CUNA Regulatory Comment Call


July 14, 2000

ACCOUNTING BY CERTAIN FINANCIAL INSTITUTIONS AND ENTITIES THAT LEND TO OR FINANCE THE ACTIVITIES OF OTHERS

(STATEMENT OF POSITION)

EXECUTIVE SUMMARY

The American Institute of Certified Public Accountants (AICPA) has distributed a proposed Statement of Position (SOP) exposure draft with the aim of reconciling and conforming its 3 Audit and Accounting Guides - Banks and Savings Institutions Guide (BSI Guide), Audits of Credit Unions (CU Guide) , and Audits of Finance Companies (FC Guide) - to create a combined AICPA Audit and Accounting Guide (new Guide or combined Guide. The provisions of this proposed SOP are to be effective for financial statements issued for fiscal years beginning after December 15, 2000, and for financial statements for interim periods in fiscal years after the year in which the proposed SOP is first applied.

AICPA requests comments on the proposed SOP by August 31, 2000. Please submit your comments to CUNA by August 25, 2000. Please feel free to fax your responses to CUNA at 202-371-8240; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Regulatory Advocacy Attorney Catherine Orr at corr@cuna.com. Responses may also be mailed to Ms. Sydney Garmong, Technical Manager, Professional Standards and Services, File 2373, AICPA, 1455 Pennsylvania Avenue, N.W., Washington, D.C. 20004-1081 or e-mailed to sgarmong@aicpa.org. Please forward any comments sent directly to AICPA to CUNA as well.

REQUIREMENTS ELIMINATED FOR CREDIT UNIONS

NEW REQUIREMENTS FOR CREDIT UNIONS

CORPORATE CREDIT UNIONS

Corporate credit unions are included in the scope of the proposed SOP. Corporate credit unions, which were previously excluded from the scope of the CU Guide, will now be subject to all of the accounting, reporting, and disclosure provisions in the new combined Guide, including disclosure about regulatory capital and net worth requirements.

Questions Regarding AICPA Proposed Statement of Position

SCOPE

RECOGNITION AND MEASUREMENT

PRESENTATION AND DISCLOSURE

EFFECTIVE DATE AND TRANSITION

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