Month: May 2022

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A CEO Reports to His Team

Learning from others is how many inform their own leadership approach.  Each month Weokie FCU’s CEO Jeff Carpenter sends a briefing to staff about the important events.

The brief excerpts below are from his April update. Used with permission.

The complete report includes pictures, member testimonials, project priorities and performance numbers.

Open communication contributes to shared efforts with common purpose.  Both are vital for effective organizational performance.

Living Our Vision & Mission

WEOKIE adopted a new vision in 2022 and has been working hard to make the vision, not just words on a paper, but a reality. I wanted to pause a minute each month to share some of the “stories” of how we are  “making a difference, one person at a time”

Calculating the Coop’s Value

Why Cooperation Matters

“Cornerstone IMPACT 2022: I attended my first “in-person” meeting of the Cornerstone Credit Union League’s Annual Meeting and Convention entitled IMPACT.

“WEOKIE is stronger when we cooperate with other credit unions and the Cornerstone League is a great facilitator and cause agent for credit union collaboration.

“The meeting had excellent educational content and numerous opportunities for R&D (Research & Development, aka Rip-off & Duplicate) great ideas that other credit unions are pursuing.”

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Memory and Hope:  Memorial Day 2022

From the golden fields of grain in Ukraine to the classrooms of Uvalde, Texas it is hard not to feel deep sadness at the self-inflicted tragedies of life.

Wilfred Owen’s poem Futility  captured this feeling during WW I in which the poet lost his life on November 4, 1918: :

Move him into the sun—

Gently its touch awoke him once,

At home, whispering of fields unsown.

Always it woke him, even in France,

Until this morning and this snow.

If anything might rouse him now

The kind old sun will know.

 

Think how it wakes the seeds—

Woke once the clays of a cold star.

Are limbs, so dear-achieved, are sides

Full-nerved, still warm, too hard to stir?

Was it for this the clay grew tall?

—O what made fatuous sunbeams toil

To break earth’s sleep at all?

Where is Hope?

The irony of memory is that lives transcend tragedy when we remember the people whose loss leaves a deep crevice in our soul.  Especially those who gave us life and purpose when we faced our own uncertainties.

The most important event during the day when deployed in the Navy is mail call.   That is a reminder of the reunion everyone longed for.

(Returning from Operation Golden Dragon, Yokosuka, Japan 1970.  Mary Ann and Lara greet our brief stop to replenish before going back to sea. USS Windham County LST 1170 in background.)

Today an individual’s presence may not be physical, but  the  meaning they gave to our lives endures.   That is how hope overcomes tragedy.

 

 

 

 

 

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Memorial Day 2022-Time to Reflect

We all take risks in our lives. Shopping, learning, and worshiping are not places where we should fear for our safety.

This weekend, can we reflect about the changes we support to create the society we wish for ourselves and our children?

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Today’s NCUA Board Meeting: an Opportunity for Insight into the NCUSIF

With only one agenda item, the NCUSIF’s March quarterly update, today’s NCUA board meeting presents an in-depth learning opportunity about the fund’s management.

With almost $22 billion in assets, the NCUSIF is the largest investment under NCUA’s control.

Because NCUA publishes monthly updates on its three major funds, credit unions are able to monitor how their members’ funds are being used.

The public board discussion is a vital part of this process for credit unions and board oversight.

What I Am Listening For

  1. There is much confusion caused by the NCUSIF’s use of Federal GAAP versus private GAAP accounting, the standard credit unions must follow. The Federal accounting terms, presentation and practice are different from private GAAP.

This is because Federal GAAP was intended for use by entities which rely on government appropriations.

Some examples.  Cumulative results of operations: Following SFFAS No 7 the NCUSIF recognizes interest on investments as “non-exchange revenue” which in turn means unrealized holding gains and losses are reported as part of revenue.

In contrast, credit union “available for sale” securities are reported at book value with unrealized gains or losses recorded in a valuation account, not as an income or expense.  This  account is not included when computing the net worth ratio.

Credit unions report retained earnings.  Federal accounting has no comparable account. This and other differences mean that NCUA staff transform NCUSIF Federal presentation into a private format, but then do not follow private accounting practice.

For example the 1% deposit true up (or refund) is treated as revenue in the NCUSIF; however credit unions record this adjustment as an investment asset on their books.

Will this confusion be addressed?   How will this affect the calculation of the 1% true up when presenting the NOL ratio for the fund?  Private GAAP recognizes the true up as a receivable or payable on the insurer’s books when the insured risk is reported triggering the required deposit adjustments.

  1. How has the NCUSIF investment committee responded to the rising interest rate environment? The market value of the NCUSIF’s investments may have fallen by as much as $1.5 billion from the peak in 2021.   What changes have been made in response?  How will the below market income stream from the fixed rate, lower earning. long-term bonds, affect the income of the fund and projections of the NOL in 2022?
  2. Credit union’s first quarter results have been summarized in Callahan’s Trendwatch. How does the first quarter’s 9.3% actual share growth compare with NCUA’s projections for the year? What impact, if any, will the rise in interest rates have on CAMELS ratings?
  3. What changes in NCUSIF investment policy and accounting presentation/practice is staff proposing? Or will be requested by the board?

Over the past 16 months, I have written several blogs about NCUSIF investing and accounting anomalies.   Here are selected observations and additional background for the questions that may be raised in today’s meeting:

I’ll follow up next week on the board’s dialogue.  Hopefully this will be a fresh start for improving the fund’s financial practices.

 

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Red Hot Inflation & A Perspective on Previous Fed Approaches

The Federal Reserve’s dual mandate of managing monetary policy to sustain full employment and price stability is now focused on just one objective: reducing the 8% current inflation to the 2-3% range.

It intends to do this by reducing demand at all levels. The primary means  is by raising short term rates to discourage borrowing and reduce existing demand.

What level of rates will be necessary is unknown, as well as how long the process will take.  Also uncertain is whether the result will be a gradual slowing of the economy or  end in  recession.

CNBC reporter Kelly Evan’s May 19th column provides an historical perspective of previous Fed efforts to stop inflation. These prior results are mixed.

In her full column below she ends by stating what  she believes will be Chairman Powell’s approach.  Her analysis is a useful summary as pundits will offer critiques at each  stage of what will probably be a year long effort.

Kudos to former Fed chair Ben Bernanke for writing a perfectly timed book on the Fed’s battles with inflation in the 1960s and ’70s. If the book has a rather dry title (21st Century Monetary Policy), that’s because Bernanke sees it as picking up the narrative where his heroes, Friedman and Schwarz, left off in their 1963 classic that inspired his career and explained the Fed’s missteps during the Great Depression, A Monetary History of the United States. 

Bernanke, in other words, aims to provide a definitive account of how the Fed “got it wrong” in the Great Inflation that saw consumer prices rising more than 7% on average annually between 1965 and 1981, peaking at nearly 13% by the end of the period before Fed Chair Volcker finally wrested inflation back under control. His retelling contains so many similarities to today that it certainly ought to give anyone pause who thinks the current inflation will simply go away on its own. 

There were basically only two Fed chairs in the entire period spanning the Great Inflation: William McChesney Martin, from 1951 to 1970, and Arthur Burns, from 1970 to 1978. Martin comes off better in Bernanke’s retelling; he at least conceptually ran the Fed as a countercyclical institution, coining the phrase that the Fed should have “the punch bowl removed just when the party [is] really warming up.” He also emphasized the importance of keeping inflation at bay, noting “price stability is essential to sustainable growth.” 

And for much of Martin’s tenure, inflation was dormant. The CPI rose only 1.3% or so on average in the decade up to 1965. But “that began to change around 1966, when consumer prices rose a surprising 3.5%,” as Bernanke writes.

What caused the sudden change? President Johnson had passed a key tax cut in 1964, the same year he announced the War on Poverty, which culminated with the introduction of Medicare and Medicaid in 1965. The unemployment rate dropped–in fact below what was sustainable without stoking inflation. 

In December 1965, Martin was able “to take a very public pre-emptive action against inflation,” Bernanke writes, “by announcing a half-percentage-point [rate hike].” But President Johnson was furious, and so began a series of back-and-forths that for the next several years saw the Fed start and stop tightening several times as it tried to coordinate with fiscal policy so as not to overly constrain the U.S. economy.

The halting approach resulted in an inflation rate of almost 6% by 1969. “I’ve been a failure,” Martin told his colleagues as he left office. 

It’s important here to note, amid our current scare, that the U.S. economy fell into recession in 1970 after Martin’s tightening the year before–but it didn’t stop inflation. The CPI still rose 5.6% that year. There were actually two recessions in the 1970s–including a longer, deeper one starting in 1974–but they didn’t keep inflation from rising throughout the decade. Even under Martin’s successor, Arthur Burns, who ran even looser monetary policy, the Fed didn’t enjoy the supposed tradeoff of a stronger economy as a result; it wound up with “stagflation” instead. 

Burns was a gifted economic forecaster, which would seem like the perfect credential for a Fed chair. But philosophically, he worried that monetary policy was an overly broad tool to fight inflation with. He responded to the 1970 recession by slashing rates from 9% to 5% by 1972. 

More importantly, he agreed with the consensus at the time that “the U.S. had become more disposed to inflation for reasons unrelated to monetary policy,” like “the growing ability of large corporations and labor unions to insulate themselves from market forces,” pushing up prices and wages supposedly at will.

In other words, he believed in the “cost-push” versus “demand-pull” theory of inflation, so he thought monetary policy was the wrong tool to fight it with. In fact, as Bernanke writes, it’s “unlikely” President Nixon would have imposed his notorious wage and price controls in the early 1970s without Burns’s support. 

Then, like now, there were also oil price shocks that further confused the situation. To Burns, they proved that “inflation was largely caused by non-monetary factors.” His Fed hiked in response to surging oil prices in 1973, then reversed when the recession hit. Meantime, the political mood still emphasized the priority of achieving full employment, passing the Fed’s “dual mandate” amendment in 1977 and the “Humphrey-Hawkins Act” in 1978 that specifically said the unemployment rate for people 20 and older shouldn’t exceed 3%. 

All told, unlike Martin and unlike his successor, Paul Volcker, Burns “did not believe that inflation was caused primarily by monetary forces, and consequently, he saw tight monetary policy as an indirect, costly, and largely ineffective tool for controlling inflation.” Burns later admitted that the Fed could have restrained inflation by restricting the growth of the money supply, but that would have created “strains” in the markets and economy that the public wouldn’t tolerate. He gave a speech titled “The Anguish of Central Banking” after he left the Fed, to try and explain himself. 

Bernanke makes it obvious that Fed chairs who dismissed inflation as a “non-monetary” phenomenon, or who only haltingly tackled the problem, were mistaken. Volcker, by contrast, came in after Burns with a “shock-and-awe” monetary policy that did choke off inflation; and even after the deep recession it caused in the early 1980s, the economy recovered so strongly that by 1984 President Reagan would be reelected with the largest majority ever. 

Volcker wasn’t concerned with “soft landings”; he made it clear to the public that his only goal was to bring inflation down. Fed Chair Powell himself made clear to lawmakers in February that he believes Volcker was “the greatest economic public servant of the era,” and that he is personally committed to protecting price stability.

But this is the real test now, with markets spiraling downward and growth looking shaky. If Powell backs down without fully conquering inflation, future historians may not treat him kindly.  

 

 

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Technology versus Slow Checkouts

America loves innovation.  Especially in technology.  We celebrate, honor, and enrich those entrepreneurs who bring efficiency and ease to our life and work with their inventions.

Technology underwrites greater productivity, reach and speed in credit union services. It enables 24 by 7 interactions. Manual processes from loan underwriting and live teller interactions are replaced by AI decisioning and intelligent teller machines (ITM’s).

Even phone responses and “live” chat are now automated to the point where one must opt out to “speak” with a real person.

What society prizes, is what the people will create. One writer contrasts our modern view of success with the culture in ancient Greece.

The ancient Greeks gauged progress differently from us. “What is honored in a country will be cultivated there,” Plato said. The Greeks, imperfect as they were, honored beauty and justice and moral excellence, and so they cultivated these values. We honor speed and connectivity and portability, and so that is what we get.

The author asserts our current focus leads to: “cognitive dissonance from our misplaced faith in technology, and an attendant disregard for other forms of human progress.”

The Introduction of “Slow”

I was reminded of this contrast between ancient and modern values after reading about a new approach in retail services in Europe, called Slow Checkout.

Jon Horvat describes this approach in retail and service industries: With so much buying happening online or through self-service kiosks, the art of shopping has lost much of its attraction. Some market-savvy executives have noticed this shortcoming and have recently introduced slow checkouts, which turn the routine chore into a meaningful experience.

Many retail experiences, that is personal shopping, are no longer personal.   Human contact, especially the kind of interactions characterized  by local farmer’s markets have been eliminated in the race for self-service and cashless checkout innovations.

The pressure to automate customer interactions will only accelerate as labor shortages occur in many retail service sectors.

Executives at several retail grocery chains in Europe noticed something was missing in their retail experiences. Some customers wanted human interaction.   Jumbo a Dutch supermarket chain and Carrefour, the French grocery leader, both introduced “slow checkout” lanes after discovering that people wanted to chat when then paid for their groceries.

Harvat describes this approach as follows:

These small-talk cashier lanes are gaining popularity. They are called “chitchat” checkouts. The French name, blablabla caisses, is a bit more expressive.

About 150 of Carrefour’s French stores have opened blablabla caisses, with plans to have at least one till in every location by the end of March. The lanes are marked for only those who want to talk with cashiers. There are no time limits for the customer, although most try to respect those waiting in line. The lanes come at no extra cost to the consumer.

Shoppers are encouraged to take their time on the slow checkouts; cashiers greet with bonjour and can ask about the family or the weather. No managers will be around to speed the process up. The aim is to slow it down.

Both customers and cashiers report greater satisfaction in their roles where interaction is encouraged.  Shopping is a social experience, not just a purchase transaction. Small talk is an important experience for people living alone or feeling lonely.  Cashiers enjoy the opportunity to communicate with people, giving them a sense of expanded agency in their interactive role.

Credit unions have traditionally been an area where these interactions have been a valued part of the member experience.  Members get tired of talking to machines or referred to online applications or processes.  They want to talk with real people.

People are social creatures.  These chit-chat interactions show that economics, the best rate or the fast turnaround, is not the only, or even the most important, human need in every circumstance.

Every person has needs that surpass material economic sustenance. Humankind does not live by bread alone.

The Boutique Credit Union

One person who has recognized this critical capacity for human interaction is Bo McDonald.  He is a credit union consultant who has focused on the unique capabilities and experiences provided by smaller credit unions.   While some may see credit unions with assets of under $100 million or below the credit union average size as a disadvantage, he sees these as “boutique businesses.”

When inspired by passion they provide member experiences long lost in some billion dollar institutions.  Ultimately every credit union is founded on relationships, even if the only measures traditionally used are the number or size of  transactions.

These boutiques may not have the growth patterns of their larger brethren; but they demonstrate the enduring power of cooperative design.  For  when we look under the technology covers increasingly deployed by credit unions, we learn that what members really value is someone to talk to  when they have a need.

Boutique credit unions demonstrate that real progress can also be achieved by slowing down and giving members your undivided attention.

 

 

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Cooperatives and Awakening the “Sleeping Giant”

Three recent observations:

  1. While reviewing an exam for a billion-dollar credit union of 25 pages, nowhere was the word cooperative used.  There were no  comments on any of the credit union’s responses to members during COVID, their PPE loans and multiple  community involvements including expanded DEI.   If the name were removed from the exam,  it would be impossible to know it was a credit union, not a bank.
  2. Two readers commented on REI’s values approach to its “brand:”

“While I am a fan of REI, I would like to mention (and this is probably not a surprise to you) that they too have a tendency towards oligarchic governance you have talked about in the context of credit unions. If I recall correctly, to be eligible for a candidacy in board elections you have to have leadership experience in a Fortune 500 company.

“We desperately need legislation that ensures fair electoral practices in co-ops. Glad you are advocating for this in credit unions. REI is a great company and credit unions are great – but they also need some tough love. “  (Leo Sammallahti)  

“I’m sure REI is admirable in its promotion of important values. However, the current unionizing effort does not seem to put REI in a good light.

“My own experience in a nonprofit progressive worker-rights advocacy organization (prior to joining the credit union movement) was that the management vigorously fought our efforts to unionize. It’s not an uncommon story among “liberal” organizations. Our effort was ultimately successful, but it taught me a lingering lesson about progressive hypocrisy. The co-op world is not exempt.”  (Cliff Rosenthal)

  1. Here is a small sample of the number of  job openings from Sunday’s CU Insight:
  • 77 positions at Lake Michigan Credit Union
  • 65 or 5.4 percent of NCUA’s authorized staff of 1,201. Fifteen were at Head Office and 50 in the regions (from NCUA Operating Fund report)
  • 40 positions at Michigan State University FCU
  • 37 positions at True Sky Credit Union

What do these Observations Mean?

Is our cooperative model struggling?   Is our business merely subject to the same economic forces affecting every other firm?  Are credit unions even addressing the multiple challenges of  inequality existing in every community?

In some respects the cooperative model is not working well.   On the surface we increasingly appear as just another financial option.  In many cases, let’s be frank, credit unions are not much different from many other financial choices in their behavior and impact on their communities.

Instead of transforming financial opportunity, credit unions increasingly embrace the tactics of their competition including purchasing banks, mergers (sell outs) of sound long- serving coops, and measuring performance by strictly financial and growth goals.

Recapturing our Promise

Occasionally a story appears in the press about a find in a flea market or an opportunity shop.  A person discovers an antique looking Roman bust selling for $34.99 in a Goodwill store.   She later learns it is 2,000 years old and priceless.

Sometimes in  life we do not understand the value of what we have.

But every credit union, not matter its size, has a founding story and purpose.  Every board inherited a legacy of power, fortitude and energy to make life better for members.

But does senior management and the board know what they have?  That is, an institution with the power to override the ever present push and pull of market forces of greed, domination and even exploitation?

The credit union charter is intended to enrich its members versus building institutional glory.  Every charter comes with that hope and potential.

So what is lacking today for why this transformative promise seems to be missing?

In One Word: Imagination

One of the examples of creative capability was Ed Callahan’s way of presenting the potential for the credit union movement, both as Chairman of NCUA and as CEO at Patelco Credit Union.

He believed the credit unions were “a sleeping giant,” or America’s “best kept secret.” They should be an option for all Americans.  Whether retired, between jobs or even for college and high school students.  The field of membership was an inclusive, not an exclusive concept.

In practice he did not let current reality limit what the future could be.  The NCUA exam cycle was over two years for federal charters when he arrived.  He held a “fire drill” that resulted in every federal credit union filing, for the first time ever, the yearend call report.   Working with regional directors, every federal credit union had an exam contact in 1982, and each year thereafter.

To celebrate the 50th anniversary of the passage of the Federal Credit Union Act, he announced a movement goal of 50 million members by 1984.   He inspired the largest credit union conference attendance ever in December of that year when state and federal examiners and credit union leaders came together in Las Vegas to debate their future.

Working with credit unions, the NCUA’s share insurance fund and CLF were redesigned following cooperative principles to create a three-part regulatory framework for the cooperative system.

These transformative events were inspired by the promise of what credit unions could be.  He recognized that in the new era of deregulation not all would perform with the same capability.  But working together, the system could position every credit union to be a competitive and valued experience for members.

Imagination was fueled by belief in what the pioneers had envisioned.  While the three current observations above may seem like challenges, they are opportunities to create a better coop system.

Let’s be honest.   Credit unions have always been understood, even trusted, as more than another financial choice.  They represent a member-centric focus dedicated to improving members’ lives and community options.

They are more than a financial institution.  Credit unions at their best represent the common hopes of young and old for a better life and a meaningful role in their chosen community.

The tools for transformative change have been a part of the cooperative model from the beginning.    What is needed is imagination tempered with vision and compassion.

Then indeed, the “sleeping giant” will be truly awakened.

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How a Co-op Tells its Value to members

How a Co-op communicates its difference to the member-owners.   Sent by a reader and REI advocate.  It’s about values, not product, price or convenience.
REI co-op
Shared values. Not share value.
As a co-op, we put purpose before profits and act in the long-term interests of our members and community. Our Impact Report shows what we’ve done (with your support!) to help connect every person to the power of the outdoors and engage them in the fight to protect it.
Cooperative Action is how we get things done
The Cooperative Action Network adds your voice, and thousands more, to the movement for climate action, environmental stewardship and equity outdoors.
A person is carrying a kayak down a ramp
Adventure more, own less
Rent your gear from REI so you don’t have to fill your closet up with awkwardly shaped outdoor things. Some of us don’t even have closets. Not only is it a good way to try new things, but it’s also more sustainable.
Two people are walking through a forest. One person has an orange backpack on.
Grow the love, shrink the footprint
By utilizing recycled materials, Fair Trade Certified™ factories and bluesign®-approved fabrics for a large portion of our products, we’re taking steps to reduce our footprint.
A collage of three images. Image1: Two kayaks on a lake are filled with three people and a dog. Image 2: Three people are riding bicycles on a trail. image 3: A person is looking out at a viewpoint.
Friendly expert advice
Your go-to source for expert outdoor knowledge you can trust. All the information you need to learn new skills, choose and maintain gear, prep for your trips and have amazing adventures.

 

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Credit Unions and Democratic Practice

Credit unions are strong proponents of democratic values.   Until they have to practice them.

I was reminded of this reluctance in a press story of a recent merger approval.  When asked about the vote tally, the credit union did not answer how many of its 9,870 members supported their charter cancellation:

Members of the $137 million Embark Federal Credit Union in Great Falls, Mont., voted to approve a merger with the $1.7 billion Horizon Credit Union, the Spokane Valley, Wash.-based financial cooperative said in a prepared statement Tuesday.

Horizon did not disclose the final vote tally. The credit union did not respond by deadline on Tuesday afternoon to CU Times‘ request for the member vote count.

Reporting the vote outcome, but not the actual numbers, suggests the credit union does not want the totals known.  The credit union provides the veneer of democracy but not the facts of how many member-owners actually participated in this required step to give up their charter.

To paraphrase a term from writer Jared Brock, credit unions have become “cooperative oligarchies.” The word comes from the Greek oligarkhía, meaning  “rule by the few.”

Merriam-Webster ‘s definition:  “a government in which a small group exercises control especially for corrupt and selfish purposes.”

Democracy has rarely been tried by capitalists.  Can credit unions really go against the incessant drive for corporate dominance and consolidation of power sought by firms in “free” market economies?

Many CEO’s and credit union boards don’t want democratic governance. They want silent customers who will passively accept the  leaders who achieved their roles years, or sometimes decades, earlier.

What they ignore is that members are the political constituency to whom  fidelity is owed. Boards and CEO’s are nothing without members.  Members deposit the funds, borrow for loans, pay the fees and generate transactions that keep the credit union revenue flowing.

Member-owners are the reason credit unions exist.
Members keep the lights on.
Members create 100% of the wealth for their cooperative.

One would think it required practice to tell members the vote tally in this management initiated effort to give up their independent credit union charter.  Especially as the CEO was awarded a $100,000 bonus and continued employment at an increased salary with the continuing credit union.

Horizon Credit Union assumes Embarks FCU’s member capital of $14 million, (approximately $1,500 per member).   The members get rhetorical promises about the future.

Is this the democratic model that will sustain members’ belief in credit unions?

 

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Learning from Past Mergers to Design a Stronger Coop Future

Since the NCUA updated its rule for mergers in 2017, almost 1,000 voluntary mergers have been completed.  In the first quarter of 2022, 41 mergers involving 366,000 members and $5.5 billion in assets were announced.

These were overwhelming strong, long-serving successful credit unions whose boards and CEO’s decided to turn their loyal members’ futures over to another firm.

The 2017 rule was intended to correct self-dealing transactions that were prompted by payouts to senior managers and staff to incent sound credit unions to give up their charters.

The rule required disclosure of all compensation related benefits that would not have occurred if the merger had not taken place.   The result has been some, but not all disclosures of promised payments.

The rule has not prevented enrichment, but ironically validated them.  The amounts and creativity of merged CEO payouts are growing.  Financial Center CU’s CEO and Chair transferred $10 million of the credit union’s capital to their private firm incorporated just prior to merger.-all with NCUA pre-approval.  In the merger  of Xceed CU the CEO negotiated a $1.0 million dollar merger bonus while promising members to look after their interest as President of Kinecta FCU for three years-only to leave within six months.

The CEO of Global negotiated a “change of control” clause in his contract that will pay him $875,000 upon merger with Alaska USA.  Change of control is used in stock corporations for managers who might lose their positions in a sale of the firm.  In this case the CEO negotiates the employment clause, seeks out a merger, retains employment post merger as  President, Pacific and International Markets, and pockets the money for the deal whose terms he set up.

The Banking Industry Is Looking at Merger Practices

In a May 9, 2022 speech at Brookings, the Comptroller of the Currency announced a review of bank merger approvals:

From my perspective, the frameworks for analyzing bank mergers need updating. Without enhancements, there is an increased risk of approving mergers that diminish competition, hurt communities, or present systemic risks.

Bank mergers should serve communities, support financial stability and industry resilience, enhance competition, and enable diversity and dynamism of the banking industry. Revisions to the bank merger framework would help to realize this goal.

NCUA’s rule 2017 merger rule was off target.   It did disclose self-enrichment, incentives  which were common place.  But it did not prohibit them..  The rule entirely missed the  Agency’s primary job which to protect members’ interests.

The evidence before and since the rule indicates that managers and boards act without consulting members, negotiate terms privately, and then present the events as final only needing the members’ perfunctory ratification.

Formal member approval is a foregone conclusion.  All of the resources, information and control was in the hands of those who set up the deal.  Members are unable to challenge let alone question the actions.

As members are shut out of the process, the concept of member owned financial institutions becomes a fiction.  Boards and management control the fate of a charter, its resources and relationships.  Members’ interests, loyalty and accumulated wealth are just pawns in management’s efforts to enhance their well-being.

As demonstrated yesterday, the majority of mergers are sound, long-serving and certainly capable of operating on their own.

How does one bring balance, objectivity and most importantly, member interests, to the fore in this increasingly wild west of uninhibited sellouts of cooperatives.

One writer, Denise Wymore,  has urged a greater commitment to purpose by credit union leaders.

Decisions, not conditions, determine your credit union’s future.

Do we look for the why behind a tough situation or do we just complain about it? Increased regulation, cost of technology, economies of scale, expanded products and services, lack of succession planning. Struggling to achieve a goal is normal and natural. Is it possible to work together to address the challenges facing “at risk” credit unions?

You have to find meaning, a purpose, something bigger than yourself. Reflect and think about your credit union’s purpose, passion, meaning…

The Comptroller outlined enhanced regulatory reviews such as:

 “Community feedback on the impact of a proposed merger also is important. . . .For example, for mergers involving larger banks, , the OCC is considering adopting a presumption in favor of holding public meetings.”  and,

“The OCC takes into account an acquiring bank’s CRA rating and performance. Banks with unsatisfactory CRA ratings are highly unlikely to receive merger approval.”  and,

Financial Stability in “too-big-to-manage is a risk with mergers, especially for banks engaged in serial acquisitions.”

Whether NCUA can reassess its role in mergers is questionable.   Unless political pressure from the Congress is exerted, NCUA seems oblivious to the reputational and safety and soundness implications of the wheeling and dealing now occurring, and the harm done to the communities who are losing their local institutions.

Putting Market Forces Back In transactions

I believe two changes in merger policy are required.  The first is make members’ interest the paramount criteria in any proposed charter cancellation via merger.  Secondly members should have the benefit of market forces to inform their decision.

Market choice would entail that all credit unions who decide to explore mergers would announce that intent publicly, invite all parties to express interest (both credit unions and non-credit unions) and then select the option the board believes meets the test of members’ best interest.  The full process would then be presented to the members for their approval or turn down.

The options for future employment, products and services, return of member capital would all be part of the public record and members would have the information needed to make an informed choice.   If a firm that is not selected wants to make a better offer, it would be able to do so and ask the members to turn down the board’s recommendation.

Putting Members Back in Charge

This change would place members in charge of the future of their credit union; not management and its personal preferences for future employment.

Mergers when sought should be a means to the end of enhancing member options and value. Today mergers alone have become the goal.  They are about self-dealing, power and control by a few.   It is time that members are given the choice about who they want in charge of their shares and loans.