WASHINGTON-CUNA Assistant General Counsel Jeff Bloch has beenworking with the organization's Consumer Protection Subcommittee ontop priority issues of late, including identity theft guidelinesand bounce protection plans. Bloch said the subcommittee would bereviewing NCUA's proposed identity theft guidelines and helpingCUNA develop its official comment letter. He said the subcommitteemembers would be considering whether the guidance is flexibleenough, particularly for small credit unions. "In the guidance is alot of information about flagging accounts, monitoring accounts,etc. and I think we're going to look closely to see if the smallercredit unions really have the resources and the technology to beable to fulfill the guidance," Bloch said. CUNA's ConsumerProtection Subcommittee will also be commenting on whether fees forbounce protection plans should be reported as an annual percentagerate, which the Fed is looking into. "The problem here is that anyfee that's charged that could even come close to covering the cost,since the loans are short-term, it would be expressed in a veryhigh annual percentage rate," Bloch explained. "First off, forfederal credit unions that are subject to the 18% usury ceiling,that pretty much would mean that they would no longer be able tooffer such programs and also, for other credit unions, since youdon't really know how long the loan will ultimately be, it's a verycomplicated and cumbersome process to try to figure out what thatannual percentage rate is." Bounce protection marketing has beengenerally considered by some as deceptive and CUNA is setting outto separate credit unions from the rest of the pack.