Month: September 2025

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NCUA Turns to Exit Stage Right in Examinations

At the NCUA’s September single board member meeting the acting CFO announced the  agency had conducted four liquidations through the first two quarters.  The YTD loss allowance was increased by $17.6 million versus $2.0 million in 2024. $12 million was expensed as an insurance loss for June without any details (Unilever FCU?).

NCUSIF trends are not going in the right direction.

The most important efforts limiting NCUSIF losses are NCUA’s  annual examination program.

The problem  is that it is no longer annual except for selected cases.  After the Agency’s April layoffs of 20% of staff, the exam cycle was extended further for apparently stable credit unions.

But it is not just the frequency of contact, but the quality of the work and the interaction with management and board on important issues.

Against this recent NCUSIF update, yesterday’s NCUA press release was especially unsettling.  On the surface, the single board member Kyle Hauptman announced NCUA’s goal to conform agency policy with the political ideology of the current administration.

The Headline read: NCUA Eliminates Use of Reputational Risk, (link).  But the change was much more extensive as described by Ancin Cooley in a  post in which he  focuses on this paragraph:

In addition to eliminating reputation risk, NCUA has discontinued the practice of assigning ratings to the Risk Categories (also referred to as Risk Areas) for the examination and supervision program. Historically, examiners assessed the amount and direction of risk exposure in seven Risk Categories: Credit, Interest Rate, Liquidity, Transaction, Compliance, Reputation, and Strategic. 

This brief excerpt does not specify what this change means.  Will the 1-5 CAMELS ratings be affected? Will the “high, moderate, or low” summary comment on risk areas be ended?

With credit union failures and NCUSIF losses trending higher, reduced examination efforts, and continuing economic uncertainty,  is now the time to muzzle examiner judgements? Here is Cooley’s reaction:

We live in odd times.

CEOs, I know you’ve had frustrating encounters with auditors and regulators. They can feel burdensome, even annoying. But this latest move from National Credit Union Administration (NCUA) isn’t a win for the reduction of “regulatory burden”—it’s something far more concerning.

Although the headlines highlight the elimination of reputation risk, please read further. In addition to eliminating reputation risk as a rating, NCUA has discontinued assigning ratings to all seven risk categories:

• Credit
• Interest Rate
• Liquidity
• Transaction
• Compliance
• Reputation
• Strategic

Imagine someone removing all the smoke detectors from your building and telling you, “Don’t worry, we’ll let you know when we see fire.”

The purpose of these risk ratings was never busywork. At the aggregate level, they provided field offices, regions, and national leadership with a top-down view of where risk was accumulating. From a staffing standpoint, if a credit union’s liquidity risk was rated high, it signaled the need for additional expertise at the next examination.

Examiners and ERM professionals assess each category based on quantity, direction, and the quality of risk management. The point was never to penalize higher-risk profiles. It was to ensure that if you accepted a higher risk, your management practices were robust enough to handle it.

America’s Credit Unions, NASCUS, and American Association of Credit Union Leagues

How is this a win for the members and the safety and soundness of credit unions? Why do we only hear about tax status, and none of these moves requested are discussed with the same intensity?

A couple of foot notes: NCUA Credit Risk Webinar

On July 15, 2025, in an NCUA (https://lnkd.in/ednAJjCE) credit risk webinar, an examiner (Min 13:49) discussed the benefits of key concepts like risk appetite, risk tolerance, and risk capacity. Those are excellent tools for boards and executives. They’re the backbone of modern ERM.

But here’s the contradiction: NCUA is now saying those concepts are helpful for credit unions to adopt, while simultaneously discontinuing examiner use of risk ratings for the seven categories (credit, liquidity, interest rate, compliance, transaction, reputation, and strategic).

National Credit Union Administration:
Additional Actions Needed to Strengthen Oversight

On Sept. 23, 2021, the Government Accountability Office issued a report stating NCUA has opportunities to improve its use of supervisory information to address deteriorating credit unions. By more fully leveraging the additional predictive value of the CAMEL component ratings, NCUA could take earlier, targeted supervisory action to help address credit union risks and mitigate losses to the NCUSIF. As of today, one of the recommendations is still open, and another is partially addressed.

END

As Hauptman tries to burnish his reputation with the administration’s anti-government ideology, the dangers of a single political point of view determining regulatory priorities in a so-called independent agency becomes clear.

This press release is not about ensuring the safety and soundness of members’ funds or enhancing the cooperative systems critical roles.  It is simply posturing for another assignment in an administration bent on governmental disruption.

The financial and institutional integrity of the cooperative system requires a competent, active regulatory oversight. Institutions that manage financial assets for others are especially vulnerable to self-dealing.  That is why almost every form of money lending, transfer, safe-keeping and advice is subject to governmental licensing and oversight.

Without effective supervision not only will credit unions continue to be lost, the playing field will become crowded with internal and external predators trying to cash in on the abdication of, and disrespect for, regulatory oversight.

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What Cooperative Owners Should Know When Their CEO Buys a Bank

Credit unions purchases of for-profit banks have become a  more frequent and accepted coop strategy.  The most recent total count is 77 purchases since 2010 with 22 announced in 2024.

Buying banks  requires the credit union to pay cash versus the option of issuing new shares or partial cash and share offers when banks purchase each another.

This cash outlay means the members’ collective equity is being used to pay bank owners for their shares, often at premiums  of 1.5 to 2.0 times the bank’s net worth.  The gain or increase is booked as “good will” a non-earning asset that must be evaluated for future write downs.

In  all these situations the members have no say. They are informed  after the deal is signed subject only to “regulatory approval.”  Information as to how and why this outlay of the credit union’s capital will benefit the members is rarely presented.

Moreover, most of these transactions are  serendipitous bought to the credit union by brokers hoping to facilitate a sale for a fee.  There is often no connection or knowledge of the bank.  Sometimes it is far removed from the coop’s existing market.  In one case in Arizona, the credit union  converted to a state charter to acquire a bank outside its FCU’s field of membership.

What Should Member-Owners Know?

What should the credit union owners be told about this use of their cash?  The most important question  is how this transaction will benefit the members.

When purchases are completed within the banking industry the standard disclosures are straight forward-what will be the impact on earnings, dividends and recovery of the capital outlay.

A Case Study in Financial Disclosure

Yesterday the $1.9 billion QNBC Bancorp (QNBC) (Quakertwon, PA)announced the purchase of the $477 million Victory Bancorp in Limerick PA.  As both are publicly traded companies, there is much market and call report information about both firms.

The press release led with the total purchase price of $41 million, based on the closing price of QNB shares in this all share transaction.

While there were other general details of the benefits of the sale such as similar culture, business models and greater combined resources, the crux of the announcement was the financial justification for the transaction for both banks’ shareholders.

In the case of the seller, Victory, the stock price (VTYB) has fluctuated between $10-$11 per share even though it reported a net book value of over $15 at the June 30, 2025 call report.  Last night the stock closed at $18.20 per share.

The $41 million total price is 132% of the banks shareholder net equity of $31 million.  The bank’s YTD performance though the second quarter was an ROE of 9.07% and ROA of .59%.  Both OK numbers, but not great.  But what stands out is that Victory reported zero delinquencies and charge offs in the first six months of 2025.

It is clear why Victory shareholders might be interested in this instant gain in the value of their shares.  But what will the purchasing bank owners gain.  This was discussed at length with specific goals in the announcement under the heading, Financial Benefits of the Merger.  Following are from the proforma financial projections how this transaction will impact QNBC’s owners:

The transaction is projected to deliver approximately 16% EPS accretion to QNB’s 2026 estimated EPS and approximately 19% EPS accretion to QNB’s 2027 estimated EPS. . . The expected tangible book value earn-back period is approximately 3.3 years. . .

On a pro-forma basis for the year 2027, the combined business is expected to deliver top-tier operating and profitability metrics upon fully phased-in integration plans, including:

  • Return on Average Assets of approximately 0.80%
  • Return on Average Tangible Common Equity of approximately 13%.

The pro-forma combined company financial metrics are based on estimated combined company cost synergies, anticipated purchase accounting adjustments, and the expected merger closing time horizon.

Specific financial outcomes based on proforma estimates.  This is what shareholders  expect to see when their shares are diluted with this purchase using newly issued shares.  This is what regulators will use to evaluate their supervision and approval.

The announcement also contains the traditional statements about future hopes:

Beyond just this transaction, this partnership represents an exciting opportunity to build one of the most dynamic and growth-oriented community bank franchises in all of Pennsylvania.”

But the bottom line on this event is the financial benefits to the owners of both financial fimrs.

The Need for Financial  Disclosures

This is an example of the financial disclosures and goals credit union CEO’s should be providing their owners when announcing bank buyouts.  It is standard industry practice and obliquitory for regulatory review.

When credit union’s buy banks the bank shareholders are given full financial details as to why this is a good deal for them.  The NCUA and FDIC require full financial proformas to analyze for safety and soundness issues.

The only owners left in the dark at the credit union members whose funds are being used to pay a premium to the bank’s owners.  It’s past time for credit union owners to have this full information.  It is essential to  understand whether the transaction makes financial sense  and to hold their leaders accountable for the proforma outcomes.  Right now everyone else has the details except the owners footing the bill.

The CEO and Board’s Fiduciary Responsibility

If credit unions want to compete to buy banks, then they should be held to the same financial disclosures to their member-owners as the banking industry requires of their institutions.  Otherwise we risk creating a dark market where the facts are unknown and  accountability for investing member funds is lacking.

The bottom line is that it is the CEO’s fiduciary responsibility to the credit union’s owners to be fully transparent when using their capital to buy a bank.  It is the Board’s duty to ensure this disclosure takes place.

 

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Serving Multiple Masters

Jim Blaine’s blog SECU-Just Asking!  has continued almost daily for over four years.

His blogs have focused on SECU’s changes of policy, norms and practices which he and Mike Lord, his successor, developed over four decades.

These changes of direction included potential mergers, ending the partnership with Local Government FCU, considering business lending and expansion of the FOM.  But his early and most strident criticism was the implementation of risk based pricing on consumer loans.  The prior practice was to charge each member the same interest rate on loans of similar maturity independent of the members’ credit score.

Jim then exercised the owner’s option to recruit members who were open to his point of view to run for open board seats at the annual meeting.  The first effort was successful in that all three member-nominated candidates won over the board’s chosen.

But since that first success the board has enacted bylaw and other procedures to make it increasingly difficult for independent candidates to run–and then eliminating any “live” member participation at the owners’ annual meeting.

Jim’s SECU blog is sometimes caustic and personal.  But most often he tries to present his policy concerns with facts, logic, SECU’s experience, and occasionally referencing other credit unions.

Creating a Unicorn

He believed that long term success depended on creating unique value through  innovation rather than following conventional wisdom or practice.

He would reference the unicorn as a standard for differentiation–mythical or real.

The Basic Question Animating His Commentary

Recently Jim began a series of blogs on SECU’s use of the the 30-year mortgage as the industry standard for home lending.  A practice that includes periodic sales of those loans in the secondary market to minimize ALM risk.

This analysis began on September 18 with a blog titled: SECU “Reinventing The Wheel” With 1930’s “New/New” Mortgage Model.

Subsequent posts have demonstrated the advantage of ARMS for members in many circumstances, but not all.  You can read his follow on daily analysis at the site.

What’s At Stake?

I chose this issue to illustrate what I see as Jim’s basic concern with the many changes suggested and introduced by his successors over the past four years.  His critique is more fundamental than a difference of business judgment.

At the core is a profound  philosophical difference in what it means to be a cooperative.

Jim’s believes the credit union  is owned and exists strictly to serve the best interests of the members.  The most important corollary is the coop’s loyalties cannot be divided between other stakeholders and their business values.  Especially when choosing operational partners, interacting with regulators or even working with other credit unions.

Reading his critique of the industry standard of the 30 year mortgage, this concern comes through loud and clear.  Yes, many persons believe and have been schooled to think that this is the optimum choice when it may not or would not be the best option.

For this is a product designed, facilitated and controlled by two quasi-governmental entities  Fannie and Freddie.  They determine what is best for consumers and their financial duopoly, not for the  consumer requesting the loan.

When one looks at his other critiques, they often ask a basic question, Why is this action, change, or initiative in the members’ best interest?

What is occuring at SECU and many other credit unions is that industry stature and growth  are the primary drivers of change.   We see this reflected in mergers of long-serving, healthy independent credit unions, the buying of banks and outside businesses.  Most critically this disdain for members well being is demonstrated in the  elimination of any owner role in the election or other involvment at their annual meeting.

The coop model has been increasingly hijacked by leaders who inherited generations of member created financial wealth that they presume is now theirs to use as they alone determine.

One of the oldest lessons from all faith traditions is that a person cannot worship both God and mammon.  A number of today’s credit unions have given up on honoring members’ interest as the highest good.  Instead their goal is to become an industry asset leader, to paraphrase a recent CEO’s defense of mergers.

Or, as explained by the $9.0 billion Community America’s CEO Lisa Gitner (Kansas) in proposing a merger with the $3.5 billion Unify Financial Credit Union in Allen Texas:  “Now, we have an opportunity to expand our reach and create more access to CommunityAmerica for you, your families, and even more people across the country. I’ve always led CommunityAmerica with goals that are defined by how many people we can help–not by how much revenue we can generate. That is the driving force behind a transformative milestone in our credit union’s history–and the reason I am writing to you.”

Or to put the issue more bluntly, what consumer or member is going to choose this credit union because it will now “have a presence in 18 states and 22 markets, with branches in Arkansas, California, Nevada, Tennessee and Texas?”

 

 

 

 

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A Shadow Taller than Ourselves?

During this summer’s  legislative and budget battles in DC various spokespersons presented the credit union point of view.  Protecting the tax exemption, interchange fee status quo or jumping on the regulatory reductions were top concerns. Often the credit union position was defended by citing  the special value coops provide members.

In one situation a CEO’s testimony would have been contradicted by his own institution’s performance and priorities if Congress had bothered to look it up.

McCormick Foundation Professor Mohanbir Sawhney describes this natural tendency for exaggeration. While his description focuses on individual behavior, it is also relevant to institutional promotions:

“It’s often necessary to cast ourselves in a favorable light on social media, in resumes, in job interviews, and even on first dates. 

“But in doing so, sometimes we end up creating a shadow of ourselves that looks taller than who we really are,” Sawhney says in a video on humility. 

“When this projection stretches beyond the bounds of reality, we can start to feel disconnected from ourselves, from others, and from opportunities to grow. 

“That’s not to say that we shouldn’t promote ourselves or polish our brand. Rather,  we should do so, but with humility—by standing tall quietly, without fanfare or drama, and by being confident, but in an understated way.

Do Results Align with our Vision?

The issue is alignment between who you say you are and who you actually are.

Humility isn’t smallness or silence. It’s clarity. It’s knowing your strengths without distorting them. It’s being visible in the right way, for the right reasons.

As the sun sets today, take a look at your credit union’s shadow.   What events occurred  that gives members a true picture of who you are?

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A Morning Reflection

Hardin and Weaver were the dominant morning radio co-hosts for the  going-to=work drive in DC in the 1980’s.   Right before the 7:00 AM news update, they would finish their broadcast hour with a morning hymn.  A moment of grace before world events, sports weather and traffic briefs.

I was reminded of their disruption of secular events by an observation from academic Ti,pthy Snyder during his current trip to Ukraine.  In a front line town, he describes moments of incredible kindness by residents living under never ending threats of drone attacks.  He writes:

Always be kind.

Does kindness seem like a naive message during a war of extermination? Not to me. I admire friendly parents and kind children in the best of times, and I will admire them in the worst of times.

To defend you have to have something to defend. It will always be out of reach, but it matters whether or not you are reaching, or teaching others to reach.

The following anthem, Until Love is Spoken,  was written in 2022 during Covid.  But the words are appropirate for today’s’fraught circumstances. In this interview  the composer Karen Marolli  relates her musical background.

(https://www.youtube.com/watch?v=OZq7gLsRfrg&t=216s)

The words  call for community engagement and hope.  One verse is:

And when our path of justice leads us to the dreadful fight,

Grant us vigor and entrust us with the power to do what is right, 

Grant us courage to be kind,

Grant us singleness of mind to free the world from hate and fear,

So only love is spoken here.

While not overtly religous language, it celebrates the power of purpose for a cause. Or, what matters is that your are reaching or teaching others to reach. 

 

 

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Two Forms of Competition Always Present

Two classic strategies for creating competitive advantage are a superior employee centered service culture. The second is to embrace  innovation.

Following are two updates in both areas.

Minimum Wage in Banking Now Hits $25 per Hour

Bank of America will increase its minimum wage to $25 an hour next month, the final step in a long-term goal the company set several years ago. The move bumps pay up from $24, a level put in place last October, the company said Tuesday.

It translates to a full-time annualized salary of more than $50,000 and applies to all full-time and part-time hourly positions in the US. The change continues a series of hikes lifting the firm’s base pay from $15 in 2017.  Source:  Marketplace and (link)

Digital Assets and Innovation

I am a novice in understanding the world of digital assets from Bitcoin to all the stable coin options now being evaluated and offered by financial firms.

Whether used as a store of value or investment, payments between parties or for operating outside the regulated financial services sector, I have not been able to identify a compelling value proposition.

The hype and people rushing to get into this new form for financial service have only accelerated since the Genius Act passed by Congress last month.

Here is a summary of some activity and loopholes by analyst Aaron Klien from Brookings in the article: Interest by any other name should be regulated as sweetly (September 10, 2025)

Cryptocurrency is an asset masquerading as a payment instrument. Congress did not see through this illusion and created a dangerous loophole in the newly passed stablecoin law, the Guiding and Establishing National Innovation for U.S. Stablecoins Act, or “GENIUS Act”.  

The law is premised around a simple trade-off: Stablecoins are exempt from bank-like regulation and in exchange are prohibited offering interest on their coins. The law’s ink is not dry and crypto firms have already found a loophole, calling interest “rewards.” If we don’t close this loophole, it could cause massive problems resulting in losses by retail crypto holders, a bailout of big crypto, or a financial crisis.

Bitcoin started with dreams of being a global currency but has become an asset and, for many, a profitable investment (so far). One reason bitcoin works so poorly for payments is its swings in value. Enter stablecoins, usually pegged to the dollar, eliminating this problem. Yet, stablecoins are primarily used for buying and selling other crypto, not for ordinary transactions. While about one in seven Americans report owning crypto, only one in 50 Americans used any form of crypto, including stablecoins, to buy anything other than crypto in 2022.

So, if stablecoins aren’t used for payments, why do people own them?  For many, it’s the same reason they keep money in banks: earning interest. The new law prohibits interest, but what if someone called interest a different name? Would it pay as well?

Coinbase, the largest American crypto exchange, proudly markets 4.1% “rewards” for holding USDC, the largest American issued stablecoin. Crypto.com offers variable rewards based on market conditions, while highlighting its latest partnership with Trump Media Group on their crypto. Its competitor Kraken offers even higher: 5.5% rewards. Notice Kraken marketing an annual percent yield (APY) notation to look like interest. That’s what this is.

Technically, the new law only prevents stablecoin issuers like Circle, which issues USDC, from offering interest. Coinbase, Crypto.com, and Kraken do not issue these coins, they just hold their customers’ coins. Imagine if E-trade or Merrill Lynch offered customers money for letting them “hold” their stocks, and you’ll see the parallel.

The economics of this loophole are problematic. Crypto exchanges generate profit to pay “rewards” to people who deposit crypto through a combination of payments from the stablecoin holders and potentially using depositors’ funds to make their own investments. The larger the rewards customers are being paid, the riskier the investments generating that money. Banks do this with your deposits, but with tight limitations, constant oversight, and federal deposit insurance that fully covers 99% of depositors. Crypto exchanges have none of these guardrails, as FTX demonstrated when it took customer assets to speculate and collapsed. . .

Credit Unions Invest in Crypto

Klein’s analysis continues for another ten paragraphs.  What makes his concerns relevant for credit unions, is that there are numerous crypto related firms and credit unions now investing in stable coin services,  The primary goal is giving members access to the purchase and holding of digital assets.

Yesterday CU DAILY reported “Stablecore, a platform that enables community and regional banks and credit unions to offer stablecoins, tokenized deposits and digital asset products, said it has raised $20 million in funding, including from a credit union-backed fund.”  (link)

Stablecore’s purpose is to  serve as a “digital asset core,” unifying the critical components of digital asset offerings into a single platform.  The credit union  CUSO making the investment was Curql.

Both these announcements may challenge credit unions who are uncertain about their core values and competitive advantage.  So before you reach out to match competitors thrusts, remember success comes not from playing the game you find, but from defining the game you want to play.

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Do Cooperatives Change Market Practices?

An historical note to start:  Today is Constitution Day in the United States, because it was on this day in 1787, at the old State House in Philadelphia, that the final draft of the Constitution was signed.

From Jared Brock on capitalism’s financial incentives:

Turning anything — money, houses, scotch — into investment products skyrockets the price of things.

Financialization… the process of turning anything into an investment… skyrockets prices.

Think Taylor Swift concert tickets, Beanie Babies, baseball cards, cryptocurrency, etc.

Turning an item into an investment increases its price.

We’re currently witnessing this with the financialization of classic cars, high-end wine and scotch, and fractional investment in paintings.

A rare piece of canvas covered in colored paint is only “worth” $100 million if the investor knows he can rent that painting to a museum and re-sell it for $110 million in the future.

Because it’s more profitable to get rich by monopolizing stuff and lending it for a profit instead of actually working to create new stuff to sell, the rich are actually incentivized to bid up prices instead of creating new useable goods and services for others. Shareholders are actively trying to destroy our wellbeing for profit.

From a credit union observer:

“Cooperatives are the future of our ecosystem. It is how we take care of each other, how we take care of our community, and it’s how we can create generational wealth for all of us moving forward without being a part of this really extractive system.”

The question:  Do credit unions practice both these economic goals for example in mergers and bank purchases? Is being a part time coop good enough?

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Credit Union Members on Housing’s Margins

Who can credit unions help the most in this time of economic transition?  What one economist calls a “bifurcated” consumer economy.

If credit unions fail to serve members facing the difficulties described below, who will?

Housing At the Margins

From a Marketplace (link) report last week:

, , ,real estate data firm ATTOM reported that foreclosure activity — which includes default notices, auctions, and bank repossessions — was up 18% in August compared to a year ago. In fact, foreclosure activity on properties across the U.S. has been rising for the past six months.

It’s not up to pre-pandemic levels, but it does signal more trouble in the economy.

Home ownership is the single most important step to financial well being for the majority of Americans.  Does your credit union have a program to help members who are having difficulty meeting their mortgage payments?   What options do you offer?

Evictions

A related but different challenge are members facing eviction from rental properties when coping with job loss or other economic crisis.

A film from March 2025 talks about the many factors contributing to evictions.   There are two trailers one for the longer movie, Evicting the American Dream (link).

The second three minute trailer focuses on evictions and the economic forces driving this process.  (link)  Most impotantly this short excerpt shows the impact on the consumer’s credit report as well as all those listed on the eviction notice, often all the family including children.

Credit unions were formed to provide an option for those on the margins of the economy supported by the participation from  the whole community including those who are doing well.

When was the last time your credit union loaned to a member who had an eviction notice on their credit report?   How do you identify and reach out to those whose paychecks are not enough, or maybe lost?

Should we just serve those doing well who easily fall within our rule bounded services  or worry about  proverbial “lost sheep?”