Exhibit 99.3


STATEMENT UNDER OATH OF PRINCIPAL EXECUTIVE OFFICER AND PRINCIPAL FINANCIAL
OFFICER REGARDING FACTS AND CIRCUMSTANCES RELATING TO EXCHANGE ACT FILINGS


I, David A. Shadduck, state and attest that:

(1)  To the best of my knowledge, based upon a review of the covered reports of
     TruServ Corporation and, except as corrected or supplemented in a
     subsequent covered report:

     -    No covered report contained an untrue statement of material fact as of
          the end of the period covered by such report (or in the case of a
          report on Form 8-K or definitive proxy materials [which TruServ is not
          required to file], as of the date on which it was filed), except as
          provided below; and

     -    No covered report omitted to state a material fact necessary to make
          the statements in the covered report, in light of the circumstances
          under which they were made, not misleading as of the end of the period
          covered by such report (or in the case of a report on Form 8-K or
          definitive proxy materials [which TruServ is not required to file], as
          of the date on which it was filed), except as provided below:

          |_|  TruServ had for several years, from at least February 1997
               through at least the end of 1999, inadequate internal controls
               relating to, among other things, various aspects of inventory
               management, accounts payable, cost of goods sold and accounting
               for certain income and expense items. Principally as a result of
               these deficiencies, TruServ reported a loss of $131,143,000 for
               fiscal year 1999. Because the problems identified above were
               caused by systematic flaws in internal controls, TruServ does not
               have information available to determine if it is necessary to
               restate its financial statements for 1999.

          |_|  As a result, while I am not aware of any information that would
               cause me to believe that the fiscal 1999 financial statements can
               or should be modified, I cannot make the certifications set forth
               above with respect to TruServ's financial statements for the 1999
               fiscal year, which are included in TruServ's Annual Report on
               Form 10-K for the year ended December 31, 2001.


          |_|  On May 24, 2002, TruServ filed a Form 8-K in which it disclosed
               that the Midwest Regional Office of the Commission intended to
               recommend to the Commission an enforcement proceeding against
               TruServ seeking a cease and desist order relating to the 1999
               loss and to the deficiencies in TruServ's internal controls, in
               part, described herein. TruServ has entered into negotiations
               with the Commission staff, and has made an Offer of Settlement to
               the Commission in connection with resolving the



               Commission's investigation of these matters. TruServ's Offer of
               Settlement neither admits or denies the findings in any
               Commission Order. If the Commission accepts TruServ's Offer of
               Settlement, TruServ will be subject to a cease and desist order
               requiring it to maintain books and records in conformance with
               the requirements of the Securities Exchange Act of 1934 and to
               undertake certain other ancillary procedures.

(2)  I have reviewed the contents of this statement with TruServ's audit
     committee.

(3)  In this statement under oath, each of the following, filed on or before the
     date of this statement, is a "covered report":

     -    TruServ Corporation's Annual Report on Form 10-K for the year ended
          December 31, 2001;

     -    All reports on Form 10-Q, all reports on Form 8-K and all definitive
          proxy materials (which TruServ is not required to file) of TruServ
          filed with the Commission subsequent to the filing of the Form 10-K
          identified above; and

     -    Any amendments to any of the foregoing.


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                                        Subscribed and sworn to Before me this
                                        25th day of October 2002.

/s/ David A. Shadduck                   /s/ Susan A. Scheibenreif
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David A. Shadduck                       Notary Public
October 25, 2002
                                        My Commission Expires: 6/19/2004
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