LASTOWKA & MESSICK P.C.
ATTORNEYS AND COUNSELLORS AT LAW

JOSEPH E. LASTOWKA, JR.
GUY A. MESSICK*

JOHN B. WHALEN, JR.
KATHERINE E. WEBER**
SUSAN MOESCH POTTS
*Washington State Bar also
**Connecticut Bar also

           THE MADISON BUILDING
108 CHESLEY DRIVE
MEDIA, PA 19063-1712

FAX: (610) 565-9363
TELEPHONE (610) 565-0330

July 16, 2002

Jonathan G. Katz
Secretary
U.S. Securities and Exchange Commission
450 5th Street, NW
Washington, D.C. 20549-0609

Re: File No. S7-12-01

Evangelical Christian Credit Union Request for Sweep Account Registration Exemption

Dear Mr. Katz:

Kindly be advised that I am submitting this letter on behalf of myself, an attorney that primarily represents credit unions and credit union service organizations, as well as General Counsel of the National Association of Credit Union Service Organizations. The purpose of this letter is in response to the SEC's request for comments upon the application of Evangelical Christian Credit Union to offer sweep accounts without registration as a broker-dealer. It is my experience there is a rising demand in credit unions for sweep accounts tied to both consumer accounts and business accounts. While credit unions have not traditionally served the business community, there is a great demand for credit unions to do so. This is partially due to the fact that many banks made a decision that they will not serve businesses under a certain asset size. Some of the credit union business demand has come from members who have retired or have been laid off by their employer and have started businesses as a second career. These businesses typically start out small but as they grow, the demand for services becomes more sophisticated. Unless credit unions are permitted to have sweep accounts, they will be at a severe disadvantage to other financial and non-financial service providers that serve businesses. Likewise, credit unions will be at a disadvantage if they cannot provide sweep accounts tied to consumer accounts.

I submit the following in response to your questions:

I would hope that the sweep registration exemption would be included in the pending comprehensive credit union registration exemption action. Thank you for your consideration.

Respectfully,

Guy A. Messick

cc: Catherine McGuire, Chief Counsel
Lourdes Gonzalez, Assistant Chief Counsel
Robert N. Dorsa, President, NACUSO