ORLANDO, Fla. – Credit unions' decision to roll their CUSOs' investment services back under the credit union's roof as a result of the No-Action Letter, is an individual business decision each credit union will have to make on their own, but integrating the CUSO's functions with the CUs may prove to be both a challenge and an opportunity. NACUSO General Counsel Guy Messick said there's still no word on when the SEC will issue its anticipated No-Action letter which is expected to prohibit CUSOs from engaging in certain securities activities without registering with the SEC as a broker/dealer and from sharing in the commission with broker/dealers. But he advised CUs to get all the facts before they make any decision concerning their financial services CUSO. "It's the difference between someone having a sales mentality and someone else having a service mentality, that's what our challenge will be," said one attendee at a workshop NACUSO held on the pending SEC No-Action letter. Ann Colucci, manager, Investment Group at Kraft Foods FCU, White Plains, N.Y. described the situation as "a cultural problem" and said she understands the difficulty that's involved for some credit unions. "Investment reps are commissioned employees and typically make more money than salaried credit union employees, yet they'll be working with them. It will be hard for some people to swallow," she said. Kraft Foods FCU may actually be able to count itself as being among the lucky few that should face minimal transition difficulties. Since March 2002, Investment Group reps have worked on a commission basis as employees of VeraVest Investments Inc., of Allmerica Financial Inc., Worcester, Mass. When they eventually work under Kraft Foods FCU's roof, they will continue to be VeraVest Investment employees. Central Florida Educators CU may not have as easy a time. Eddie Sanabria, director of regulatory compliance, security and facilities for Central Florida Federal Financial Services, a wholly-owned CUSO of Central Florida Educators CU said the credit union plans to continue to have a broker/dealer relationship with CUNA Mutual Member Financial Services after the SEC issues its No-Action letter. The broker/dealer reps will be employees of Member Financial Services and will work in the credit union. Therein lies the potential rub, said Sanabria. He explained that Central Florida ECU requires its staff to go through its `service first' training program' that trains employees on how to interact with members and have a `what else can I do for you' attitude. "It's how they have to close each conversation they have with a member," he said. The dilemma facing Central Florida ECU is that the Member Financial Services reps will not be required to complete the service first training and will consequently may not have the same standards, said Sanabria. "We don't want there to be two standards at the credit union, one on the teller line and another in the financial services area," he said. "That could get confusing to the members. They're accustomed to our high standards, and there could be problems if the reps don't have the same standards." Aside from that, Sanabria said he foresees the transition to run smoothly. Central Florida ECU already has relationships with certain companies under the credit union's umbrella because of incidental powers that are not part of the credit union, such as AFLAC Insurance and Dental Benefits Plus Insurance. Sanabria said so far Central Florida ECU has not taken a preemptive reorganization move pending the SEC decision, "but you want to be prepared," he said. Tammy Douglass, president, Fairwinds Financial Services, a wholly-owned financial services CUSO of Fairwinds CU in Orlando said the credit union's board a few years ago considered having the CUSO's reps be salaried employees because, she said, they were concerned that earning a commission might make the reps "push something that wasn't in the member's interest." The idea didn't carry, and Fairwinds Financial Services has continued to use CUSO Financial Services as its broker/dealer and call its commissioned-paid reps financial consultants. Fairwinds CU plans to bring the reps under the credit union's roof and refer to them as `financial advisors.' "Beyond that, the changes should all be transparent to our members, the only thing that will change will be their housing," said Douglass. [email protected]