My Response to NCUA’s Request(RFI) to “Improve Communications and Increase Transparency”  (due by March 9)

ALEXANDRIA, Va. (Jan. 4, 2021) – The National Credit Union Administration Board unanimously approved, by notation vote, a request for information(opens new window) seeking comments and information on the NCUA’s communication methods to promote efficiency and increase transparency.

“This request for information seeks public input on how the agency can streamline and improve its communications with our stakeholders. Outdated or duplicative regulatory and supervisory information adds to the overall regulatory burden of credit unions as they must devote time and resources to sorting through this information,” NCUA Chairman Rodney E. Hood said. “We recognize that the amount of information the NCUA provides to credit unions can create challenges and may impose unintended burdens.

Four pages, half of this  request, describes NCUA’s current communication efforts.  Reading through, I was not even sure where to send this response:

My Comment

Effective communication is not about publication design, content, frequency or media.  Nor is it determined by statutes and interpreting the law. It is about human intent.   My suggestions are:

  1.  Require every NCUA employee who provides their email in their presentations to actually reply if contacted. Public servants responding to constituent’s inquiry is a professional courtesy as well as a responsibility, especially when they advertise their availability.

When I tested Rodney Hood’s offer of his personal email for contact  in last week’s GAC speech ( I was surprised to get a direct reply within 24 hours.

2. Fix the so-called “search” engines on NCUA’s web site. To have uploaded decades of information that cannot be accessed is offering nothing at all.  Neither the general search engine on NCUA’s home page nor  the one dedicated to finding documents from the general counsel’s office are effective.

One can type in a very precise request such as a credit union’s name or for a specifically identified NCUA supervisory letter or document and receive hundreds of unrelated responses, none correct.

Hint to readers:  Use the search engines at Credit Union Times, Credit Unions Today or CU Journal to find relevant information more easily.

  1. Reorganize FOIA. Repurpose its mission to answer requests with full transparency and awareness of the agency’s responsibility to the public.  Quickly.  NCUA routinely denies requests for which information is public, has been routinely provided in the past, or to hide shortcomings in its own activities.

For example, credit unions know more about former Chairman McWatters’ hundred-dollar travel reimbursements than how the agency managed and sold over $750 million dollars of 4,000 members’ taxi medallion loans to a hedge fund.  Many of those details were in a Wall Street Journal article. For the first 15 years of the CLF’s operations, NCUA routinely published its member subscribers, but now refuses to release the same information.

The list could go on.  One CEO described this FOIA  coverup of NCUA shortcomings and falsehoods in a series of posts  several years ago.  The oversight of this function was then by a General Counsel whose professional and personal decisions were revealed to be unprincipled, even corrupt, upon “retiring.” The FOIA’s office’s practices have not changed with a new General Counsel.

Communication versus PR

Today corporate and credit union “communications” are seen as a skill best managed by public relations professionals.  Never admit error or mistakes.  Do not show vulnerability.  Reframe questions to give your talking points.

No straight talk.  Select chosen facts or use phrases such as “our research shows” or resort to unprovable assertions about future events.

An organization’s communication challenge is not an issue of volume, mastering  the right digital media or even words. It is about leadership’s trustworthiness; a responsibility that cannot be outsourced, delegated or covered over with  a FOIA blanket.

This ends my comment.





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