July 10, 2002
Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street N.W.
Washington DC 20549-0609
Regarding File: S7-12-01
Dear Members of the Securities and Exchange Commission,
Thank you for this opportunity to comment on the exemption request made by Evangelical Christian Credit Union (ECCU) to offer sweep investment services directly to its members. We are interested in this because granting this request would specifically apply to faith-based, non-profit organizations, such as my own.
I am the Chief Financial Officer of World Vision USA, a non-profit, donor-supported organization. Founded in 1950, World Vision is a Christian relief and development organization, assisting the world's poorest children and families in nearly 100 countries. You may be familiar with World Vision by name or perhaps know someone who sponsors, by a monthly donation, a child who benefits from improved medical care, food, clothing, clean water, improved agriculture methods, shelter, education, micro-enterprise development loans, etc.
As an organization, World Vision has been a corporate member of ECCU since 1990. We truly appreciate working with an organization like ECCU as it rare to find a financial institution that focuses on the unique cash management needs of non-profit organizations. In many cases, donor-supported organizations are, at best, misunderstood and may even be viewed negatively by commercial banks. World Vision is representative of most non-profit ministry organizations in the U.S.
World Vision receives donations and grants that exceeded $500 million last year. The majority of this comes in the form of small donations of $26 per month to sponsor a child in one of our projects overseas. As a non-profit organization, our donors demand a high degree of competence in the administration of the funds they entrust to World Vision. The donation cycle tends to be somewhat predictive, yet donations vary during the course of the year. For organizations, like World Vision, liquidity is a concern, yet we must manage our financial resources prudently and safely. The sweep investment service proposed by ECCU would meet the liquidity, safety, and yield requirements of non-profit ministries, such as ours, and allow us to effectively meet our financial objectives throughout the year.
We wish to endorse this effort by ECCU and strongly recommend the approval of ECCU's exemption to offer a sweep investment product. This would represent a significant benefit to non-profit organizations and their distinct cash management needs. Thank you for your consideration.
Chief Financial Officer
World Vision, Inc.