CUNA Regulatory Comment Call


June 14, 2002

Accounting and Disclosure Requirements for Guarantees

EXECUTIVE SUMMARY

DESCRIPTION OF THE PROPOSAL

QUESTIONS ABOUT THE PROPOSAL

  1. The proposal would require that at the time a guarantor issues a guarantee, the guarantor must recognize a liability for the fair value (market value) of its obligations under that guarantee. Would this initial recognition and measurement provision cause undue burden for your credit union’s accounting practices as they relate to guarantees?

    Yes ______ No ______

    If so, can you quantify that burden?
















  2. The proposal would require grantors to disclose more information regarding guarantees than under current practices, such as the nature of the guarantee. Would making the additional disclosures set forth in this proposal cause undue burden in terms of your credit union’s accounting practices regarding guarantees?

    Yes ______ No ______

    If so, can you quantify that burden?
















  3. 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