Comment Number:	540033-00025
Received:	6/5/2009 7:30:25 PM
Organization:	Cincinnati Central Credit Union
Commenter:	William Herring
State:	OH
Agency:	Federal Trade Commission
Rule:	Disclosures for Non-Federally Insured Depository Institutions under the Federal Deposit Insurance Corporation Improvement Act (FDICIA)
Attachments:

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Comments:

I am writing on behalf of the 21,000+ members of Cincinnati Central Credit Union, a privately insured state chartered credit union located in Cincinati, Ohio. Our members live throughout the greater Cincinnati area including southeast Indiana, northern Kentucky and many states throughout the U.S. CCCU has four locations to serve our diverse membership including a branch in a low income, underserved community of Cincinnati and a branch that serves the Hispanic community. We joined the shared branching network through the Ohio Cedit Union League's service corporation to better serve and offer greater convenience to our members. It is my understanding that the FTC is proposing disclosure signage different from the NCUA rule and that it would require CCCU to impose signage on the federally insured credit unions that are part of the shared branching network. This would not only be not practicable but could jeopardize our membership in the shared branching network. CCCU believes in disclosing to our members that they are privately insured by American Share Insurance (ASI) and we compy with the rules and regulations of disclosure to our members. However, imposing our disclosure requirements on federally insured credit unions is unfair and unworkable. CCCU and its 21,000+ members encourage and request the FTC to adopt the disclosure requirements of the NCUA for shared branching. Thank you for your consideration in this matter William A. Herring, President/CEO Cincinnati Central Credit Union