Where an FCU acts as insurance insurance, the FCU effectively provides insurance coverage for members` loans by taking on the risk of payment of each loan. Self-insurance is not an activity subject to an explicit power of the FCU. However, an FCU may, within the framework of its ancillary powers, conclude debt relief contracts or waivers of the CAP, provided that it withdraws an insurance policy covering the entire risk of loss. In your letter, you referred to a notice from Richard Schulman to Richard Hetzel, dated November 16, 1995, in which we found that an FCU could sell debt cancellation contracts to your members as an ancillary activity with the explicit credit of the FCU. Other reasons for debt cancellation are military service, marriage and divorce. A CAP programme, set up by an FCU, operates in two phases.