Three-In-One

Tuesday’s virtual oversight financial hearing before the Senate Banking Committee will be a dramatic way to demonstrate the credit union difference.  

For NCUA Chairman Rodney Hood represents all the cooperative system’s regulatory and supervisory roles as a single witness. It takes three bank representatives to cover the same responsibility for that industry.

These three are:

1. Randal Quarles Vice Chairman for Supervision at the Federal Reserve Board-Liquidity
2. Joseph Otting, Comptroller of the Currency-Chartering and Supervision
3. Jelena Williams, Chairman of the FDIC-Insurance

Cooperative Design’s Simplicity

The credit union system built its federal regulatory structure over five decades (1934-1984). As credit unions evolved, their supervisory system followed the same cooperative principles. The NCUSIF is a collaborative fund where each member contributes 1 cent of every share dollar as a capitalization pool. The CLF is a mixed ownership corporation whose credit union funding is the basis for liquidity borrowings from the federal financing bank.

The advantages of an integrated, collaborative based regulator which covers all three functions are obvious. Greater efficiency, coordination, and single point of policy and oversight at the federal level.

The Drawbacks

But the potential downside of one organization is that there is no check and balance from other expert agencies. The effectiveness of the single regulator’s role depends on one board with the Chairman as spokesperson.  

If the board’s leadership  is not familiar with cooperative design and credit union differences, there will be the temptation to look to their bigger regulatory kin, who have a longer, different history and a lot more resources. When that approach is used to justify an action, NCUA can get off track.

What to Watch for in the Hearing

Because the hearing is virtual, the side by side visual of one versus three may not be as dramatic were the hearing in person.

I’m listening to see if Chairman Hood presents the credit union role from a cooperative point of view. Are there reports of the unique initiatives credit unions have taken to assist members? Or will the ever-present temptation of “bank envy” characterize his comments?  

Credit unions were not meant to be banks. Level playing field arguments or changes because the banks can do it, are not the reason the cooperative option exists.  

Hopefully the Chairman will show the difference not just in the 1 vs 3 setting,  but also by presenting the member focused accomplishments the industry has achieved in this crisis.

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