competencies for consumers and financial education providers. The core competencies will be used to establish a clear understanding about what individuals should know and the basic concepts program providers should cover.  In addition, the core competencies will be used to establish a baseline of knowledge.

CUNA agrees that the five core concepts the Commission has proposed are appropriate; these are earning, spending, saving, borrowing, and protecting against risk.  We believe each of the core concepts and competencies is clear, concise, and thorough.

We believe establishment of concepts and competencies is a necessary step and an appropriate method to achieve the Commission's objectives.  Specifically, we support use of the proposed concepts and competencies as a foundation on which to structure financial education.

In addition, CUNA generally agrees with the Commission's proposed list of knowledge and actions. As proposed by the Commission, we believe it is necessary to attach actions to each knowledge component as a baseline on which to measure program success.

As a supplement to the proposed list, we encourage the Commission to consider the following recommendations, which follow the same format the Commission has proposed for its list of knowledge and actions.

Earning

Knowledge: Understand how to increase income
Action: - Consider additional education or training
- Evaluate additional employment opportunities including a second/part time job
- Consider selling unused personal property

Spending

Knowledge: Understand the reason for certain spending habits
Action: - Spouses/partners should gain a better understanding of family money dynamics
- Encourage individuals to seek financial support from a trusted source
- Make positive changes in behavior
- Be aware of how marketing influences why and on what we spend money

Knowledge: Ways to save money
Action: - Use money saving tools, such as coupons, discounts, libraries, cash, etc.

Saving

Knowledge: Understand now vs. later
Action: - Save for purchases through special savings
- Delay gratification to achieve long-term financial success

Knowledge: Short-term, intermediate, and long-term goals
Action: - Increase financial planning

Knowledge: Act as a financial role model for your children
Action: - Talk with your children about money and finances

Borrowing

Knowledge: Understand good debt vs. bad debt
Action: - Keep total debt to a reasonable level

Knowledge: Understand the concept of income vs. debt
Action: - Assess adequacy of current income
- Reduce debt

Knowledge: Understand how to establish good credit
Action: - Establish good credit

Knowledge: Be aware of warning signs of a financial problem and know who can help
Action: - Avoid problems and know what to do to correct over time
- Know where to seek assistance

Knowledge: Credit reports
Action: - Understand how decisions for borrowing and repayment affect credit score
- Understand how the score is calculated
- Know how to appropriately deal with creditors when in financial trouble
- Obtain free credit score

Protect Against Risk

Knowledge: Importance of acting now to protect against potential catastrophe later
Action: - Maintain a list of personal belongings
- Maintain a "wallet register" of cards and IDs
- Maintain a list of financial relationships and account numbers
- Define beneficiaries
- Keep all the above in a safe place

CUNA will also be commenting on the Commission's draft National Strategy for Financial Education 2010, which was published in the Federal Register on September 3. For both the draft National Strategy and the core competencies comment requests, we understand that the actions of the Commission do not require formal comment solicitation under the Administrative Procedures Act.  However, we believe financial literacy is of such great importance that the Commission should allow public input for a minimum 30-day comment period.

Thank you for the opportunity to express our views on this extremely important topic. If you have any question about our letter, please do not hesitate to give Senior Vice President and Deputy General Counsel Mary Dunn or me a call at (202) 508-6743.

Sincerely,

Luke Martone
Regulatory Counsel