Author: Chip Filson

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Twenty Five Years as CEO and Counting

The Chairman of CU*Answers announced at the CUSO’s 2019 Annual Meeting that the CEO would have his twenty fifth anniversary this month.

Many important accomplishments could be listed from this quarter century of management leadership. But I would highlight two critical processes that have contributed to this success.

The first is his ability to always plan ahead, not just manage the present moment. An example was the announcement that the cooperatively-owned CUSO will be investing over $400 million in technology spending in the next five years. That fact underwrites the CUSO’s ability to “pay it forward” for future generations of users and their members. The first rule of technology management is that it requires constant reinvestment.

A second factor oftentimes overlooked, is Randy’s unceasing efforts to encourage participation by all the owners and users of the CUSO. This is accomplished by more than traditional cooperative practice of boards, committees and annual meetings. He constantly invents new ways to incent feedback by owners through boot camps, leadership conferences, board planning sessions, and a never ending deluge of emails seeking reactions.

As important as money may be to sustainability, it can never substitute for passion. And participation encourages passion and cooperative pride of ownership.

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The Source of Credit Unions’ Soundness

“Our movement does not exist because it was created from the top down. Rather it was created from the bottom up. . . we did not tell Congress we wanted to be “safe and sound” institutions. We always knew that if we were lending to our members, there was risk involved. Serving came first; safety and soundness was a means to the end of serving.”

(Ed Callahan May 1999)

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Independence Day Names Only Half the Holiday

July 4th is the grandest of America’s patriotic observances. We celebrate the declaration that the colonies are free from the rule of the British crown.

Freedom is frequently described as freedom from something: fear, want, rule by an external force or exigency.

But freedom from also enables the ability to do something that might otherwise be feasible. It is this empowering opportunity that Ed Callahan as Chairman of NCUA singled out in a speech to the Mass CUNA League’s Annual meeting on November 3, 1984.

Deregulation had freed credit unions from the government’s rule making and oversight of operations and given that responsibility to boards and managers. It had provided a context where credit unions were empowered to make decisions not previously open to them. Ed singled out three new freedoms:

  • Freedom to compete: credit unions now make their own business decisions;
  • Freedom to serve: credit unions now decide who the membership will include;
  • Freedom of security: credit unions have their own unique insurance safety net and liquidity fund.

These freedoms were possible because of the unique cooperative design that harnessed members and credit unions in a interdependent system of self-help and self-reliance. Combining independence and interdependence is what makes the cooperative system unique.

The Rouser at the End

Ed as an old football coach often completed his speeches with a motivational exhortation.

In this case he challenged the attendees to go beyond the rhetoric of people helping people, or reciting the movement’s historical milestones. He stated: “You’ve got to go forward from this time to document that people serving people is not just a slogan, but a reality.” Show your congressman what you have done for the elderly, the retiree, the people moving, the high schoolers, the kids and children.

“We’re all flesh and blood. We turn to our credit union to help us out.”

Freedom enables both independence and interdependency. Collaboration and autonomy. United in cooperative design.

Credit unions are as American as apple pie. They enable members’ financial well-being and to be engaged in a community of peers.

“Independence Day” includes a special irony. For it is not just freedom from, but freedom to do.

And credit unions are a unique example of the fruits that this freedom can produce: social impact and personal fulfillment.

Happy 4th

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An Example for Today’s Credit Union Pioneers

In 1925 Michigan passed its first credit union act. A November 21, 1925 brief article in the Grand Rapids Press reported on efforts to implement this new authority with the following lead:

Roy F. Bergengren, Boston Secretary of the Credit Union National Extension Bureau conferred with several business men and Association of Commerce officials Saturday regarding organization of credit unions in Grand Rapids.

The article then describes what a credit union is and its purpose: “to help members and give them good credit standing.”

The final paragraph records a powerful example of the cooperative’s appeal Bergengren used in his talk. “15 telephone girls in Boston organized a credit union with $4.50 in total funds. The credit union now has 13,000 members and $280,000 in total funds.”

From Small Seeds

While learning the immediate reactions to his pioneering proselytizing would require more research, today Michigan has 225 credit unions headquartered in the state, serving over 5 million members and managing $67 billion in assets. Credit unions hold 20% of all financial deposits making Michigan one of the most heavily credit-unionized states in the country.

From a small seed mighty results have emerged. How might Bergengren react to the fruits of his labors almost a century later? With satisfaction? Or perhaps with questions such as:

  • Where are today’s credit union pioneers?
  • What seeds are they planting?
  • What partnerships are they building in their communities?
  • How have the members benefited from the growth of credit unions?

My sense is that he would be asking questions knowing that the answers will condition the future of the credit union movement in Michigan. While brief, the article illustrates several timeless factors necessary for today’s cooperative entrepreneurs who seek to further the work of the original Credit Union National Extension Bureau.

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The Greatest Generation: What They Did for Credit Unions

Tom Brokaw’s characterization of my parent’s generation as the “greatest” is recalled every time a WWII commemoration is presented.

But as the recent celebration of the 75th Anniversary of D-Day is overwhelmed by present events, it is important to remember another vital contribution this same generation made when not fighting a world war.

Children and young adults born of Depression-era parents, also accelerated a self-help movement for economic democracy that continues to thrive today. It is the $1.5 trillion cooperative credit union system which counts almost a third of Americans as member-owners.

The seeds were laid from 1909 to 1934 in states that passed over 25 laws authorizing cooperative charters. That pioneering “proof of concept” provided the credibility to pass the Federal Credit Union Act in 1934. Now credit unions could be formed anywhere in the country.

A Chartering Tsunami

What happened next is as dramatic a change as occurred in any post-war industry in America. For with the encouragement of the Bureau of Credit Unions housed in a small niche of the Department of Agriculture, the credit union option flooded across the US.

From a first-year total in 1934 of 78 new credit unions, the total of active federal charters peaked in 1970 at 12,977. Except for the war years of 1943-45, the net growth of new charters was 300-400 per year, with a high point of 852 new credit unions in 1954.

By 1970 the total of all credit unions was 23,687 of which 10,132 were state-chartered.

How could this dramatic expansion in just one generation have taken place?

Two Who Helped Build the System

Just as the war years produced leaders and heroes, so also did this national chartering effort by those fighting for consumer choice in a financial service industry dominated by for-profit firms.

Many factors aided the dramatic growth of cooperative charters: the need for consumer credit, the support of employer-sponsors, the creation of support organizations for the credit union system, and the post-war economic boom. However, these favorable circumstances still needed cooperative entrepreneurs.

One of Those Was Louise McCarren Herring (1909-1987)

I first met Louise while at NCUA in 1982 where she was escorted by Sam Rizzo, the President of the National Deposit Guarantee Association (now called ASI), a cooperative state-chartered insurance alternative to the NCUSIF.

Her stories about participating in the founding of CUNA in Estes Park, Colorado in 1934 were memorable as she was sole living participant from that event.

But more significant than being present at the beginning, was her role in chartering hundreds of credit unions throughout the state of Ohio, including 17 within the Kroger Company’s grocery store chain  where she had found her first job.

Louise’s contributions were more than chartering. She helped create organizations that were essential to the growth of the emerging credit union support system including leagues, centrals, and alternative deposit insurance. She was an ardent supporter of choice and dual chartering.

Her passion for cooperatives was unabated late in life. She believed everyone should have an opportunity to belong to a credit union. During deregulation when credit unions were arguing whether credit unions could have member overlaps, she defended the opening of the charter and the importance of serving entire communities with the logic: Poverty is not a common bond.

The Organizer

Lance Barden (1896-1967) helped organize 400 to 500 credit unions. After WWI service and college, he joined the US Farm Credit Administration (FCA) in Berkley, Calif. While there he formed a credit union for the employees and served as both manager and treasurer.

A year and a half later he was appointed federal credit union organizer in the FCA’s credit union section for northern California.

In the book The California Story, his wife describes his work as a credit union organizer. “Our entire lives were wrapped up in credit unions. Even our weekends; managers of small credit unions would visit us regularly on Sunday afternoons and Lance taught them bookkeeping and accounting.’’

Lance was sent to Hawaii in 1936 to continue credit union organizing. The plan was to stay two weeks and start a half dozen or so. Instead he stayed the entire winter and organized close to a hundred.

He also helped to form leagues in California and Hawaii. His work became a family vocation and commitment. His son and daughter became credit union CEOs. His granddaughter Sue Longson became CEO of a credit union in her teens and continues as a consultant today.

Lance’s example of hard work, sharing firsthand experiences and an exceptional commitment to the cooperative model demonstrates what one government employee can accomplish. While verifying specific numbers of new charters is difficult, what is clear is that whatever the final count, he helped to found more credit unions than NCUA has chartered in all the years since 1985.

Lance’s wife told a story that illustrates Lance’s belief in the credit union model. When he organized a new credit union, he would ask for the money right on the spot. “Right then and there. There was one time a very poor man had just died. The credit union didn’t even have its books setup, but Lance lent the first nickel he collected to the man’s family for his funeral.” He always said, “When you give your money to a credit union, it will be put to good use immediately.”

The Greatest Generation’s Gift to Us

This phase of credit union history is about more than new organizations and building organizational support. Lance and Louise’s contribution was more than hundreds of new charters. What they “paid forward” was a set of values along with institutions to sustain those ideals.

Recent events have shown how cooperative institutions can be quickly and quietly merged or closed.  The loyalty of generations lost.. Objective accomplishments are overlooked.. Shared values are the foundation that sustains cooperatives.

The greatest generation paid forward an enormous legacy for their children  Can we maintain and extend this inheritance?. Should  we aspire to do anything less?

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NCUA Board has a Unique Opportunity to Eliminate the Flawed Risk Based Capital Proposal

This Thursday (June 20) the NCUA Board has only one topic on the agenda: the Risk Based Capital Rule (RBNW). Rodney Hood will be the 4th Chairman to address the issue.

He and fellow board member McWatters will have the chance to set a whole new direction for regulatory policy if they choose to do the obvious and cancel outright this deeply flawed rule-making effort.

Not only would such an action align with the administration’s policy priorities, it would also end a regulatory approach that is problematic. All other financial regulators have moved away from the belief that future risk can be both predicted and modeled so accurately so as to require specific and relative levels of capital more than sufficient for any future crisis.

The Proposal’s Flawed Foundation

In the post 2008/2009 financial crisis, FDIC and bank regulators reduced reliance on risk-based approaches in favor of a simple leverage capital ratio. Tomas Hoenig, the former Vice Chairman of the FDIC, championed this clearly understood and easily calculated capital ratio. At the same time, he repeatedly documented the flawed premises and historical errors of modeling future risk relativities among myriad categories of bank assets.

However, NCUA under Chairman Matz introduced this flawed approach that was so lacking in factual foundation that the initial draft had to be withdrawn; but then it was reintroduced a second time.

This revised proposal drew significant dissent from new board member McWatters who was in the minority 2:1 board vote to approve the regulation.

“Based upon my thirty plus years of experience as an attorney who has worked in many intricate issues of statutory and regulatory interpretation, I am of the view that NCUA does not possess the legal authority under the NCUA to adopt a two-tier RBNW regulatory standard.

NCUA staff did not undertake a formal estimate of the recurring compliance costs of the proposed regulations… Regrettably this additional burden falls on a financial services sector that is not too-big-to-fail and was in no manner responsible for the recent financial crisis.”

Kicking the Can Down the Road

The objections and complications of the rule were so great that NCUA delayed the final implementation until 2019 to allow time for the agency to expand its call report and internal software to be able to monitor the new rule.

When there were two board members only, Metzger and McWatters, they agreed to postpone implementation another year, til 2020. Congress has even proposed a law to delay this proposal further, a traditional political tactic when a flawed policy cannot be ended outright.

In the meantime, credit unions reported continually rising levels of capital, ending at over 11% collective net worth as of March 31.  This is 400 basis points over the well-capitalized regulatory requirement of 7%.

Taking a Cue from Bob Dylan

In 1966 the folk singer Bob Dylan faced a circumstance which he memorialized in the song 4th Time Around.  It starts with these words:

When she said, “Don’t waste your words, they’re just lies.” I cried she was deaf.

This is the 4th NCUA Board to consider imposing a detailed capital model when the credit union system was the only one to navigate the last crisis relatively intact under no risk-based rule. The RBNW rule is not only flawed but potentially dangerous to the future of credit unions. It rates certain categories of assets as risk free versus other assets.

This approach could induce credit unions to make decisions that could end up pushing all credit unions into the same risk profiles. As FDIC Vice Chairman Hoenig pointed out, the lowest rated risk categories before the Great Recession were sovereign debt and real estate collateralized securities. Both asset classes were at the center of the declines in asset values in the 2008-2009 crisis.

As the woman in Dylan’s song pleads, “Don’t get cute.” The circumstances and history of this wrong-headed regulatory effort suggest that it is time for the board not to get cute once again. Rather it should reject this approach to determining credit union capital adequacy. Or will the Board be deaf to the lessons provided by the last six years of this misguided effort?

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Cooperatives and Avoiding the “Blame Game”

After the Bay of Pigs fiasco in which a CIA backed Cuban exile group landed in Cuba to overthrow Castro and were defeated within days, President Kennedy took full responsibility with the observation “Victory has a thousand fathers, but defeat is an orphan.”

Unfortunately that is not true in real life. Whenever a problem shows up, especially one that results in real loss and tragedy, there are plenty of persons willing to point out those responsible for the defeat. It is called the “blame game.” Its purpose is to shift responsibility away from those responsible for resolving problems to those who caused the “defeat.”

The whole taxi medallion crisis, centered in New York City, is a case in point.

The New York Times ran a series of three articles two weeks ago showing the harm caused to almost 1,000 individual medallions owners by the dramatic declines in value since 2014. This three-part series was just converted to a video broadcast in a 30-minute Hulu special in The Weekly.

The fingers of blame are pointed everywhere: at the taxi-limousine commission, the New York city council, the medallion brokers, the multiple bank and credit union lenders, the regulators. And of course the external-event-defense: Uber and Lyft’s ride sharing economic disruption. NCUA in its public statements has blamed the credit unions, boards, disruption and even admitted its oversight of “concentration risk” was not as diligent as it should have been. But no matter, NCUA just took over $1.0 billion in cash and paid off the shareholders, gave the loan medallion portfolios to external servicers, and washed its hands of the problem.

And that is the real problem. Credit unions were formed to walk toward members and their difficulties especially in times of trouble. Instead of encouraging and helping the medallion borrowers at the time of greatest need, NCUA cut and ran. Most of the taxi medallion credit unions had fully reserved for the potential losses as values fell to cash only sales of around $200,000. In one case a merged credit union had not only written down the values, but still had loss reserves of over 50% for the amounts still on the books. But the examiners prohibited the credit union from rewriting loans or making other accommodations that were in everyone’s best interest. As one CEO said, the examiner’s goal was to put the credit union out of business.

The billion dollar cash outlay for the liquidations of LOMTO and Melrose locks in losses at the time of lowest value. And therefore the greatest loss. No upside potential is possible. In the NY Times Hulu video story, an advocate for the medallion owners states that the income from a taxi license would support a loan of $400,000; but that value can only be realized if someone is using it to generate income. Meanwhile hedge funds are paying cash at foreclosures because lenders and regulators have shut off any financing possibilities for medallion user-owners.

An economic valuation cycle is thus turned into multiple personal crises for credit union borrowers because the institutions set up to serve them, denied help when the members were most in need.

Disasters happen. Some are caused by internal failures, some by external events over which an institution may have no control. This is why there is a regulatory system. And why as part of this “system” credit unions have an “insurance pool” funded by 1% of every shareholders savings. This is the critical source of financing when necessary to transition from problem to solution. But resolutions get aborted when the fund is used to expense away current difficulties. That is not why cooperatives were created. That is not why the NCUSIF was funded with members’ savings.

The inability of NCUA leaders to acknowledge their responsibility for resolving problems, not liquidate them, only leads to the next set of problems. In this case it is the destitution of over 700 medallion owners who have declared bankruptcy and for many others burdened with debt they cannot see a way out of. The expensing of member funds to make problems go away ultimately leads to greater and greater problems down the road. The self-help and self-financing capability of the cooperative model is compromised any time a problem just becomes a liquidation event. Mergers just transfer the responsibility to somewhere else in the system. The crucial resilience and patience that cooperative design allows is fatally neglected for instant resolutions.

The problem of relations with Cuba that JFK thought he was resolving is still unfinished business today. When NCUA plays the blame game versus acknowledging the responsibility to transform problems into turnaround stories, there will never be any victories for which to claim success. Only an ever mounting, open ended expenditure of member funds to sweep mistakes under the rug. This corruption of the system’s cooperative model could in the end destroy it.

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The Hamilton Question and New York’s Municipal Credit Union’s Conservatorship by NCUA

The last song in the runaway hit musical Hamilton ends with a question:

Let me tell you what I wish I’d known
When I was young and dreamed of glory
You have no control
Who lives, who dies, who tells your story?

On May 17, 2019 NCUA was appointed conservator of the $3.03 billion state-charted Municipal Credit Union. The March 2019 call report data shows 588,000 members, a net worth ratio of 7.6%, delinquency of .77%, and an allowance account funded at 150% of total delinquencies. No taxi medallion loans.

The New York regulator had previously removed MCU’s supervisory committee in May 2018 and the full board in June 2018. It designated an “on premises administrator”, Mark Ricca, to oversee the general management. Mark had no credit union background.

When appointing NCUA conservator, the state also removed its chosen administrator. NCUA provided no information about who will be running the credit union and under what guidance since there appears to be no immediate financial safety and soundness issues, but a leadership transition event.

The impetus for state action was the arrest in May 2018 of the former CEO Kam Wong. He pleaded guilty in November 2018 and in June 2019 was sentenced to five years in prison and ordered to forfeit $9.9 million to pay restitution to the credit union for the amount he had defrauded. The misuse of credit union funds extended from 2013 through 2018. The credit union has received a bond settlement for loss as well.

What’s next for the members?

On January 10th the Brookings Institution hosted a conference entitled Ten Years Later: Lessons from the 2008-09 Financial Crisis. One speaker was Lawrence Summers who was Treasury Secretary from 2009-2011, a PhD economist and former president of Harvard University,

During the Q&A he was asked why the government did not take over the direction of the troubled banks and insurance companies instead of TARP funding, much like the conservatorships of Freddie and Fannie. His answer was succinct: “it is my experience that government intervention in banks is a major destroyer of asset value.” He further commented who wants to run or do business with a conserved government-directed institution?

NCUA’s track record as a conservator is extremely mixed but on balance proves out Summer’s conclusion. NCUA’s conservatorship of the two largest corporates and then takeover of three more in a mass liquidation process destroyed solvent institutions that according to NCUA’s own numbers today have estate surpluses of over $5.6 billion, of which $3.1 has been transferred into the NCUSIF.

By setting itself up to run a credit union as a conservator, NCUA has a conflict of interest. Does it act in the members’ best interests or does it act in its own self-interest? As in all conservatorships, the members have no voice. The board is gone, and often the person appointed to lead has little or no background in the credit union, and is little more than a hired gun until some external resolution can be reached. Restoring the credit union to self-sufficiency rarely occurs, because in so doing it contradicts the logic that government takeover was necessary in the first place. Moreover as in this case, the NCUA and the state had examined the credit union annually from 2013 to 2018 while the misappropriations occurred, and apparently found no wrong doing. So the tendency is to shift the responsibility for the situation to the bad actor and the lack of board oversight, not the possible shortcomings in the exam process.

The Key to Success

Conservatorship or even replacing a CEO while leaving the board in place to ensure members’ interests are represented, can be done successfully. During the financial crisis several noteworthy turnarounds were engineered by John Tippets at North Island Credit Union and Bill Connors and Andy Hunter at Silver State Credit Union in Nevada.

The key success factor is finding and supporting the right turnaround leader. The challenge is simple: Any jackass can kick down a barn, but it takes a carpenter to build one.

Will NCUA appoint a jackass or a carpenter? Someone to play caretaker until the agency elects a merger partner to resolve a leadership transition? Certainly there will be vultures a plenty looking to take the “problem” off NCUA’s hands.

Or will the NCUA find someone with the experience, political skills and leadership to restore the credit union to its pivotal role in the New York and broader credit union community? The possibilities are out there. These could include proven, retired leaders such as Rudy Hanley, Gordan Dames, Gary Oakland, Jeff Farver, Steve Winninger or other equally capable and astute individuals whose reputation and knowledge of credit unions and the system would give them a running start. They would not be seeking another job, but have the energy and foresight to bring the credit union members confidence that their future was in good hands.

NCUA has provided no updates on this unprecedented conservatorship of a solvent credit union. But one will know the future when the next acting CEO is named. Will it be a caretaker following direction from examiners who are anxious to get rid of a problem, or will it be a proven credit union leader who can restore the credit union for its members? Chartered in 1916, Municipal is the oldest state charter in New York. Can NCUA make decisions that will sustain this cooperative now serving its fifth generation of members, or will it just fulfill Summers’ bleak assessment of what happens when government takes over a financial institution?

Municipal Credit Union faces Hamilton’s challenge: You have no control, who lives, who dies, who tells your story? Every credit union today should care about this situation.

If a sound, long-established, and well-capitalized credit union can be dissolved without any role for members, what prevents the regulator/insurer from doing the same when your credit union faces a transition?

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Credit Unions and Farming: What we can learn about business sustainability

Clichés are frequently based on an element of fact. But that does not mean they are the truth.

One of the most persistent clichés that drives credit union thinking is that bigger is better. That is, only credit unions with $10 million or $100 million or a $ 1 billion in assets will survive. The consequence of this assertion is that many viable, well-run and long-serving credit unions believe their only future is to merge.

The truth is the cooperative model fits all sizes but especially smaller, niche players. Locally managed, focused, relationship-based financial institutions are needed in large and small communities across America. All credit unions start small, some grow and many remain “undersized” versus the largest few. Size doesn’t determine viability. Rather it is leadership’s understanding of the their business model that creates sustainability.

Living in a small farming community

Several recent conversations about farming and the minimum amount of acres needed to make a living echoed this size fixation in credit unions.

Certainly “conventional” or industrial agricultural models dominate farming in America today. A college classmate recently lamented that the 160 acres of southern Illinois farmland his family inherited was just not financially viable. “We would have to have at least 1,000 acres to make a real profit,” he asserted.

In grades one through four, I lived on a five acre farm outside Divernon, Illinois; a town of just over 1,000 population, about 20 miles from Springfield, the state capital.

We had three ponies, played cowboys and Indians all summer long with our homemade bows and arrows from the stand of poplar trees. Every morning my older sister would milk the cows by hand, my mom would pasteurize and bottle the milk and my dad deliver into town. We raised fruits and vegetables which we sold on the roadside in all growing seasons. We bred and raised our own pigs and several times a year would send a hog to be butchered for meat. We kept the meat supply in a frozen locker in town. The rabbits we raised were for eating, rolled in flour and pan fried just like chicken.

My dad wanted to be a farmer and buy more land but America was literally feeding the world in the 1950s. Five acres provided a rich experience, as long as we understood the best way to use our limited resources.

Community Supported Agriculture

Last month I visited Caledonia, Michigan (pop 1,600) for dinner. As we walked down the two block main street I saw a Schuler Farms poster in a store window selling “shares.” The business offer was full shares for $600 or half shares for $400. This Community Supported Agriculture (CSA) farm model is described as a “micro farm with vision and planning:” I went to the web site for more information.

A CSA honors a commitment between the farmer and the share holders. The members pay the grower in advance for a weekly share of the harvest. The shareholder receives a crate of fresh, local, naturally grown produce from a source they know and love.

The 2019 Membership Agreement reads in part:

In the community supported farm structure, every member of the relationship benefits, the share-holders, the farmers, the farms (the earth), and the greater community.

Each member will receive a weekly share of organically grown gourmet produce, that varies throughout the growing season. The product is expected to be available by mid-May and end in October. We farm with all natural organic methods . . . Our vegetable selections are for the most part based on taste and experience with various varieties, as well as trying new varieties all the time. . . .

Our plan is to start small and develop a core group of members that buy into our philosophy and quality. We are looking for families who have a high vegetable intake, culinary skills, and the time to prepare the food and eat within the season.

This locally focused farm model has become more relevant as a broader change is occurring for direct distribution of farmer’s crops. Since 1994, the number of farmers markets has grown from 1,755 to over 8,700 today. Communities large and small are supporting the need for fresh and local produce.

My current hometown Bethesda, MD has a cooperative Women’s Farm Market where Jean Paul sells plantings and vegetables from his 43 acre farm three days a week.

I believe this growing model of local farming has direct meaning for credit unions.

The diversity of credit union size is a source of system strength. Some small credit unions today will be the seed corn for larger ones in the future. But not all firms or farms can be large scale-whatever size that might mean. Credit unions of any size work well when they focus on the needs of their member shareholders. When that connection gets lost, then scale cannot replace relevance and relationship.

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Habits Never Die, They Just Recycle

A colleague of mine used to describe human nature thusly: People do what they do. Or the traditional observation that a leopard cannot change its spots.

The benefits of bureaucratic organization are many. Structured processes, experience and expertise, and explicit design. These organizational advantages replaced the arbitrary and unpredictable rule by all powerful leaders in authoritarian regimes. Bureaucracy is an essential component of government activity in a democracy.

But the strength of bureaucracy is also its weakness. It is stable, but rarely innovative; it is predictable, not situational in response; it is self-perpetuating even when the original circumstances may have long ago disappeared.

I was reminded of this bureaucratic paradox  when I received the Weekly National Rates and Rate Cap Report from the FDIC seen below.  After deregulation in the 1980s I thought government got out of the business of setting deposit rates.

No, as shown below, when the next big crisis came in 2009, the FDIC reactivated old habits. It passed a new rule setting the maximum rates that any FDIC insured institution could pay that was deemed to be “less than well capitalized.” Every kind of account at every level of maturity is listed. And the rate caps are reset weekly!

Regulatory responses to new events is to reprise old habits. This is definitely not isolated to the FDIC. The same is true of the NCUA. The difference should be that in a cooperative democratic system, the response should always be driven by what is in the members’ best interest, not the bureaucracy’s instinctive recall based on self-preservation.

Weekly National Rates and Rate Caps – Weekly Update

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On May 29, 2009, the FDIC Board of Directors approved a final rule making certain revisions to the interest rate restrictions applicable to less than well capitalized institutions under Part 337.6 of the FDIC Rules and Regulations. The final rule redefined the “national rate” as a simple average of rates paid by U.S. depository institutions as calculated by the FDIC. The national rates and rate caps for various deposit maturities and sizes are provided below.

For more information. see Financial Institution Letter FIL-25-2009

Weekly rate cap information for the week of June 3, 2019.