I found Editor-in-Chief Paul Gentile's column of Jan. 18 interesting and on target. No doubt between Congress and NCUA sometime in 2006 we credit unions will and should be required to document our efforts to serve the underserved. The issue as stated, is how to document those efforts. Savings, as Gentile points out, is certainly one vehicle that can be used. However in my view, we will need to be able to benchmark our total efforts to serve a population and not just services used. I feel that we need to be judged on the effort and not simply positive results. People fall into the underserved category for a variety of reasons and there is not going to be one solution for everyone involved. Any CU trying to reach an underserved membership, not simply new members from within the newly added field of membership, while working to fulfill a CU's mission of reaching and serving low-income and disadvantaged potential members, will face a difficult, time-consuming, costly, and repetitive process. If a CU wants to cultivate an underserved area it needs to understand the task involved as well as the CU philosophy. I think once an undersevered area has been approved I would want my CU at a minimum to be able to document the following: 1) Number of potential members, 2) Specific action steps designed to attract members, 3) Marketing processes, costs i.e. types of advertising: mass mailing, door hangers, radio, cable TV ads, meetings with groups of potential members, 4) Response to marketing efforts: how many contacts and at what cost, new members, 5) Number of new accounts opened using a specific account series to identify new members from the underserved area from other branch members, 6) What type of accounts; savings (in all forms offered), checking, loans as well service penetration over the course of a member's time with CU. All to often we look at potential membership but don't understand the work necessary to actually obtain and more importantly retain members. We need members who are profitable to the CU because they use the services provided. To succeed, we need to offer an underserved area services they need not simply services we routinely supply existing membership. When we can document efforts, and more importantly have success, then and only then will the basic credit union rule of members helping members be achieved. Once we do that job no one will be able to validly challenge our role as nonprofit, tax-exempt institutions. William Rupp Director Unity One Federal Credit Union Fort Worth, Texas