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CUNA Regulatory Comment Call

August 4, 2003

EXECUTIVE SUMMARY

• The Department of Defense (DoD) has issued a proposal regarding revision of its existing policy governing personal commercial solicitation and insurance sales on DoD installations. The proposal is issued in connection with the DoD process of rewriting its Directive (DoDD) Number 1344.7. DoDD 1344.7 provides policy and procedural guidance concerning: life insurance products and securities offered and sold to DoD personnel; supervision of on-base commercial activities; prohibited practices; denial and revocation of permission to solicit on-base; advertising policies; and financial education programs.
• CUNA is working with the Defense Credit Union Council to help ensure the existing regulation is not changed in a way that harms the ability of on-base credit unions or credit union service organizations to provide financial services on the military installation.
• Currently, the DoD is seeking comment through August 22, 2003 on whether changes to the existing rule are necessary. DoD will also be holding a hearing on this issue on the 22nd. CUNA will be actively involved to advocate on behalf of DoD credit unions.
• Comments are due to DoD by August 22, 2003. Comments should be sent to: Colonel Michael A. Pachuta or Mr. James M. Ellis at DUSD (MC&FP), 1745 Jefferson Davis Highway, Suite 302, Arlington, VA 22202. Or you may send comments via e-mail. Colonel Pachuta’s e-mail address is: Michael.pachuta@osd.mil. Mr. Ellis’ e-mail is: james.ellis@osd.mil. Please submit your comments to CUNA by August 15, 2003. Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Senior Regulatory Counsel Catherine Orr at corr@cuna.com; or mail them to Mary and Catherine in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. To obtain a copy of the proposal, please contact CUNA contact CUNA or click here. To obtain a copy of the regulation, please contact CUNA or go to the following Internet address: http://usmilitary.about.com/gi/dynamic/offsite.htm?site=http://www.dtic.mil/whs/directives/corres/html/13447.htm.

1. Do you believe the revised Directive should incorporate guidance pertaining to the Commanders' responsibility with respect to financial education?
   
   Yes ______ No ______
   
   Please explain.
   
   

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2. Do you think the revised Directive should provide guidance to curtail the ability of multi-service financial service companies to cross-market services and products that are also offered by credit unions?
   
   Yes ______ No ______
   
   Please explain.
   
   

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3. Do you agree that the revised Directive should clearly reference the right of on-base financial institutions to provide financial services on the installation?
   
   Yes ______ No ______
   
   Please explain.
   
   

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4. Other comments?
   
   

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