Associated School Employees Credit Union
June 12, 2005
Proposed Rule for FDICIA Disclosures, Matter No. R411014
Federal Trade Commission/ Office of the Secretary
Room H-159 (Annex A)
600 Pennsylvania Avenue, N.W.
Washington, D.C. 20580
The Associated School Employees Credit Union is a State Chartered, Privately
Insured Credit Union located in the Youngstown Area of Northeast Ohio. We
have approximately 9,000 members and assets of close to $60 million. The
credit union was charted in 1959 to serve the financial needs of school
As indicated, our credit union is privately insured and has been since well before
June 19, 1994. The fact that we are privately insured is a direct result of the
credit union making a decision that it felt best served its needs. It is not the result
of our credit union being a second class credit union that would not be able to
obtain Federal Share Insurance. In fact the credit union has a capital ratio of
close to 15% and operates in a sound manner that is evidenced in both its
examinations and audits.
We have received notice that the Federal Trade Commission (FTC) has proposed
several rules that could have a negative impact on the credit union and to a
degree impact the very safety and soundness of the deposits that the rules are
trying to protect.
Perhaps the most onerous of these rules is the one described in Section 320.5
that states in part:
“… depository institutions lacking federal deposit insurance are prohibited from
receiving any deposit for the account of a new or existing depositor unless the
depositor has signed a written
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