CUNA Regulatory Comment Call

January 13, 2009

EXECUTIVE SUMMARY

• The Federal Reserve Board (Fed) has issued a proposed rule to amend Regulation E, the Electronic Fund Transfer (EFT) Act, that will provide consumers with certain protections relating to the assessment of overdraft fees. These will apply to automated teller machine (ATM) transactions and one-time debit card overdrafts. This proposal replaces previously proposed rules under the Unfair and Deceptive Acts or Practices (UDAP) Act and the Truth in Savings Act that addressed overdraft protection plans. As a result, this new rule will apply to all credit unions, not just federal credit unions as would have been the case if these provisions were implemented under the UDAP Act.
• The current proposal outlines the following two approaches for providing consumers a choice regarding the payment of ATM and one-time debit card overdrafts by their financial institution and seeks comments on which approach should be adopted in the final rule:
  • Opt-out - Under this approach, an institution would be prohibited from imposing an overdraft fee unless the consumer is given an initial notice and a reasonable opportunity to opt-out of the institution’s overdraft service, and the consumer does not opt-out.
  • Opt-in: This second approach would prohibit an institution from imposing an overdraft fee for paying such overdrafts unless the consumer affirmatively consents to the institution’s overdraft service.
• The proposed rule will also prohibit financial institutions from imposing an overdraft fee when the account is overdrawn because of a hold placed on funds in the consumer’s account that exceeds the actual transaction amount. This prohibition will be limited to debit card transactions in which the actual transaction amount can be determined within a short period of time after the transaction is authorized. Examples include transactions at gas stations and restaurants.
• Comments in response to this proposal are by March 30, 2009. Please submit your comments to CUNA by March 16, 2009

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.com or to Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.com; or mail them to Mary or Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, 6th Floor, Washington, DC 20004. If commenting directly to the Fed, you must refer to Docket No. R-1343. You may also contact us if you would like a copy of the proposal or you may access it here.

BACKGROUND

The EFT Act establishes rights, liabilities, and responsibilities for parties involved in EFT systems, which include transfers through automated teller machines, point-of- sale terminals, automated clearinghouses, telephone bill-payment plans, and remote banking programs. Regulation E implements the EFT Act, which contains official staff commentary that interprets the regulation and provides guidance in applying the regulation to specific transactions.

In February 2005, the National Credit Union Administration (NCUA) and the other financial institution regulators issued guidelines on overdraft protection plans that addressed safety and soundness considerations, legal risks, and best practices. These guidelines will still be in effect after this proposed rule is finalized.

In May 2008, these regulators issued rules under the UDAP Act that would have required institutions to provide consumers with the right to opt-out of overdraft protection plans and would have prohibited fees if the overdraft occurred as a result of a debit hold that exceeded the amount of the transaction. These provisions were not finalized, but are now being proposed again under Regulation E, although they will now be limited to ATM transactions and one-time debit card overdrafts. The other proposed revisions to the UDAP rules have been finalized and are the subject of a separate CUNA Final Rule Analysis.

In May 2008, the regulators issued a related proposal under Regulation DD, the Truth in Savings Act, which outlined the form, content, and timing requirements for providing the opt-out notice and included additional disclosure requirements. This proposal has also been finalized and is the subject of a separate CUNA Final Rule Analysis.

DESCRIPTION OF THE PROPOSED RULE AND CHANGES TO THE OFFICIAL STAFF COMMENTARY

Opt-out / Opt-in Approaches

The proposed rule outlines two alternative approaches for providing consumers a choice regarding the payment of ATM and one-time debit card overdrafts by their financial institution. ATM transactions would include those at both proprietary and foreign ATMs, and debit card transactions would include those at point-of-sale (POS) with a merchant, online, or by telephone. These choices for consumers will not be required for other types of transactions under the overdraft plan, such as checks, automated clearinghouse (ACH) transactions, and preauthorized EFTs. This differs from the earlier proposed UDAP rules in that financial institutions would have been required to provide consumers with the right to opt-out of all types of overdraft transactions. Model forms will be provided that institutions may use to satisfy these disclosure requirements

The proposed rule will apply to both automated overdraft programs and to non-automated, ad-hoc accommodations. The rule will not apply to overdrafts paid pursuant to a line of credit under Regulation Z, including transfers from a credit card account, a home equity line of credit, an overdraft line of credit, or overdrafts paid pursuant to a service that transfers funds from another consumer account.

The proposal provides alternatives for implementing the consumer’s choice for both the opt-out and opt-in approach. One alternative would be for the institution to offer an account with the same terms, conditions, rates, fees, and features that are provided to those who participate in the overdraft plan, except for features addressing the payment of overdrafts. Another alternative would allow institutions to provide such accounts with different terms, features, or conditions, as long as they are not so substantial that they discourage a reasonable consumer from exercising his or her right to opt-out of the plan, or compel a reasonable consumer to opt-in. Below is more information about the opt-out and opt-in alternatives.

I. Opt-out Alternative

Financial institutions would be required to provide consumers with a notice and a reasonable opportunity to opt-out of the overdraft plan for ATM withdrawals and one-time debit card transactions. This must be provided before any fees are assessed, which could also be at the time the account is opened. A fee could then be assessed if the consumer does not opt-out. If the consumer does not opt-out or revokes a previous opt-out election, an additional notice would also be sent during any periodic statement cycle in which a fee is assessed, although the consumer would be obligated to pay the fee in those situations. The initial opt-out notice would not be required for accounts opened before the mandatory compliance date of this rule, although opt-out notices for these accounts will be required whenever an overdraft fee is assessed in the future in connection with an ATM or debit card overdraft. The proposed rule will require an institution to treat an opt-out direction by any joint accountholder as an opt-out from all the accountholders.

The institution may still pay the overdraft if the consumer chooses to opt-out, but cannot charge a fee, except under these circumstances:

• The institution reasonably believes there are sufficient funds in the account at the time the institution authorizes the transaction. Here are some examples of these situations:
  • An authorization balance is not updated in real time.
  • The institution authorizes a transaction on the reasonable belief that a previous deposit was good, and that item is then subsequently returned, which causes the transaction to overdraw the account.
  • The settlement exceeds the amount submitted for pre-authorization.
  • In connection with a force-post, or must pay, debit card transaction that an institution is required to honor when, at settlement, intervening transactions by the consumer have reduced the balance below the authorized amount of the transaction.
• The merchant or payee presents a debit card transaction for payment by paper-based means, rather than electronically using a card terminal, and the institution has not previously authorized the transaction.

The proposal provides that a consumer has a “reasonable opportunity” to opt-out if he or she has thirty days to make this decision after receiving the notice. A shorter time may be considered adequate, depending on the circumstances. Methods of exercising the opt-out include the following:

• The institution provides a written form that the consumer may fill out and mail.
• The institution provides a toll-free telephone number that the consumer may use.
• The consumer exercises the opt-out electronically. This may include an online form, as long as the institution directs the consumer to a specific web page to access this form, as opposed to referring the consumer to the institution’s home page.
• The institution provides an opt-out notice prior to or at the time the account is opened and requires the consumer to decide whether to opt-out as a condition to opening the account.

The following are two exceptions to the requirement of providing consumer notice and a reasonable opportunity to opt- out of the payment of overdrafts for ATM withdrawals and one-time debit card transactions:

• The institution has a policy and practice of declining to pay these transactions if it has a reasonable belief that the consumer does not have sufficient funds to cover these expenses.
• The institution requires the consumer to affirmatively consent, or opt-in, before assessing fees for paying overdrafts for these types of transactions.

The institution may not condition a consumer’s right to opt-out of the payment of ATM withdrawals or one-time debit card transactions under an overdraft plan on the consumer also opting out of the overdraft service with regard to other types of transactions, such as checks, ACH, or preauthorized EFTs. The proposed rule will also prohibit an institution from declining to pay overdrafts for these other types of transactions because the consumer has opted out of the overdraft service for ATM and debit card transactions.

Institutions will still have discretion to pay overdrafts, but the proposal will require that the institution apply the same criteria for deciding to pay overdrafts for checks, ACHs, and other types of transactions, regardless of the consumer’s opt-out choice with respect to ATM and debit card transactions. However, the Fed is considering another approach in which an institution would be permitted to condition the consumer’s ability to opt-out of the overdraft service for ATM and debit card transactions on the consumer also opting out of the service for checks and other types of transactions. This means the institution may decline to pay checks, ACH, and other types of transactions if the consumer has opted out for ATM withdrawals and one-time debit card transactions. This other approach is intended to address the operational issues associated with implementing a partial opt-out rule.

As noted above, if the consumer does not opt-out or revokes a previous opt-out election, he or she must receive additional opt-out notices in each periodic statement cycle in which an overdraft fee is assessed. Again, the consumer is obligated to pay the fee, even if he or she decides to opt-out after receiving the additional notice. A fee may also be assessed if the consumer has opted out but incurs an overdraft before the opt-out has been implemented, although the institution must comply with a consumer’s opt-out request “as soon as reasonably practicable” after receiving it. The consumer’s election to opt-out will remain in effect until it is revoked by the consumer.

These additional notices may be provided on the periodic statement or by way of a separate notice that is sent promptly after the overdraft occurs. If this notice is provided on the periodic statement, the opt-out information must be in close proximity to the aggregate totals for overdraft and returned item fees that will now be required to be disclosed under the recent changes to Regulation DD, the Truth in Savings Act. The obligation to provide these additional opt-out notices continues until the consumer decides to opt-out of future overdrafts.

The proposal provides model forms for both the initial opt-out notice and the additional notices that are provided during the periodic statement cycles in which overdraft fees are incurred. The initial notice provides detailed information about the overdraft service and the right to opt-out and includes the following information:

• The maximum fee or range of fees.
• The dollar limits on fees that may be assessed or that there is no limit.
• That the consumer has the right to opt-out and the methods that may be used to exercise this opt-out right.
• How to contact the institution for more information.
• Whether the institution offers alternatives to the overdraft plan and how to obtain more information about them.

Although institutions must use notices that are substantially similar to the model forms, for both the initial and additional notices, the proposed rule will permit institutions to provide certain, additional information in the initial notices. This includes an explanation regarding the types of transactions that would not be covered by the opt-out, an indication that the payment of overdrafts is discretionary, and an explanation as to the consequences of opting out of overdraft services.

For the additional notices that are provided during the periodic statement cycles in which a fee is incurred, the institution may provide a notice that is the same as the initial notice or an abbreviated version. A model form is provided for this abbreviated version, which generally states the right to opt-out, the availability of alternatives to the overdraft service, and how to contact the institution for more information.

II. Opt-in Alternative

Under this alternative, financial institutions would provide consumers with a notice of the right to opt-in, or affirmatively consent, to the overdraft service for ATM withdrawals and one-time debit card transactions. This notice must explain the overdraft service and provide a reasonable opportunity to consent, or opt-in, to the service. The institution must provide confirmation of the consent if the consumer decides to opt-in. A fee cannot be charged until the notice is provided and the consumer elects to participate in the plan for these transactions. No subsequent notices would be required under this approach, such as the additional notices when overdraft fees are incurred, as would be required under the opt-out approach.

If the consumer does not opt-in, the institution may still pay the overdraft if it does not charge a fee. The institution may also refuse to pay an overdraft, even if the consumer affirmatively consents to the overdraft service, since these programs are designed to be discretionary.

To obtain the consumer’s opt-in, the institution must provide a notice explaining the overdraft service for ATM and debit card transactions. The notice must be segregated from other information and disclosures, and it must not contain any information that is not otherwise permitted under these rules. A notice will not be required if the institution has a policy and practice of declining to pay these transactions if it has a reasonable belief that the consumer does not have sufficient funds to cover these expenses.

The opt-in notice must be in a form that is substantially similar to the model notice that is provided in the rule. Any consent from a joint accountholder will be treated as an affirmative consent from all the joint accountholders.

The proposed rule requires the institution to provide a reasonable opportunity for the consumer to opt-in to the overdraft plan and to provide reasonable methods for providing the consent. Methods of exercising the opt-in include the following, which are similar to those that would be used for the opt-out alternative:

• The institution provides a written form that the consumer may fill out and mail. However, the institution may not obtain the consumer’s consent by including preprinted language that is provided with a signature card or contract that the consumer must sign to open the account, which would acknowledge the consumer’s acceptance of the terms. Similarly, the institution may not obtain the consumer’s consent by providing a signature card containing a preselected check box indicating that the consumer is requesting overdraft services.
• The institution provides a toll-free telephone number that the consumer may use.
• The consumer exercises the opt-in electronically. This may include an online form, as long as the institution directs the consumer to a specific web page to access this form, as opposed to referring to the institution’s home page.
• The institution provides an opt-in notice prior to or at the time the account is opened and requires the consumer to decide whether to opt-in as a condition to opening the account.

The institution cannot condition the payment of any overdrafts for checks, ACH, or other types of transactions on the consumer also consenting to the payment of overdrafts for ATM and debit card transactions. Similarly, an institution may not decline to pay checks, ACH, or other types of transactions because the consumer has not also consented to the overdraft service for ATM and debit card transactions.

In general, the decision to pay overdrafts is still discretionary, but the institution must apply the same criteria for deciding when to pay overdrafts for checks, ACH, or other types of transactions, regardless of whether the consumer has consented to the overdraft service for ATM and debit card transactions. However, the Fed is considering another approach in which institutions would be permitted to condition the payment of an overdraft for check, ACH, and other types of transactions on the consumer also consenting to the overdraft service for ATM and debit card transactions. Under this approach, the institution could then decline to pay checks, ACH, and other types of transactions because the consumer has not consented to the overdraft service for ATM and debit card transactions.

The institution may still pay the overdraft and charge a fee even if the consumer has opted in to the service under the similar exceptions described above for the opt-out alternative approach. These exceptions include when the institution reasonably believes there are sufficient funds in the account at the time the institution authorizes the transaction and if the merchant or payee presents a debit card transaction for payment by paper-based means, rather than electronically using a card terminal, and the institution has not previously authorized the transaction.

The timing requirements for providing the opt-in notice differs, depending on whether the account existed at the time the final version of this rule becomes effective. For new accounts, the notice must be provided before an overdraft fee may be assessed. For existing accounts, the rule will require institutions to provide notices to existing accountholders so that they are made aware of their rights to enroll in the overdraft program. These notices may either be provided to all the existing accountholders on or with the first periodic statement that is sent after the final rule goes into effect or provided following the first assessment of an overdraft fee that is on or after the date the rule becomes effective. If an existing consumer has not opted in within sixty days after receiving the notice, then the institution must cease assessing fees for overdraft services, unless a fee is permitted under one of the exceptions described in the above paragraph. However, fees may be assessed for all overdrafts during this sixty-day period.

These notice requirements for existing accounts would only apply for those specific accounts in which overdraft services are provided at the time the rule becomes effective. Therefore, institutions would not be required to provide these initial notices to those who have already opted out of or have not affirmatively consented to the overdraft service, depending on whether the institution currently has an opt-out or opt-in system. Institutions electing to provide notices before the rule becomes effective would not have to provide additional notices, as long as consumers were provided a reasonable opportunity to opt-in.

An opt-in election from a consumer will be effective until it is revoked by the consumer. However, the institution may also terminate access to the overdraft program, such as in situations in which there is excessive usage of the program by the consumer.

Debit Hold Provisions

The proposed rule will prohibit institutions from assessing an overdraft fee if the overdraft would not have occurred but for a debit hold that was placed on funds in an amount exceeding the actual transaction and if the merchant can determine the actual transaction amount within a short period of time after authorization (for example, gas and restaurant purchases). This prohibition will not apply if the institution adopts procedures designed to release the hold within a reasonable period of time, and the rule provides that two hours will be considered reasonable.

This prohibition will also not apply if the amount of the transaction itself would have caused the overdraft to occur or if the overdraft occurs for reasons other than the hold. Examples may include prior debit card transactions that may have been authorized but not yet presented for settlement or when a deposited check in the account is returned.

As mentioned above, the prohibition will not apply if the actual transaction amount cannot be determined for a considerable period after the merchant has submitted the transaction for authorization. Examples would include hotel stays and rental car transactions.

Even if the overdraft fee is prohibited under these provisions for debit holds, an institution will not be considered in violation if it promptly waive or refunds the fee. However, the institution may not require the consumer to provide notice or other information about the overdraft as a condition for the waiver or refund.

The proposal also describes the interaction between these debit hold provisions and the opt-in or opt-out requirements described above. Specifically, if a consumer is not enrolled in the overdraft service for ATM withdrawals or debit card transactions, either because he or she has opted out or not opted in, the institution may not assess a fee in connection with a debit hold even if the institution is otherwise not prohibited from doing so by these debit hold provisions, as outlined under the scenarios described above.

• Should this rule apply to recurring debit card and ACH transactions, in addition to ATM withdrawals and one-time debit card transactions? What would be the appropriate amount of time that institutions should have to implement this rule?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Once a consumer receives an opt-out notice, he or she must be given a reasonable amount of time to exercise the opt-out, with 30 days being considered reasonable. Would a shorter time period, such as 15 or 20 days, be more appropriate?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Should institutions be required to provide a toll-free telephone number as a means to opt-out of the overdraft program? Should the rule add examples of opt-out methods that would not comply with the requirement to provide a reasonable opportunity to opt-out, such as requiring the consumer to write a letter?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• A financial institution will not be allowed to condition the right to opt-out of the overdraft service for ATM and debit card transactions on the consumer also opting out of the service for checks, ACH, and other transactions. The rule will also prohibit an institution from declining to pay checks, ACH, and other transactions because the consumer opted out of the service for ATM and debit card transactions. What are the merits of this approach and are there other, more effective means to ensure consumers are not discouraged from opting out of the overdraft service for ATM and debit card transactions?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• The Fed is considering another approach in which an institution would be permitted to condition the consumer’s ability to opt-out of the overdraft service for ATM and debit card transactions on the consumer also opting out of the service for checks and other types of transactions. This means the institution may decline to pay checks, ACH, and other types of transactions if the consumer has opted out for ATM withdrawals and one-time debit card transactions. This other approach is intended to address the operational issues associated with implementing a partial opt-out rule. What are the merits of this approach and are there other approaches that would also address operational concerns, while not discouraging consumers from exercising the opt-out?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• The proposal provides alternatives for implementing the consumer’s choice for both the opt-out and opt-in approach. One alternative would be for the institution to offer an account with the same terms, conditions, rates, fees, and features that are provided to those who participate in the overdraft plan, except for features that address the payment of overdrafts. Another alternative would allow institutions to provide such accounts with different terms, features, or conditions, as long as they are not so substantial that they discourage a reasonable consumer from exercising his or her right to opt-out of the plan, or compel a reasonable consumer to opt-in. What are your views on these alternatives? Do you currently place consumers in different accounts, based on whether they elect to use the overdraft service, and do you vary the terms on these accounts? If so, which terms are different and why are they different?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Should the opt-out notice be segregated from other disclosures to ensure the notice will be seen by the consumer?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• For the opt-out notices that are on periodic statements, should institutions be permitted to include the notice in any cycle in which a fee has been assessed, even it was not incurred in connection with an ATM or debit card transaction? Should institutions be permitted to provide opt-out notices on periodic statements, even if no fees were assessed? Will the operational benefits of either of these approaches be outweighed by the fact that consumer may just consider this boilerplate language, especially if the notice is on every periodic statement?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• The notice to the consumer must include the maximum fee, or range of fees. Is additional guidance needed if a fee is determined by other means, such as if it is based on a percentage of the overdraft or a percentage of the transaction? Is there other information that should be included in these notices, other than what is required or permitted under this proposed rule?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• The proposed rule requires that the institution comply with a consumer’s opt-out request as soon as “reasonably practicable” after the institution receives it. Is more guidance needed on the term “reasonably practicable” and how long it should be? Should a consumer be permitted to revoke the opt-out orally, such as by telephone or in person? What are the other costs and benefits of the opt-out process, as described in this proposed rule and how do these costs and benefits compare to the opt-in approach?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• The proposed rule will prohibit the institution from conditioning the payment of overdrafts for checks, ACH, and other transactions on the consumer opting in to the payment of overdrafts for ATM and debit card transactions. Likewise, the institution would be prohibited from declining to pay checks, ACH, or other transactions because the consumer did not opt-in to the service for ATM and debit card transactions. What are the merits of this approach? Are there other means to ensure consumers are not compelled to opt-in to the overdraft service for ATM and debit card transactions?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Alternatively, the Fed is considering allowing institutions to condition the payment of overdraft for checks, ACH, or other types of transactions on the consumer also opting in to the program for ATM and debit card transactions. What is the merit of this approach and is this preferred in order to address operational issues associated with implementing the opt-in to specific transactions, as opposed to all transactions? Are there other approaches that address concerns about compelling consumers to opt-in to ATM and debit card transactions in order to have overdrafts paid on checks, while also addressing the operational issues for the institutions?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Is there a better approach with regard to the opt-in process for existing consumers? Instead of just an opt-out or opt-in process, the Fed is considering a hybrid approach in which there would be an opt-out rule for existing accounts and an opt-in rule for new accounts. Under this approach, the institution could continue to pay overdrafts and assess fees for ATM and one-time debit card transactions for existing consumers who have not opted out, but would be prohibiting from assessing fees on new consumers who have not opted in to the overdraft service. What are your views on this alternative approach?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Under the opt-in approach, the institution must cease assessing fees for overdraft services if an existing consumer has not opted in within sixty days after receiving the notice. Is sixty days adequate or should it be longer or shorter?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Overall, what are the costs and benefits of the opt-in approach, for both consumers and financial institutions? Would the opt-in or opt-out approach be more optimal for institutions and consumers? Do either of these approaches present unique operational or cost issues that would not be associated with the other approach?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• The prohibition on overdrafts in connection with debit holds will not apply if the institution adopts procedures designed to release the hold within a reasonable period of time, and the rule provides that two hours will be considered reasonable. Do you agree with this approach or would another time period be more appropriate in light of operational constraints at smaller institutions, which may only receive authorization and settlement information periodically during the day?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• The debit hold overdraft prohibition applies in situation in which the merchant can determine the actual transaction amount within a short period of time after authorization of the transaction. Is more guidance needed with regard to this timing requirement? Do you have comments on any other aspects of these debit hold provisions, especially the cost and benefits for both institutions and consumers? Should the Fed issue additional rules to require merchants or processors to submit debit card transactions promptly for settlement? Should they be required to submit them within the two hour time period described in the previous question?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  
• Other comments?
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

  ---

  
  
  

Copyright © 2009 - Credit Union National Association, Inc.