Who is NCUA’s Customer?

Several leading business schools, Harvard, Yale and Wharton, have offered courses to explore the role of capitalism.  Does business have a responsibility beyond expanding shareholder wealth?  How do concepts like ESG or DEI impact strategy?

Five years ago one professor noted these issues would not be part of the core curriculum.  Why are these courses outside the norm being offered?  Who is the school’s customer?  Are business schools becoming socially progressive?

A cautionary note about these boot camps for capitalism becoming more socially conscious was given by Jim O’Toole a long time USC business school professor.  “In the Dean’s view, the business community is their primary stakeholder. . . ranking of business schools reflects who hires the students. . .  most business are not trying to hire woke students.”

The Question for NCUA

Every organization, no matter the legal design or setting, has a customer.  Even governmental agencies.

December is a pivotal month on the NCUA calendar.   Multiple budgets, staffing changes, project priorities are being reviewed at the board level.  The NCUSIF’s NOL is reset.  The 2023 expense parameters are laid down including the OTR and the FCU operating fee.

Who is NCUA’s customer?   How does this focus affect these multiple spending and organizational priorities?  Is there evidence NCUA is becoming more sensitive to its customers?

Who is NCUA’s customer?

Is it the 100 million plus credit union member-owners?    There is no evidence of this.   In fact I can think of no example in which NCUA has responded to individual members’ concerns, let alone supporting their ownership rights.  In fact NCUA has ignored numerous situations where members are routinely disadvantaged by their own institution.

Could it be the 4,500 cooperative institutions?  Much of NCUA activity is directed toward the industry, its examinations, supervisory and admin roles and rules.  But NCUA does not treat these as customers in any traditional sense of the term.  It is very unusual for anyone at NCUA call out a credit union’s contributions on behalf of its members or communities.

Perhaps Congress is the “customer.”   NCUA claims independence from any traditional Congressional oversight via appropriations.   It keeps its own funds and maintains backup liquidity from Treasury.   It is an agency completely self-sufficient,  outside of any Congressional approval.

If not Congress, then the executive branch which nominates the three-person board.   Certainly board members assert party loyalty and will sometimes make overt efforts to follow administration priorities.  But in the overall governmental structure, NCUA is not a very visible part of any administration.

There is one other possibility which is alluded to in the frequently used justification for NCUA’s actions to “protect the insurance fund.”   From whom or what is never spelled out.  But the implication is NCUA is guarding the US Treasury from credit union’s somehow calling on the government for support.  There is no legal basis for such a belief, but this phrase is often used to justify some new rule or abrupt action without further explanation.

If all the obvious constituencies for who is NCUA’s customers do not align with current practice, then who do NCUA board members and senior staff see as their primary customer?

The  answer:  themselves.   The primary purpose of NCUA is self-preservation.

Just like the business school curriculum, the ultimate customer determines the outcome.   It is not the credit union member, credit union institutions or even a cooperative system that drives NCUA’s agenda and budgets.   It is institutional growth as measured by budgets, staffing and multi-year capital projects.

You might ask where does purpose fit into this organizational picture?  It doesn’t.

If in doubt about the agency’s priorities, just follow the money in the upcoming board agenda setting.  While there are multiple constituencies that claim an interest in NCUA’s activities, only one stakeholder matters when it comes to counting the money.




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