WASHINGTON-CUNA and NAFCU each wrote the Federal Reserve Board and Federal Trade Commission to endorse the recently proposed effective dates for certain provisions of the Fair and Accurate Credit Transactions Act. The agencies previously requested comment on a proposed effective date of March 31, 2004 for changes in the law that do not require significant alterations in business procedures. They also proposed an effective date of Dec. 1, 2004 for provisions that could lead to big changes. An interim final rule issued at the same time provided for a Dec. 31, 2003 effective date for the federal preemption provisions in the FACT Act, which renewed portions of the Fair Credit Reporting Act. "The December 1, 2004 effective date for a number of these provisions provides the maximum amount of time permitted under the FACT Act, which we believe is the proper approach given the scope and complexity of the Act," CUNA's letter, signed by Assistant General Counsel Jeff Bloch, read. "Credit unions will need as much time as possible in order to comply with these provisions, as well as provide appropriate training for their staffs." CUNA also expressed its appreciation for a clarification from the Fed and FTC that state identity theft laws will remain intact until the FACT Act provisions become effective.