Add my name to those who agree with Jim Blaine, president/CEO, State Employees CU in Raleigh, N.C. Credit unions do not need bankruptcy reform. City-County CEO Dean Nelson could not have made that point more clearly than when he stated his credit union has a charge-off rate of .45%. A look at the overall charge-off rate for credit unions and you won't find much of a bankruptcy problem. SAFE Credit Union reviews every bankruptcy filing for signs of abuse. We rarely find abuse. What we do find is that our members who file have debts beyond their means. All of the member's excessive debt was issued by a financial institution. Making bankruptcy more difficult for the borrower just encourages aggressive underwriting. Credit unions have a history of consumer advocacy. I would rather see credit unions devote their energy to supporting Consumer Credit Counseling as a means to help members who have debt problems. There are many tools to identify members who have debt problems and need counseling. The entire basis of credit scoring and underwriting is to determine the member's credit worthiness and the overall level of debt. Many of those who complain the loudest about bankruptcy either don't use these tools effectively or they assume that their borrower is an exception. Credit scoring has an unfortunate disadvantage. It allows lenders to make virtual loans where the lender and the borrower never meet. Even for the most credit challenged member there is no counseling and therefore no compact and no bond to the credit union. Many of the bankruptcy reform advocates talk about accountability and personal responsibility. Yes, it is always the borrower who has to be accountable and responsible. When do we hold MBNA and Capital One accountable and all of the other mega lenders who flood our mail boxes with credit offers to the extent that our jobless and dependent college students are offered credit? Go ahead and pass bankruptcy reform. Hold the member accountable and responsible. But until lenders are held responsible and accountable there will be more and more families and individuals that are loaded with debt. We are the financial experts. We have a physician-like role with our members when we issue credit. Do no harm. At a minimum those who make careless lending decisions ought to suffer a loss. The bankrupt member certainly does. Henry W. Wirz President SAFE Credit Union North Highlands, Calif.