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Editors Note: Chuck Bruen, CEO of First Entertainment CU, Hollywood, Calif., has sent this comment letter to NCUA, which he has shared with readers of Credit Union Journal.

Re: First Entertainment Credit Union Comments on Potential Voluntary Prepaid Assessments Program. On behalf of First Entertainment Credit Union, I appreciate the opportunity to comment to the members of the National Credit Union Administration Board about the proposed Temporary Corporate Credit Union Stabilization Fund (TCCUSF) Voluntary Prepaid Assessments Program.

First Entertainment is an $860-million in assets, 58,000-member California-chartered, federally insured credit union headquartered in Hollywood, Calif. Although our credit union has no intention of participating in the voluntary prepaid assessments program, we fully support the idea and hope that many credit unions jump on board. Further, we appreciate the NCUA Board's implied offer to help with our credit union's surplus liquidity through a long-term, zero-interest loan to the TCCUSF that is at the core of this voluntary prepayment plan. We also would support the publishing of a list of those credit unions that participate in the program, so we can thank each of them for magnanimously lowering our credit union's 2011 and 2012 TCCUSF assessment costs.

We admire credit unions that are willing to step up and make zero-interest loans to the NCUA-managed TCCUSF. Such charity is a creative variation on providing loans to those of modest means-in this case the NCUA. We understand that natural-person credit unions are going to pay for the corporate credit union crisis in one way or another, and this program enables the most charity-minded credit unions to nobly pay more than those of us more focused on preserving our members' capital. This is a win-win situation for everyone involved.

Our credit union has no shame in sitting back and watching others financially support the Voluntary Prepaid Assessments Program while we enjoy whatever negligible short-term benefits that might come our way. If we are to be labeled free-riders, free-loaders, or even free-spirits, we will wear that badge with honor. Regardless, we take comfort in the knowledge that our membership would applaud our decision to place their interests first. It is our fervent hope that the NCUA Board will devise similar plans that will transfer some of the burden associated with the corporate credit union crisis away from us and onto others.

We again thank the NCUA Board for offering this proposal and hope that it is subscribed to by other credit unions to the maximum allowed levels of prepayments. I welcome any questions concerning these comments.

Charles Bruen, President & CEO
First Entertainment Credit Union,
Hollywood, Calif.

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