CUNA Regulatory Comment Call


May 28, 2004

NCUA Proposal to Authorize FCUs to Serve as Trustees or Custodians for Health Savings Accounts (HSAs)

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE HSA PROPOSAL

  1. Do you agree with the proposed rule changes to provide authority for credit unions the authority to serve as trustees or custodians of HSAs?

    Yes ______ No ______

    If not, why not?
















  2. Is your credit union interested in acting as an HSA trustee/custodian for your members now or in the foreseeable future?

    Yes ______ No ______

    Please explain.
















  3. Do you agree with NCUA’s current position that HSAs will not be treated as a separate category for insurance coverage purposes?

    Yes ______ No ______

    Please explain.
















  4. Other comments?
















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