CUNA Regulatory Comment Call


April 3, 2007

Records Preservation Program and Catastrophic Act Preparedness

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE INVITATION TO COMMENT

  1. Do you agree with the proposed modification in the definition of “catastrophic act” to state that either physical destruction or damage to the FICU, as in the current rule , or interruption in vital member services lasting more than 2 business days would qualify?

    Yes ______ No ______

    Please explain.
















  2. Do you agree with the new definition of vital records?

    Yes ______ No ______

    Please explain.
















  3. Do you feel the definition of vital member services is complete and appropriate?

    Yes ______ No ______

    Please explain.
















  4. In the proposal, the Board recognizes that FICUs generally engage in some form of planning for catastrophic acts and have access to existing guidance on disaster preparedness, which is parallel. In light of those facts, the Board is specifically requesting feedback on the usefulness of providing recommendations to assist FICUs to prepare for catastrophic acts. Do you believe there is a need for the proposed Appendix B – Catastrophic Act Preparedness Guidelines?

    Yes ______ No ______

    Please explain.
















  5. Other comments?
















    Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
    Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
    Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
    Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
    Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com