CUNA Regulatory Comment Call


May 31, 2005

Fidelity Bond and Insurance Coverage for Federal Credit Unions

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE PROPOSAL

  1. Do you agree with the qualifying factors for the increase in deductible limits?

    Yes ______ No ______

    If not, would different criteria, such as the capital standards in NCUA’s Prompt Corrective Action (PCA) regulation, be a more appropriate measure to link to the higher permissible deductible?
















  2. Do you agree with the increase in the minimum bond coverage requirements?

    Please explain.













  3. The current rule states that an FCU/FISCU should purchase additional coverage when circumstances, such as cash on hand or cash in transit, warrant. Are there additional activities the regulation should include as suggested factors that credit unions may want to consider in determining whether to raise their bond coverage above the regulatorily required amounts?

    Yes ______ No ______

    If yes, what are those factors?










  4. The proposal notes that Credit Union Blanket Bond Standard Form 23 of the Surety Association of America has not been changed since 1950 and is no longer used by many credit unions. Should NCUA rescind its approval of this Form?

    Yes ______ No ______

    Why or why not?
















  5. 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
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com