Looking back 12 years ago finds private insurers divided on whether to write their own disclosures or continue to wait for disclosure regulations. While the Washington Credit Union Share Guarantee Association has opted for the former, American Share Insurance is attempting to persuade the Federal Trade Commission to engage in negotiated rule-making, which would allow the credit union movement and the insurance industry to work directly with the agency as it drafts disclosure regulations-thereby avoiding drastic changes and eliminate the need for a comment period. According to ASI General Counsel Duane Welsh "to run out there and anticipate what the FTC is going to do is the act of a fool". "It seems futile to try to concoct a foolish disclosure that may not comply with anything- why go through all the expense and the risk of creating apprehension? You have to be careful that in an attempt to disclose, you don't create a crisis," said Welsh. That issue also finds the credit union interest in shared branching soaring. "We've been wondering when credit unions around the country were going to figure out that shared branching makes a lot of sense," said Service Centers Corporation President Dan Balagna.