Category: Co-ops in Capitalism

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NCUA May Board Meeting:  Vice Chair Hauptman Finds His Voice.  Harper Cancels June Meeting

(Note correction to spelling of board member Tanya Otsuka’s name from the initial post)

With Chairman Harper on extended medical leave, May’s board meeting was expected to be a routine quarterly review of the financial status of the NCUSIF.

Instead, Vice Chair Hauptman opened with a ten minute critique of NCUA’s new collection of NSF and OD fees from credit unions in future call reports.

Hauptman’s remarks can be heard early in the Board video.  He is articulate and energized. The proposal was not discussed at any board meeting. He had not heard about the effort till January.  All his suggestions for how to use the information were rejected.

Most importantly he believed the policy implications were intended to push fees downward.  This regulatory action would be contrary to the federal credit union act to serve the underserved.

In his view, when a person is short on cash, there are no good options.   In many instances, having the payment go through and charged a fee may be best of limited choices.  He gave several personal examples of being in this situation.

In addition to adding to regulatory burdens, he believed the effort was prompted by two  groups not looking out for credit unions’ best interests:

  1. The press looking for clickbait headlines;
  2. Political groups with an agenda.

Board member Otsuka’s response urged that the collection effort’s impact not be prejudged.  Members have a right to know this information. This is about safety and soundness and consumer protection.

The Meeting’s Outcome

This is the first time Vice Chair Hauptman has been so outspoken in response to Chairman Harper’s priorities.  He has loyally supported new rules, spending initiatives, and staff reports that could have been critiqued on both policy and substantive grounds.

While it is not clear why he chose this topic at this time, the response from Chair Harper absent on medical leave was immediate.  He announced the cancellation of the June board meeting.  This is after cancellation of the March meeting and a very “light” April agenda which the Chair attended virtually.

The power of board members comes from their participation at public board meetings and from the political process provided by the three person board oversight.   This legislative change from a single administrator in 1977 was to ensure no single person had total control over the agency.

Now while physically on leave, Harper is trying to retain his political control by canceling normal board functioning.  With a two-person board, both members have to agree on the board’s agenda and concur for any motion to pass. The check and balance still exists.

However  Harper’s cancellation of public board meetings stakes away the most important power and venue board members have.  He is undermining the Board’s oversight responsibilities and other agency priorities.

Leadership Uncertainties

Harper’s efforts to hold onto his authority while absent raises critical questions for credit unions and NCUA.   For credit unions, the reputation and political standing of the Agency is at risk.  Who speaks for NCUA? Who is leading the staff?    Who sets priorities?   With no public meetings, how are the multiple constituencies to which the agency is accountable, supposed to know what is going on?

For NCUA staff, do they respond to queries raised by board members concerning internal and external events-policy and otherwise or just ignore?   Does the newly created Office of Business Ethics or the IG have a role in this exercise of absentee leadership?   The cancellation of board meetings?  The lack of the Chair’s public presence and accountability?

Hauptman may have thought he was just providing an alternate perspective on an Agency data collection effort.  But his critique, and Harper’s response,  raises a whole new set of consequential issues about the board members’ role in a time of Chair vacancy.

In recent years within NCUA and the broader federal government. when there have defaults of leadership (vacancies and personal management failures)  it has been individuals dedicated to their Agency’s mission and the proper exercise of authority that have stepped into the vacuums.  Did Hauptman just start this process for NCUA?

 

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Alternatives to the Credit Union System

The traditional view of market competition is that it is a zero-sum game.  There are winners and losers.  Acquirers and the acquired.  A credit union gains member deposits, or they go somewhere else.

But endgames do not always happen with clear winners and losers going out of business.  Sometimes the losers just limp off the field in irrelevance.

Substitutes slowly absorb earlier organizational efforts with new ones.  In credit unions this evolution is already occurring.  Two updates from these alternatives were recently announced.

The Federal Home Loan Bank System

This week, the members of the Board of Directors and Executive teams from the Federal Home Loan Banks and the Office of Finance are in Washington DC for their annual conference.

For some time, they have been the primary source of liquidity for the credit union system.  Their self-description:

The FHLBanks are 11 regionally based, wholesale suppliers of lendable funds to financial institutions of all sizes and many types, including community banks, credit unions, commercial and savings banks, insurance companies, and community development financial institutions. The FHLBanks are cooperatively owned by member financial institutions in all 50 states and U.S. territories.

The Banks’ regulator the FHFA issued a report last year on their mission and is following up with a request for comments.  The primary issue is how well the Banks are fulfilling their mission of increasing affordable housing options in America.

At the conference, the Council announced the Banks anticipate “a record-breaking $1 billion in support for affordable housing and community development initiatives in 2024. This significant commitment reflects our unwavering dedication to our mission and promoting access to safe, affordable housing.”

The chart below shows the membership of the banks by state at December 31, 2023.  The system serves roughly 6,500 members nationwide with a regional, custom approach from FHLBanks in Atlanta, Boston, Chicago, Cincinnati, Dallas, Des Moines, Indianapolis, New York, Pittsburgh, San Francisco, and Topeka.

Since the 2008/2009 financial crisis, the FHLB cooperatives have effectively replaced the lending functions the CLF and corporates were designed to provide the credit union system.  Corporates still serve critical payment and short-term liquidity roles. However, the FHLBs have taken over almost all term lending.  They do this using a cooperative design.

New Public Banking Legislation

The digital web site Next City has reported on multiple efforts to create publicly owned banks following the model of the North Dakota State Bank.  Here is their latest update:

At Next City, we’ve covered efforts to create city-owned banks in Philadelphia, New York, Los Angeles, San Francisco and the East Bay. We’ve also covered efforts to create state-owned banks in California, Massachusetts and New Mexico. Sometimes, as in the case of New York or California, state legislation has been proposed (and passed in California) to authorize local governments to create their own banks — but none of those efforts have yet reached the point of obtaining a bank charter, accepting deposits and making loans as envisioned.

This month in New York, there’s a new iteration: state legislation that, if passed, would create the Bank of Rochester, a bank that would be controlled by the local governments of Rochester and the encompassing Monroe County. 

Technically, the bank would still need to apply successfully for a bank charter from the state’s Department of Financial Services, just like a private-sector bank, before it could accept deposits. Per the legislation, the bank would serve “the public purposes of achieving cost savings, strengthening local economies, supporting community economic development, and addressing infrastructure and housing needs for localities.”

It would not be a bank that accepts deposits directly from members of the public. As laid out in the bill, the Bank of Rochester would be modeled largely after the century-old state-owned Bank of North Dakota. Nearly 90% of the Bank of North Dakota’s deposits come from the state government, which is required by law to use the Bank of North Dakota as its primary bank.

Similarly, the Bank of Rochester would only be authorized to take deposits from government bodies, including local or state government as well as federal offices. It would be restricted from retail banking and raising deposits from individuals and businesses.  

Change is the Lifeblood of a Market Economy

These evolutions of financial service providers may seem to nibble only at the margins of the credit union system.   However, the relatively recent CDFI option (September 1994) is both a wholesale and consumer response to unmet local borrowing needs for communities throughout the country. Its creation was inspired by Cliff Rosenthal, a credit union and cooperative advocate.  Today some CDFI’s are established financial charters; others are stand-alone lending organizations.

The strategic implications for credit unions remains constant: to differentiate their business and service models by focusing on the members they seek to serve.  When credit unions  look and sound like all other options in a market, members and customers will just look for the best deal, not an owner relationship.

Credit unions have learned the art of tapping member and organizational funds to create large balance sheets.  That same skill and funding attracts fintech startups and encourages multiple efforts at public banking.

Raising funds is just the beginning-how those resources are used thereafter is what matters.  Is it to make a profit or to serve a community? When community needs are not being met, newcomers will find a way to create options for those underserved. That is what the FHLB and the public banking models are trying to do-serve where others have failed to do so.

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Credit Union Mergers: The Final Solution?

(This post was composed by Jim Blaine and reprinted with permission)

      Credit unions are changing…

     … and disappearing.  

Badin Employees Federal Credit Union used to be tucked up against the Uwharrie Mountains on the banks of the Yadkin River, about 40 miles east of Charlotte – the hometown of banking giants Bank of America,Wells Fargo and Truist.

The Uwharries are thought to be the oldest mountains in the U.S. These mountains are well-worn and rounded; the Rockies they ain’t! Uwharrie is an old Indian word. It’s a bit tricky to pronounce, much like La Jolla, Yakima, Albuquerque, and Butte. “Yew-whar-eee” is correct;  “you’re hairy” is not.

https://asset---north-carolina.bldg15.net/img/4/f/4fc74af4-b323-4065-ab53-b09cd8dcf5dc/Stanly%20County%20-%20Morrow%20Mountain%20State%20Park%20Overlook-crop(1,0.636,0.000,0.334,r4).4e964e48.jpg Been searching for years for the original Indian meaning of that name. Recently, a friend told me he knew the origin. He said, it’s in the dictionary: “Uwharrie” means “unknown”. Really? Asked him for a copy of that reference for my files. Sure enough, the following week, in came a copy of the dictionary definition. It said: “Uwharrie – adj., probably from an ancient tribal name; meaning unknown.” Perhaps I just need to pick better friends….

Badin is a company town. In 1917, Alcoa dammed the Yadkin River to generate hydroelectric power for a new aluminum ingot plant. The lake and town which sprang from those efforts are quietly picturesque – but, all things revolved around the plant. Driving into town, down Falls Road, under an unwashed denim sky, is a journey home, a journey back in time The town is just two blocks long, but makes the most of it.
 

https://1.bp.blogspot.com/-K9Q1q_E1eFs/YDv8zTuCAtI/AAAAAAAASQw/nmm1E01Qrkc7SpsLMraBnCI_Ug_1RiicgCLcBGAsYHQ/w1200-h630-p-k-no-nu/IMG_3451.jpg “Downtown” the candy-striped awnings and improvised handicap ramp of Badin Town Hall and Police Department adjoin the Masonic Lodge #637. Then comes the post office with its single window, fleet of post office boxes, and well-used community bulletin board.  Shading the post office is Memorial Park, flanked by a cedar tree honor guard for the seven Badin soldiers who died in World War II. And, out of sight up a short dirt road, is the best named roadhouse on the planet: The Bottom of the Barrel Disco and Cafe; now vacant, having recently burned to the ground.  Bet that last party was a great one. Sorry to have missed it!

But, the center of attraction in town was the Badin Employees Federal Credit Union. The Credit Union was housed in a one story, red brick building with blue shuttered windows and a bright, “no-way-to-miss-it”, burgundy door. The Credit Union always closed for lunch from 12:30 to 1:30 pm, but you could sneak a look into the office through the partially drawn, real-wood Venetian blinds. It was a comfortable, inviting looking place. The kind of place you could sit a while, have a cup of coffee, talk to the manager, y’know think it through a bit.

Badin Employees Federal Credit Union was prosperous with assets reaching $4 million, capital 18%, loans available to all, delinquency negligible. Everyone in town was a member; no local banks remained. Badin Employees FCU had achieved “market dominance” without ever spending a penny on “engagement, member experience, or passions of self-importance”. The “word around town” took care of all that. Yep, folks in Badin had a strong opinion about their Credit Union. They were the kind of folks – as you might suspect – who didn’t need “thought leaders”, “X”, or talk radio in order to form an opinion!

https://i.pinimg.com/736x/41/5b/88/415b88882030af28aaba824deda36369.jpg The beauty of Credit Unions used to be something you couldn’t easily wrap, bottle, or “spin”.   Badin FCU is no longer there to make a difference – gone the way of merger. There are no longer any banks or credit unions in Badin. The aluminum plant, too, is gone.

… are we getting close to the Bottom of the Barrel on a lot of important things in our Country, including credit unions?

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The Strategic Opportunity of a Shred Day

The post card came to us although we are not a members of the credit union.  It announced a “community shred day” at the main office parking lot last Saturday.

From time to time we receive these notices from realtors or sometimes a local government office.  But not a credit union.  It arrived as we were doing some spring house clearing and wanted to dispose of older financial records.  So we dropped a box off, and learned why this may be a simple solution to a perennial business problem.

The Last Mile

The term last mile summarizes the constant business challenge of closing a sale, usually from a distribution or supply chain point of view.  This last leg of the process is often least efficient, comprising up to 53% of the total cost to move goods.  It is the critical final step in retail for a customer to buy goods.

A similar challenge in service industries, such as credit unions, is how do I find my next new customer/member?

The short brief Ten Ways to Get New Customers is summarizes every method used by credit unions.  Todays most likely tactic is for  a strong social media presence with  a defined brand voice across platforms like Instagram, LinkedIn, Facebook and Twitter.

This makes perfect sense. Digital marketing is the preferred way to find digital members. No local presence needed. But why a shred day?  The effort seems so retro?

The Experience

So we pulled into the parking lot of the credit union’s head office.  The branch was closed and the parking area marked by tents with credit union personnel serving breakfast of donuts, coffee along with  credit union literature and tchotchke.  Staff took the boxes, checked for anything other than paper such as plastic binders and filled up big 40-50 gallon containers to wheel over to the shredding truck.

Even though we were late in the three hour period, there was a steady flow of people and boxes so much so, the coffee had ran out.  The following shows the setting.

Why This Makes Sense

How does a community shred day help find the next best customer? Several thoughts.

A person bringing records to be shredded suggests an individual or household conscious about proper management of financial accounts.

Driving to the location where there is a branch, introduces the non-member  to where one of the credit union’s offices is located.  The public made the journey on their own initiative. Local is an advantage almost every credit union can build on versus larger institutions.

The people dropping off records experienced instant hospitality and service.  No charges, no sales pitch. Staff offered  food, gave away branded desk pens and entered person’s names and email into a drawing for four $100 cash giveaways.

And that drawing is the hook.  Here was the message waiting for me when I returned home later on Saturday:

Hi there Chip,

Thanks for chatting with us at our Shred Day! We wanted to follow up and send over some additional information about our organization.

At Lafayette Federal, we offer nationwide membership eligibility with a mission to serve, support and empower you by understanding your financial needs, delivering products and services to achieve your financial goals and offering solutions to assure your financial well-being.

Below are a few offerings that we believe you may benefit from. Please feel free to contact us should you have any questions!

The email cited their 2.02% checking account and a 5.09% certificate for savers as well as other services.

I have no idea how many leads the credit union received.  But I did go to the website. It presents a special focus on members and the community.  I was told the credit union does this once a quarter at different branches as a “community” service.

For me it was the most intriguing introduction to a local credit union in the many years we have lived in Bethesda.  It made many traditional marketing emails from our existing credit unions seem like all the other marketing emails that fill an inbox every day.

This shred day service broke through this communication clutter and got my attention.  Maybe it is not so retro after all.  In its simplicity the effort showcased the traditional credit union advantages of service, local and community.  Hard to do in an email.

 

 

 

 

 

 

 

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Work, Trade, or Finance?

From an unknown source:

An observer of modern social movements has said: “Some men wrest a living from Nature and it is called work. Some men wrest a living from those who wrest a living from Nature and it is called trade. Some men wrest a living from those who wrest a living from those who wrest a living from Nature, and it is called finance.”

And cooperatives?

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The Need for a Level Playing Field

At December 31, 2023, there were 2,280 federal credit unions and 1,724 chartered by 45 different state authorities.

The broad operating authorities are similar.  However, there is one major difference in the transparency of the two systems.  This difference was noted in a NASCUS comment to NCUA on August 15, 2022 on bank conversions and mergers:

All FISCUs must complete annual Internal Revenue Service Form 990 filings. Part VII of those filings is public and requires FISCUs to disclose any compensation paid to directors and officers; the compensation paid to “key employees” (employees earning more than $150,000.00 in reportable compensation; and “highly paid” employees (the top 5 employees earning more than $100,000.00 in reportable compensation).

Transparency and Accountability are Inseparable

Without timely information member-owners cannot make reasonable decisions about the board’s role overseeing CEO and senior staff compensation.

Disclosure is required for all state charters as part of their special status as tax exempt organizations.  Quarterly 5300 call reports provide only general corporate trends and broad dollar totals of some compensation programs.

Transparency of leader’s pay is an essential aspect of the member-owners’ governance role in cooperative design, via the election of directors.  Full disclosure is standard operating practice in the public sector.

The value of reporting is not just the current level of compensation.  Tracking trends over several years can show how pay correlates with the credit union’s financial performance.  Unlike their competitors, there is no daily stock price passing judgement on management’s responsiveness to members or shareholders.

Moreover, the uniform reporting standard of the 990 is specific, by name and position.  It is more useful than generic salary surveys in which asset classifications or by position and other criteria provide only general ranges.

“A Leadership Requirement”

When individuals aspire to positions of senior leadership in the management of other person’s financial resources, their own disclosures demonstrate their responsibility for the trust members have in their credit union.

The time to make this change is now, voluntarily  showing proactive leadership, not after a law or regulation requires this level playing field.

Otherwise, the absence of comparable data may give an impression that senior leaders of federal credit unions are unwilling to be as accountable as their state counterparts.  Which will just beg the question, why?

Change before you have to is a maxim FCU CEO’s  should follow in this basic issue of transparency.  It  communicates basic respect for the member-owners’ role.

Frank Diekmann, CUToday Cooperator-in-Chief,  described the benefits of transparency in a different context this way:

“Not only would disclosure be the right and ethical thing to do, it would make for an effective response to critics. . . that claim credit unions are just “profit-seeking enterprises masquerading as tax-exempt non-profits.

Transparency is a leadership requirement.  It creates trust and confidence even when things go wrong.  Doing the right thing should not require a rule or reg.   It is a character trait. “

 

 

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How Long Have Bankers Opposed Credit Unions?

With the help of a young progressive, attorney Willard King, and several years efforts, the Illinois General Assembly passed the first Illinois Credit Union Act in 1925.

The Act’s purpose was “to safeguard the monetary deposits and other financial instruments of Illinois credit union members” through a system of supervision and regulation.

Bucky Sebastian was the internal counsel for the Illinois Department of Financial Institutions (DFI) from 1977-1981. One DFI responsibility was to charter and supervise the largest number of credit unions of any state system.  At yearend 1977 there were 1,095 Illinois charters, managing $1.8 billion in assets for 1,274,732 members.

Sebastian and King became good friends discussing the legal history of the Illinois credit union system and their shared interest in the life of Abraham Lincoln.

In 1977 the bankers were challenging the Department’s authority to permit share draft (checking) accounts for Illinois state charters.  There were also initial thoughts about how to update the Act to respond to deregulation. King’s knowledge of prior credit union legal changes was very useful in understanding the legislative politics for coops.

One of the stories King told was overcoming the opposition from established commercial and financial interests in 1925 to the new credit union option.  King shared the position of the Chicago Association of Commerce which was: “This is a bill to permit a lot of ordinary people such as blacksmiths and bricklayers to go into the banking business, where they will certainly lose their money.”

To answer how long credit unions have been opposed by banking interests, there is a simple reply: Forever.

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The Ultimate Co-op Strategy to Overcome All Challenges

Worried about new fintech competitors?  Liquidity tight and interest margins narrowing? Hard to find competent, affordable staff?  Growth too slow?  Delinquency rising? CFPB and NCUA about to cap fees-reducing ROA?

There is one surefire solution to all these ill winds every credit union faces.  It is touted and practiced by CEO’s of all  credit union sizes.  Consultants are marketing their multiple processes for implementing this universal solution.

The magic formula is Merger.   And incidentally, if you are not the surviving credit union, the payoff can be even greater than keeping your regular “day job.”

As this siren song travels across the cooperative waves, two skeptics have written critiques.  One humorous and one listing what member-owners should know when asked to vote on this event.  Here are their thoughts on this all encompassing panacea being touted by credit union saviors today.

An Elder Learning Fable

A  story-metaphor  by Ancin Cooley, Principal , Synergy Credit Union Consulting and former OCC examiner.

Grandson Hey, grandma. How are you doing?

Grandma: I’m good, baby. How are you doing?

Grandson: Grandma, I was wondering… I heard you did something with the house?

Grandma: Yeah, baby, I went ahead and let the next-door neighbor merge with my house. Now we are all together in one big house.

Grandson: When did you decide to make that decision?

Grandma: Oh, baby, we decided a couple of days ago.

Grandson: The house had $500,000 in equity, Grandma. You just gave that away?

Grandma: Yup, they didn’t give me any money.

Grandson: What!?!?

Grandma: I got better cable and better air conditioning.

Grandson: Services?!?! Grandmother, with your equity, you could’ve bought cable and air conditioning. You didn’t have to give it all away.

Grandma: I know, but this nice person came over and said we’d just be better together.

Grandma: I’m happy. I can watch Judge Judy as many times as I want now.

Grandson: Who presented you with this idea?

Grandma: It was our property manager. He said the cost of keeping the house maintained was going up.

Grandson: Let me see the contract…. Grandma, the manager got $50k of your equity when you merged. That’s why he brought up the idea.

Grandma: Baby, you are blocking the TV.

What Member-Owners Should Know before Voting in a Merger

CEO  Daryl Empen of Gas and Electric Credit Union (GECU)  in Rock Island, Illinois sent comments motived by multiple merger announcements in the state.

In addition to his CEO longevity, Daryl’s entire leadership team posts their pictures and direct phone numbers on the credit union’s home page under the heading: Meet Your Credit Union.  His thoughts.

I cannot recall a merger in any industry that has led to better member service.  That’s not to say that mergers can’t bring benefits.  But more often than not, it means that consumers lose a voice and a say in things. 

Credit Unions are one of the last 100% member-owned industries.  As a member-owner, you should have a voice in your credit union, and certainly be fully informed about all of the areas below when asked to vote in a merger transaction.

The Minimum Disclosures Member-Owners Should Receive

Credit union mergers have been happening for decades.  Some forced by regulators, some  voluntary. There are a multitude of legitimate reasons.  But as I celebrate 32 years in this industry, it is still sad to see the pace of mergers pick up every year. 

When we lose our small credit unions, we are losing the heart and soul of our movement and the multiple earned legacies that make credit unions special.  No matter the size, credit unions are still member-owned, not-for-profit financial institutions.  But as we grow larger, whether organically or through mergers, members have less of a voice than at most smaller institution.  I fear that we are becoming just another industry, instead of a movement.

Eleven Areas for Disclosure

If I was a member of a credit union being merged into a larger credit union, what questions should I be asking? Merger announcements tend to use generic statements like “economies of scale, synergies, shared philosophy of member service”.  These all may be true, but are  incredibly generic and tell you nothing about specific benefits. 

Based on my experience, as both the President of a credit union, and a member-owner, here are some of those areas I would ask about.

1.Additional services.  Some credit unions cannot afford today’s technology and electronic services.  So this is a legitimate issue.  What makes the surviving credit union’s  version of your products better?

2.Operating expense ratio.  If the larger CU has a higher expense to assets ratio, that’s not a sign of economies of scale.  If the argument is the larger you are, the more efficient you are, then your operating expenses should be lower.   This is not always the case – size doesn’t always equal efficiency. 

3.Personnel. Will employees from the merging credit union be offered employment with the surviving credit union?  What will their new positions and salary be after the merger is completed?

A list of all post-merger promotions with new position and salary should be provided.

Describe the details of any retirements or severance packages because of the merger.

 4.Average Salary Expense.  This is directly tied to average operating expense, as salaries and benefits are usually the largest component of our expenses.  What are the wages of the top management?  Are they reasonable?  All state-chartered credit unions file IRS Form 990 tax return which are public and contains the salaries of the CEO and highest paid employees.  This information is should be included in the merger information, whether state or federal charter.

5.Net Worth.  It  is common that a smaller credit union will have a higher net worth or capital. If  your net worth is significantly higher than the surviving credit union, will a bonus dividend occur before the merger?  If not, why? 

6.Cost of Funds/average dividend per member.  A larger credit union should be able to pay better rates on savings products, especially if they are touting “economies of scale.”   If the larger credit union’s rates are not better, what is the benefit to you as a member?

7.Average Loan Rates.  Again, the surviving credit union should be able to charge lower  rates on their loans with better economies of scale.  If their average loan rates are higher, ask why.   

8.Member Service.  To some members, personal service is not important To others, it is THE most important item.  Does the surviving credit union have a call center?  Use ITMs not personal tellers?  How easy is it to talk with a live person?

9.Costs of the merger.  There are costs involved with any merger – paying out of the remaining terms of vendor contracts can be huge.  Communications and advertising is another cost.    Are there any bonuses or incentives being paid?  How much will the merger cost?

10.Repesentation.  Will you be represented on the new Board of Directors.  Will your credit union have a seat ?

11.The Process.  Who reached out to start the merger discussion?  Did someone research other credit unions to make sure they were finding the best fit?  If they didn’t, why not 

We find it is often the larger credit union that makes an unsolicited proposal, or uses a third party to seek merger partners.  In my 30+ years at GECU, we have never approached another credit union about merging.  They have all approached us first. I always encouraged them to research other credit unions, as they have an obligation to their membership to find the best fit and best value. 

Close

When asked to give up their long serving credit union charter with its multiple legacies of goodwill and accumulated collective wealth, members-owners should be provided specific details as to why they should approve ending their independence.   This is not happening today.  Transparency is critical for trust in a member-owned institution.

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Why the CLF Has No Interest

For over 15 years, the public-private credit union designed liquidity lender, the CLF, has had no activity.  The last major loans were to the NCUSIF for $10 million to pass through to US Central and WesCorp as part of the stabilization efforts when they were conserved by NCUA in 2009.

Liquidity Options

In April 2024 an $800 million credit union reported to the board their return on its two primary liquidity lender relationships as follows:

The FHLB declared and paid a 9.0% quarterly dividend last month.  Our capital stock value there is $1,884,000.

Corporate One FCU declared and paid a 5.75% dividend on all Perpetual Contributed Capital last month.  Our PCC there is $1,283,000. 

In contrast, the CLF reported its first quarter dividend as 4.54% which was down from 4.62% from the prior quarter.  That return is approximately 1% below the overnight rate credit unions are earning on risk free investments.

The CLF’s First Quarter Financials

At March 31, 2024 the CLF’s $895 million balance sheet was composed of $859 million in member shares and deposits and $41 million of retained earnings.  There were no loans.

The CLF’s primary assets are investments in Treasury notes ($819 million) and cash ($95 million).  At yearend the portfolio was $9.0 million underwater.  Why would a liquidity facility  ever invest longer than one year, let alone the $45 million extended beyond five years?

Moreover, the CLF has investment authority similar to FCU’s.  Why is it limiting its portfolio to just Treasury securities-generally the lowest return option in the market?  Does NCUA lack the investment expertise from staff who routinely evaluate the soundness of credit union portfolios?

The below market quarterly dividend means every credit union member is subsidizing the CLF.   The dividend decline is even more puzzling when the CLF reports adding $869,000 to retained earnings which now total over $41.1 million.

The CLF has no risk and no loans so why shouldn’t all net income be paid to its shareholders?  In the same quarter of 2023, for example, the CLF added only $3,000 electing to send all net income to shareholders.

A Vestigial Organ

The numbers show that the CLF has played no role in a year which saw record credit union borrowings and liquidity pressures from rising rates and banking failures.  CLF investments report below market returns. The dividends paid are not competitive.  That fact alone shows how detached CLF and NCUA leaders are from managing a facility that would actually serve the members who loyally fund it.

Contrary to NCUA board members’ entreaties for new Congressional legislation, the lack of credit union support for the CLF is not a statutory shortcoming. It is a management one.

Over decades the CLF has evolved to become a regulatory vestigial organ serving no purpose. As shown above, credit unions have liquidity options which they also own and which provide real value.

Isn’t it time the CLF decided to do the same?  Or at a minimum pay a competitive dividend before shareholders decide there is no reason to continue “bankrolling” a moribund facility.