VIA EMAIL: rule-comments@sec.gov
-.- * -. .-. -
SEC
100 F Street, NE
Washington, DC
"- ~~ -~-. Re: . . Fair value accounting (SFAS 157)
To whom it may concern:
Western Corporate Federal Credit Union (WesCorp) is a corporate credit union and has
a national field of membership sewing 1,065 credit unions in 44 states, offering liquidity,
balance sheet solutions and payment system services to its member credit unions. As a
liquidity provider, marketablesecurities make up the bulk of our assets, which we use
primarily as collateral for liquidity purposes, most of which are backed by residential
mortgage assets. Specifically, we have total assets of $25.2 billion, of which $21.6
billion, or 86% of all assets, are held in marketable securities classified as either
available-for-sale or held-to-maturity. As a federally-chartered credit union, WesCorp is
regulated and insured by National Credit Union Administration (NCUA). While we are
not an SEC registrant,we increasingly are impacted by SEC actions.
Corporate credit unions generally operate on very thin margins, and thus, tend to be risk
VIA EMAIL: rule-comments@sec.gov-.- * -. .-. -SEC100 F Street, NEWashington, DC"- ~~ -~-. Re: . . Fair value accounting (SFAS 157)To whom it may concern:Western Corporate Federal Credit Union (WesCorp) is a corporate credit union and hasa national field of membership sewing 1,065 credit unions in 44 states, offering liquidity,balance sheet solutions and payment system services to its member credit unions. As aliquidity provider, marketablesecurities make up the bulk of our assets, which we useprimarily as collateral for liquidity purposes, most of which are backed by residentialmortgage assets. Specifically, we have total assets of $25.2 billion, of which $21.6billion, or 86% of all assets, are held in marketable securities classified as eitheravailable-for-sale or held-to-maturity. As a federally-chartered credit union, WesCorp isregulated and insured by National Credit Union Administration (NCUA). While we arenot an SEC registrant,we increasingly are impacted by SEC actions.Corporate credit unions generally operate on very thin margins, and thus, tend to be risk
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