| Comment Number: | 515567-00114 |
| Received: | 6/14/2005 9:05:37 AM |
| Organization: | Deere & Company Credit Union |
| Commenter: | William Stangler |
| State: | IL |
| Agency: | Federal Trade Commission |
| Rule: | Disclosures for Non-Federally Insured Depository Institutions under the Federal Deposit Insurance Corporation Improvement Act (FDICIA) |
| Docket ID: | 3084-AA99 |
| No Attachments |
Comments:
Proposed Rule for FDICIA Disclosures Matter No. R411014 Deere and Company Credit Union is an Illinois Chartered, privately insured credit union, which has been in existence for 70 years. We are a closed chartered credit union, which serves the John Deere Employees nationwide, and worldwide through a multiple delivery channel. We have been privately insured since November of 1983. We currently own 19 ATM’s throughout the United States; the ATM’s are located in John Deere facilities to accommodate our remote members. Each regulatory examination and each insurance examination, and each internal audit, and annual external audit, is completed and reported to our supervisory committee, which deliberately and vigorously requires that we seek full compliance with all safety and soundness best practices. We have notified and continue to notify all members and potential members and new members of our insurance status. We specifically state that we are not federally insured, and that the protection of all funds is provided by private insurance. As we understand the ramifications of the proposed matter we would be required to deliver more notification of our status, and in our view create the impression that we are less safe and sound than is the case. Constantly defining what we are not, does not state the strength we are. Our examinations and comparisons with the industry and peers shows us to be a well capitalized credit union with acceptable earnings and exemplary products and expense control. The costs of such campaigns can be estimated and would be an unnecessary burden. The constant implication that we are less sound as a result of our deposit insurance choice is the greater burden and inaccurate in our view. We respectfully submit our lack of support for the proposed matter. Sincerely, William E Stangler President/CEO