WASHINGTON-Mary Dunn, CUNA's associate general counsel and senior vice president for regulatory advocacy, wrote the Financial Management Service in favor of its interim regulation regarding the handling of Treasury checks under Check 21. CUNA objected to going beyond this rule concerning certain consumer protections because they would only be redundant. "We wanted Treasury to parallel what the Fed has done on Check 21 and it did in the proposal and the interim rule." Dunn told reporters last week. "One of the big lingering issues is are there further regulations needed to protect consumers if one of the checks, which is transmitted by electronic image is subject to fraud. In our comment letter, even though we are very supportive of consumers' rights and consumer protection, we did not support further regulations because we felt there were enough rules already in place to correct that." The interim rule covers the rights and obligations of financial institutions presenting electronic images to Treasury, according to CUNA's Jan. 18 comment letter; it provides the legal framework for presenting electronic images without having to later deliver original or substituted checks. The Financial Management Service, a bureau of the Treasury Department, also specifically requested whether a safekeeping provision specific to truncated Treasury checks is necessary, which CUNA felt was not. Financial institutions already apply existing information security procedures to all truncated checks, Dunn pointed out. Additionally, the Financial Management Service sought comment on whether additional regulation was necessary to restrict the use of information on truncated checks. CUNA stated that the current consumer information protections were sufficient, particularly when there is no demonstrated evidence of a problem. However, Treasury should continue to monitor the situation and later determine whether problems warrant new regulation under a separate proposal. The interim final rule took effect Oct. 29 with a subsequent comment period.