Disclosures for Non-Federally Insured Depository Institutions under the Federal Deposit Insurance Corporation Improvement Act (FDICIA) #540033-00013

Submission Number:
540033-00013
Commenter:
Jeff York
Organization:
CoastHills Federal Credit Union
State:
CA
Initiative Name:
Disclosures for Non-Federally Insured Depository Institutions under the Federal Deposit Insurance Corporation Improvement Act (FDICIA)

Re: Supplemental Proposed Rule for FDICIA Disclosures, Matter No. R411014 Secretary: CoastHills Federal Credit Union currently provides financial services to 65,000 members in the Santa Barbara and San Luis Obispo Counties. Our credit union has $650 million in total share/deposit accounts and operates 11 branch facilities. As a federally insured credit union participating in the shared branching network, we are writing in opposition to your agency’s supplemental proposed rule Section 320.4(a)(1) suggesting consumer disclosure requirements for privately insured credit unions also be posted at branches of federally insured credit unions participating in the FSCC shared branching network. NCUA rules and regulations governing shared branching facilities are designed to advise members that their accounts are federally insured at our credit union, and to remind visiting members that their credit union may not be federally insured. We find the current signage provides the appropriate language regarding insurance of members’ accounts, and to implement your agency’s proposed requirements could result in confusion to members – both federally and privately insured. Respectfully submitted, Jeff York President/CEO CoastHills FCU