**TO:** NCUA Board **DATE:** July 8, 2008

**FROM:** Office of the Executive Director **SUBJ:** Changing of NCUA's
Seal

**ACTION REQUESTED:** NCUA Board's approval of the changing of NCUA's
seal.

**DATE ACTION REQUESTED**: July 24, 2008

**OTHER OFFICES CONSULTED**: Office of the Chief Financial Officer,
Office of General Counsel, Office of Public and Congressional Affairs

**VIEWS OF OFFICES CONSULTED**: Concur

**BUDGET IMPACT, IF ANY:** \$36,832

**RESPONSIBLE STAFF MEMBERS:** Larry Fazio, Deputy Executive Director,
Office of the Executive Director; Frank Kressman, Staff Attorney, Office
of General Counsel

**SUMMARY:** Staff has been contemplating the need for a new National
Credit Union Administration (NCUA) seal for several months. Over the
last few years, it has become increasingly apparent our current seal
contributes to misconceptions about the nature of NCUA with members of
Congress, other government agencies, the media, and the public.
Persistent anecdotal feedback about the seal indicates many perceive an
association to a trade or lobbying organization, or some other form of
private entity, not a federal agency. The current seal does not convey a
clear connection to the federal government and the associated confidence
and security, as well as the strength of the backing of the full faith
and credit of the United States government via federal share insurance.
This is particularly apparent when contrasted with seals used by other
federal financial institution regulators. The roof and door making up
the white portion of the seal (i.e., the "house") is not readily
recognizable, with many people confusing it with an arrow. Further, the
symbolism intended by the roof and door, and overall design, is too
vague to be meaningful to all but a few with knowledge of the history of
the seal. In addition, the house carries an association with housing and
mortgage lending that is not properly representative of credit unions
nor, more importantly, NCUA as the federal regulator and insurer.

Based on our research into seals used by other federal agencies and
various designs considered, we recommend the NCUA Board approve
submission of the proposed new design (see below) to the President of
the United States (President) for approval via Executive Order as NCUA's
new official seal. Attachment 1 contains suggested language for the
President's Executive Order.

**BACKGROUND:** The lineage of NCUA dates back to 1934 with the passage
of the Federal Credit Union Act (FCUA). The 1934 FCUA created a system
of federally chartered credit unions in the United States and
established the Federal Credit Union Division (Division) within the Farm
Credit Administration. In 1942, the Division was transferred to the
FDIC. In 1948, the Division was renamed the Bureau of Federal Credit
Unions (Bureau) and relocated to the Federal Security Administration. In
1953, the Bureau was moved to the Department of Health, Education and
Welfare. In 1970, the Bureau was renamed as the National Credit Union
Administration and made an independent agency. On January 20, 1971,
President Nixon signed Executive Order 11580 establishing a seal for
NCUA (see attachment 2).[^1] In 1979, the NCUA's Administrator was
replaced with a three-member Board.

The current seal's design, circled by the title of NCUA, includes 3 main
elements:

-   A roof intended to symbolize the credit union concept of cooperative
    protection, shared by the common bond members.

-   A door meant to symbolize the opportunity and protection given
    member's shares through the program of insurance by the federal
    government.

-   All white against a blue background of four sections symbolic of the
    major advantages of credit union membership: cultivation of thrift,
    encouragement to save, granting of loans for provident purposes, and
    budget and consumer counseling.

**PROPOSED DESIGN FOR NEW SEAL:** The full color and the black and white
versions of the proposed new seal are as follows:

**Full Color Black & White**

![](media/image1.jpeg){width="2.6479166666666667in"
height="2.6333333333333333in"}
![](media/image2.jpeg){width="2.5319444444444446in"
height="2.5319444444444446in"}

The design of the proposed new seal is intended to symbolize the
following:

-   The eagle and shield from the Great Seal of the United States
    clearly indicating NCUA's role as an agency of the federal
    government. Our research, which has been confirmed by the United
    States Department of State, indicates that 18 U.S.C. 713(a) is the
    governing law with respect to the use of the Great Seal of the
    United States.[^2] This section of the United States Code states
    that it is a crime to knowingly display any printed or other
    likeness of the Great Seal of the United States for the purpose of
    conveying, or in any manner reasonably calculated to convey, a false
    impression of sponsorship or approval by the Government of the
    United States or any department, agency, or instrumentality thereof.

-   Three blue stars above the eagle representing the three-member NCUA
    Board.

-   The letters "NCUA" in white on a blue background on the crest of the
    shield, matching the federal share insurance signs that federally
    insured credit unions are required to display.

-   The circle of the seal includes the title of the agency, "National
    Credit Union Administration." The date "1934" in the lower portion
    of the circle of the seal reflects the creation of the federal
    credit union system in 1934 and the long, unbroken line of federal
    credit union regulators that evolved into NCUA. The two stars in the
    lower portion of the circle of the seal separate the date "1934"
    from NCUA's title.

Consistent with the President's initiatives on financial literacy, it is
important to help consumers more easily identify mainstream financial
service providers. Credit unions are an important element of our
mainstream financial system. We believe the new seal will in part help
achieve easier consumer recognition of credit unions supervised or
insured by NCUA as mainstream financial institutions by better
identification that NCUA is a federal agency. Also, the new seal's
connection to the NCUA federal share insurance sign will help promote
that federally insured shares are backed by the full faith and credit of
the United States government. The new seal should also help facilitate
interaction of NCUA staff with other government agencies and Congress.

The timing of the proposed change to the NCUA seal is appropriate given
the upcoming 75^th^ anniversary of the FCUA on June 26, 2009, and the
need to promote confidence in federally insured financial institutions
given the current challenges present in the economy.

**OTHER CONSIDERATIONS:** The new seal will provide NCUA with better
branding and consumer recognition as an agency of the federal
government. The design of the new seal also incorporates elements of
NCUA's official insurance sign for better and more consistent
recognition. This will result in various intangible benefits which
cannot be readily quantified that accrue to NCUA and the credit union
system.

Regarding the cost of adopting a new seal, as reflected in attachment 3
there are only a handful of aspects of our facilities that incorporate
the seal which would need to be upgraded, and limited aspects of our
operations incorporating the seal where a change would necessitate an
incremental cost. The total incremental cost is relatively small,
estimated to be less than \$37,000. In addition, there is a great degree
of flexibility as to the cost of converting to a new seal, as well as
the timing of these costs. For example, if we merely replaced the three
board members' and the PACA Director's business cards prior to normal
replenishment and obtain only two large printed acrylic seals for the
most prominent locations in the central office building (the lobby and
the board room), we could incur an incremental cost of as little as
\$2,248. Given the status of the 2008 budget, we do not anticipate
incurring incremental costs this budget cycle unless funds are available
after satisfying our contingent needs, and then of course not until
after approval of the new seal by the President. The implementation plan
to be developed if the new seal is approved will maximize the use of
existing supplies and materials and minimize overall costs to the extent
feasible.

**RECOMMENDED ACTION:** Authorize the Executive Director and the Office
of Public and Congressional Affairs to seek an Executive Order from the
President for approval of the proposed new seal. Authorize the Executive
Director to finalize an implementation plan to address new supplies,
materials, and facility upgrades that minimize the cost of the change to
the seal and address the costs as part of the budget process.

**ATTACHMENTS:** (1) Proposed Executive Order, (2) Current Executive
Order 11580 and (3) Estimated Total Costs of New Seal

**Attachment 1**

EXECUTIVE ORDER

Establishing a Seal for the National Credit Union Administration

WHEREAS the Board of the National Credit Union Administration (NCUA) has
recommended that I approve a new seal of office for the National Credit
Union Administration, the design of which accompanies and is hereby made
a part of this order, and which is described as follows:

> A likeness of the eagle and shield of the Great Seal of the United
> States, clearly indicating the NCUA's role as an Agency of the Federal
> government; the eagle in gold and white against a white background.
>
> Six white and seven Old Glory red vertical stripes on the face of the
> shield, representing the original 13 colonies; the letters "NCUA" in
> white against a rectangular Old Glory blue background forming the
> crest of the shield, similar in appearance to the federal share
> insurance sign displayed by all federally insured credit unions;
>
> Three Old Glory blue stars above the eagle to provide visual balance
> and representing the three-member Board of the NCUA;
>
> The band forming the circle of the seal in gold; the year "1934" in
> Old Glory blue incorporated into the circle of the seal at the bottom,
> referencing the enactment of the Federal Credit Union Act, which
> established a system of federally chartered credit unions in the
> United States and the long, unbroken line of federal credit union
> regulators that evolved into NCUA; the words "National Credit Union
> Administration" in Old Glory blue incorporated into the remaining
> upper portion of the circle of the seal; a single white star on each
> side of "1934" in the circle of the seal, separating the year from the
> name of the Agency;

AND WHEREAS such a seal is of suitable design and appropriate as the
official seal of the National Credit Union Administration:

NOW THEREFORE, by virtue of the authority vested in me as President of
the United States, I hereby approve such seal as the official seal of
the National Credit Union Administration, replacing the seal established
by Executive Order 11580 on January 20, 1971.

**Attachment 2**

![](media/image4.wmf){width="6.490277777777778in"
height="8.502777777777778in"}

**Attachment 3**

**Additional Estimated Total Costs of New Seal**

+------+----------+---------------------------------------------------+
| **Ad | **Item** | **Comments**                                      |
| diti |          |                                                   |
| onal |          |                                                   |
| Co   |          |                                                   |
| st** |          |                                                   |
+------+----------+---------------------------------------------------+
| \$0  | Website  | Replace old image with new one.                   |
+------+----------+---------------------------------------------------+
| \$0  | Publ     | No extra cost. Publications will be updated with  |
|      | ications | new seal on next scheduled reprint.               |
+------+----------+---------------------------------------------------+
| \$0  | St       | No extra cost. Will use up existing supply on     |
|      | ationery | internal and routine external correspondence.     |
|      |          | Incorporate new seal on ongoing restocking        |
|      |          | purchases already budgeted for (e.g., stationery, |
|      |          | note cards, and other paper products).            |
+------+----------+---------------------------------------------------+
| \    | Business | Board members (6 full color @ \$62) and senior    |
| $972 | Cards    | executives (40 single color @ \$15 a box) to      |
|      |          | receive new business cards. New hires and         |
|      |          | promotions are already budgeted for, so no extra  |
|      |          | cost. All other staff will exhaust their current  |
|      |          | supply and receive new seal on resupply orders.   |
|      |          | Note: If we did issue new business cards to all   |
|      |          | employees, this would cost \$15,000.              |
+------+----------+---------------------------------------------------+
| \$35 | Central  | 1\. Replace metal seal hanging in board room,     |
| ,860 | and      | metal seal hanging in Chairman's conference room, |
|      | Regional | metal seal hanging behind board receptionist      |
|      | Office   | station, and metal seal hanging in lobby over     |
|      | Fa       | security guard desk with full color new seal.     |
|      | cilities | (\$16,000: 4 @ \$4,000 for cast aluminum --       |
|      |          | alternatively acrylic is less expensive @ \$1,000 |
|      |          | for a total of \$4,000)                           |
|      |          |                                                   |
|      |          | 2\. Obtain 11 podium seals, digital print on      |
|      |          | acrylic. (\$660)                                  |
|      |          |                                                   |
|      |          | 3\. Obtain two large acrylic seals for each       |
|      |          | region (\$10,000).                                |
|      |          |                                                   |
|      |          | 4\. Order 6 new NCUA flags; 1 for each board      |
|      |          | office, 1 for the board room, 1 for lobby, and 1  |
|      |          | photo-op roving flag. (\$6,000)                   |
|      |          |                                                   |
|      |          | 5\. Rugs with NCUA seal in lobby. Replace with    |
|      |          | generic rugs when they are worn out. (\$0)        |
|      |          |                                                   |
|      |          | 6\. Remove the decal seal (it is                  |
|      |          | [not]{.underline} etched) on the glass doors to   |
|      |          | the board offices area on the 7^th^ floor and the |
|      |          | glass doors to Region 2. (\$200)                  |
|      |          |                                                   |
|      |          | 7\. Entrances. Of the 3 exterior entrances, only  |
|      |          | 2 have the old seals (two on each). The seals are |
|      |          | imprinted into the stone over the entrance. The   |
|      |          | Duke street entrance is barely visible given the  |
|      |          | large metal awning over the entrance. The         |
|      |          | Diagonal road entrance is for staff only and      |
|      |          | relatively indistinct. No plans to adjust these   |
|      |          | at this time given their limited perceptibility.  |
|      |          |                                                   |
|      |          | 8\. Remove the 2 small metal seals mounted on     |
|      |          | posts on the Duke-Diagonal marquee. (\$500)       |
|      |          |                                                   |
|      |          | 9\. There is a subtle version of the old seal in  |
|      |          | marble in the floor in the lobby. This looks like |
|      |          | part of the black and white pattern for the floor |
|      |          | and is not very noticeable. Thus, there would be  |
|      |          | no plans to change this. (\$0)                    |
|      |          |                                                   |
|      |          | 10\. Replace the board member and OED office door |
|      |          | signs with the new seal. For all other staff      |
|      |          | offices, purchase stickers of the new seal to     |
|      |          | place over the existing seal on the office door   |
|      |          | signs. (\$2,500)                                  |
+------+----------+---------------------------------------------------+
| \$0  | On-      | No extra cost. Will use up existing supply and    |
|      | the-Spot | incorporate new seal on purchases going forward.  |
|      | Awards   |                                                   |
+------+----------+---------------------------------------------------+
| \$0  | Re       | No extra cost. OHR already budgeted to replace    |
|      | cruiting | recruiting materials in 2008. Placement of the    |
|      | M        | order is on hold pending approval of the new      |
|      | aterials | seal. Therefore, the new seal can be incorporated |
|      |          | into the already planned expenditure.             |
+------+----------+---------------------------------------------------+
| **\$ | *        |                                                   |
| 36,8 | *Total** |                                                   |
| 32** |          |                                                   |
+------+----------+---------------------------------------------------+
|      |          |                                                   |
+------+----------+---------------------------------------------------+
| **\  | **Credit | None. The NCUA seal is not on the NCUA insurance  |
| $0** | Union    | sign. Credit unions are not authorized to use     |
|      | Impact** | NCUA's seal, only the insurance signs.            |
+------+----------+---------------------------------------------------+

[^1]: This Executive Order was amended in 1987 for a technical
    correction to refer to the NCUA Board instead of the NCUA
    Administrator.

[^2]: The State Department is vested with authority over the Great Seal
    of the United States. We consulted with and shared a copy of the
    proposed design for the new NCUA seal incorporating the Great Seal
    with the State Department. Though the State Department does not
    formally act on use of the Great Seal by other government agencies,
    they indicated they did not believe our intended use to be unlawful
    or inappropriate. Further, many other government agencies
    incorporate into their seals facsimiles of the Great Seal, such as
    the SEC, the Department of Justice, and the Department of Homeland
    Security.