CUNA Comment Letter

Workplace Financial Education Honor Roll Program

October 27, 2008

Director Dubis Correal
Office of Financial Education
Department of the Treasury
1500 Pennsylvania Ave., N.W., Room 1328
Washington, D.C. 20220

Dear Ms. Correal:

The Credit Union National Association (CUNA) appreciates the opportunity to comment on the Office of Financial Education's solicitation regarding the Workplace Financial Education Honor Roll program, recommended by the President's Advisory Council on Financial Literacy. By way of background, CUNA is the largest credit union trade organization in this country, representing approximately 90 percent of our nation's 8,200 state and federal credit unions, which serve over 90 million members.

Summary of CUNA's Views

CUNA broadly supports efforts to increase financial literacy among the American public. In light of current economic conditions, financial education is more important than ever to our country's economic stability and future growth.

Discussion of CUNA's Views

CUNA supports financial literacy efforts and acknowledges the need for expanding current efforts to reach more Americans. In light of today's economic instability, the relevance of this topic is quite apparent. The objective of the Workplace Financial Literacy Honor Roll program is to encourage employers to implement efforts that will ultimately result in enhanced employee financial knowledge.

However, we are concerned with employer costs for such programs and hope Treasury does not focus too much on which employers spend the most money to initiate or maintain a program, but more on efficiency and success.

Additionally, some organizations may not be equipped to provide these programs in-house, and would likely have to contract with a third party for such services. This financial factor should be considered, as it would add to the organization's cost of business and will either be absorbed or passed onto the consumer.

CUNA does agree that promoting financial education is positive, and that in order to have any meaningful impact on society, efforts should come from a variety of avenues. We believe that targeting those at the workplace can be an important means to reach a sector of the public that may otherwise be inaccessible. Having several concerns about the feasibility of implementing such programs, we ask that the Office of Financial Education offer guidance on establishing and maintaining such programs with minimal costs to the organization. Additionally, suggestions on how to effectively reach employees, as well as encourage participation in the program, would be appreciated.

Thank you for the opportunity to express our views on the Workplace Financial Literacy Honor Roll program. If you have questions 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 Research Counsel