Category: Co-ops in Capitalism

Posted on

  Whose Voices Should Shape SECU’s Future (Part III)

The author of a lengthy Business Journal article on SECU’s competing future visions wrote a brief follow up to his original story that began:

The North Carolina State Employees’ Credit Union is such an integral part of our state that it’s often taken for granted.

There’s nothing like it across the nation, I learned, while studying the $53 billion dollar enterprise for a story in the February Business North Carolina. In the ninth-most populous state, SECU dwarfs peers nationally other than the national Navy Federal Credit Union. . .SECU is a maverick.

When viewed in a broader context, this local controversy is more than competing approaches to a business model.

In many large credit unions today there is a growing distance between member priorities and institutional ambitions.  A number of credit union leaders aspire to an ever-expanding role in the financial services marketplace.  Organic growth is insufficient, too slow.  Executive strategies such as whole bank purchase and aggressive courting of merger partners everywhere are embraced, two initiatives often enabled by external sources of capital.

Members become merely the means to further institutional prominence.   The rhetoric continues about serving members, but often these expansion efforts  offer little or no member benefit.

There is a parallel example in current religious practice.  Some well-known and successful preachers promote faith with a vision of what is called the “prosperity gospel.”  It is little more than capitalism in ecclesiastical garments.   The equivalent happening in credit unions is full out banking strategies dressed in cooperative clothing.

There is a spreading “cooperative anemia” circulating in the credit union system.  Its basic symptom is the separation of institutional priorities from members well-being.

A Model that Transcends

The SECU which Jim Hayes joined as a leader in 2021 had been able to transcend these constant temptations to alter cooperative design into a proto-banking model.   Instead it became increasingly viewed as a “maverick” by credit unions.

The persons who invested most of their professional lives building this contrarian approach developed a certain stubbornness.  They both authored the effort and produced unprecedented results.  They continue to have a sense of stewardship, even as they become “just a member. “ As one writer has observed  “some of the best founders are difficult people.”

When institutional leadership is transferred to managers in today’s selfie world, there is an understandable perception that “me” is being put in front of membership.

A Path Forward: Investing in Members’ Ownership Responsibilities

Leadership of any institution is first and foremost a political task, not a business model problem. The concerns about changes in business direction, labelled “rumbles” by SECU staffer, have now morphed into public and opposing camps.

One side is represented by a person who self describes as “often wrong, but never in doubt.”  The other camp has retreated to their bunkers of incumbency, and adopted a tactic I call “brute legalism.”  This means “we’re in charge (with member approval), so we don’t have to accommodate contrary points of view.”

The coop process for resolving this debate is supposed to be democratic. An autocratic rejection of member concerns, may lead to increasing displays of public opposition.  It certainly makes CEO Jim Hayes’ leadership much harder.

If the separation of credit unions and member priorities is the core of the problem, then embracing the owners’ democratic engagement may be the solution.

Cooperative democracy is more than electing directors at the annual meeting.  Often this voting function has been reduced to an administrative formality as nominations by the incumbents just match the number of open seats.

Democracy depends on choice.  Real choice is more than putting more names on the ballot.  It requires continuous transparency, open communication, and ongoing dialogue with every internal and external level of the organization. This habit is more than press releases or marketing messages.

Cooperative democratic design is more than good governance, that is accountability to the owners. It is how trust and confidence in the leaders’ decisions are created.

The motions at the 85th Annual meeting were unusual but a proper exercise of member-owner rights. It has opened up conversations about decisions that have major member impact but little visibility.

Blaine’s motions were an act of courage and member duty.  He took the step of “walking to the front of the line” to find out who might be with him.  There is no more democratic act than members speaking out.

A Democratic Ampersand

Cooperative design is at its strongest when an ampersand is added to the member & owner role.  Otherwise the owners end up as being viewed as just customers.  Keep them satisfied, find more like them, and allow the “elected” leaders to shape the credit union’s future.

Many credit union managers believe they choose their members, especially encouraged by the regulatory concept of the common bond.  Nothing could be further from the truth.  It is the members who choose to join, support, or leave the coop.

In the American economy, it is called “consumer sovereignty.”

Member loyalty cannot be acquired in a merger or bank purchase.  That just cheapens any relationship.  Rather it is hard earned over generations.  When well done, the result creates the most important business and political advantage a movement could want.

A Public Purpose

Coop democracy is more than a process for accountability and acknowledging the owners’ roles.   It is core to credit union’s purpose.   That purpose is extending economic opportunity for all Americans, especially those at the mercy of for-profit providers.

Economic equality is vital to the continuation of the capitalist system. It is critical that all striving for financial security ( especially those living paycheck to paycheck) can have an institutional option that is fair and just, not discriminatory, in their transactions.

SECU’s board and leadership are in a unique moment for affirming the credit union’s continued commitment to furthering America’s promise of economic justice. This credit union will be fair to all who join SECU as members-owners.

Achieving that outcome will require more conversations and crafting additional business  options.  Without this effort member uncertainty and market forces will slowly erode the credit union’s position in its key markets and nationally.

A lesson from events to date is that sometimes it takes heading in the wrong direction in order to find the right one. Now is the time for SECU to make real the promises of coop democracy–in multiple ways.

No one has a monopoly on insight.  Being a maverick is tougher than jumping into the financial mainstream. Old and new members sitting down together offers a better chance of SECU sustaining its transcendent credit union performance.

As Robert Frost might counsel in the final verse of The Road Not Taken:

I shall be telling this with a sigh

Somewhere ages and ages hence:

Two roads diverged in a wood, and I—

I took the one less traveled by,

And that has made all the difference

Posted on

Differing Outlooks for SECU’s Future (Part II)

At the October 11, 2022 members’ Annual Meeting, SECU CEO Jim Hayes had been in his role since  August 2021. He arrived with 25 years of  senior credit union  and NCUA leadership experience.  He succeeded Mike Lord who in turn took over from  Jim Blaine in 2016.

All the persons involved were obviously  aware of Hayes’ “outsider” status. The hiring decision must have reflected a desire for a fresh look, and/or strategic change.

Here’s how SECU’s chief culture officer, Emma Hayes, explained the board’s choice in a talk to the AACUC conference in September 2022 in a CUToday report:

“We hired someone not only from outside the organization—there had never been for 85 years an external hire for CEO—but also someone who came from the wrong coast (the former Wescorp in San Dimas, Calif.) by way of somewhere up north (Andrews FCU in Maryland) to come down to North Carolina to lead the second-largest credit union,” explained Hayes, drawing laughs from the audience.  “The strategy for SECU for 85 years had been to grow talent from within. They had done that and done it well. Now they decided to open the organization and take a peek and see if there is someone out there.

‘Never Been Heard of Before’

“SECU runs like a well-oiled machine,” she continued. “But (Hayes) had new ideas for how to do things. One of the first things he did was send an email to all staff. In 85 years, no one who sat in that seat ever sent an all-staff email. In that email he says, ‘Let’s get rid of our ties.’ Imagine the shock and awe! Nobody believed this was real, like someone had hacked into his email address. We don’t take off our ties. We sleep in them. We go to the gym in them. It was unheard of! But Jim was like, ‘Let’s do something a little different.’ He then said, ‘I’d love to hear from you. Send me an email.’ People stared emailing him and he responded back. With his own hands he typed out messages! This also had never been heard of before!”

Shaking Things Up

The result, said Hayes, was word began to spread in the state of North Carolina where SECU is a highly visible and well-known brand that the new CEO was “shaking things up.”. . She said the changes created a “little rumble” within the organization and community.”

Those little rumbles culminated in the two resolutions , described yesterday, that members approved in the October 2022 Annual meeting

The 20 Credit Union Paladins (not a video game)

As of December 2022, twenty credit unions reported assets over $10 billion.  This threshold  subjects them to the scrutiny of the CFPB, reduces their debit card interchange, and includes special oversight by NCUA.

These twenty manage 23% of the industry’s assets, 24% of its loans and serve 23% of credit unions’ total reported 137 million members.  But they are just .4%  of all 4,495 credit union charters.

Their roles in the movement make them objects of emulation.  They are also, at times, examples of unveiled ambition.  Overseeing billions can sometimes lead to feelings of “cooperative triumphalism” and unlimited  growth aspirations.

Their business models vary widely.  Several have bought banks, sometimes more than one. Others have programs to acquired other credit unions across the country. Some have defined FOM’s; others say anyone can join.

Operating expense ratios vary widely:  Star One reported a 1.11% and Alaska USA 3.67% for 2022.  SECU’s was 2.16%.

SECU’s Rare Accomplishment

There are as many models in this group. However another factor distinguishes SECU’s performance.

There are state employee field of membership credit unions in almost every state.  These  charters share the same member economic profile of stable employment and a range of member demographics.  The motivations of state and local employees closely align with the not-for-profit service culture of credit unions.

But only SECU, the second largest credit union, achieved the market dominance serving this common employment group.

How Did SECU Become So Consequential?

SECU combined a unique strategy and culture which for some observers claim  is grounded in the 20th century.  It developed over decades.  The elements were highly  integrated and carefully chosen. Among the factors were these:

  • A limited North Carolina operational FOM with a branch in every county, and a statewide ATM network.
  • Branches were assigned local responsibility and accountability: for example, loan originations and collection, advisory boards for visibility in the community, local employment and personal service including routing member calls to their local branch;
  • A product and service profile that serves each member equally: same loan rate for all members (no tiered savings, no risk based pricing or indirect auto loans);
  • Staff receives only salaries, with no commissions or incentives for performance. Promote as much as possible from within.
  • Be low cost with a simple financial model: 3% net interest margin, 2% operating expense ratio and 1% ROA.  Minimize member fees.  No paid advertising.  Rely on word of mouth and the earned publicity from SECU’s Foundation grants.
  • Mortgage loans are the primary means for members to build financial security. 80% of SECU loans are first mortgages or real estate secured.
  • Provide a complete menu of low cost financial services beyond traditional consumer banking products. These include life insurance, a broker dealer for access to no load mutual funds at Vanguard, a 529 program open to all state residents, tax preparation,  trust services and even a CUSO for housing rehabilitation.
  • Avoid mergers; instead provide help to smaller or struggling credit unions.

The result was a no frills, plain vanilla product selection (no rewards cards) and long term member loyalty.  The focus was intentional—serve those demographic segments that have limited  financial choices. More simply, those that know the least or have the least.   Well to do members might find better loan or savings terms elsewhere.

By design SECU avoided imitating other financial providers.  Its purpose was to create a unique cooperative alternative for middle and low income Americans.  They wanted to avoid a strategy of becoming the competition to beat the competition.

The Issues Raised in the Annual Meeting

The six topics or business questions presented as the basis for the resolutions.

  1. SECU’s efforts to achieve an open field of membership.
  2. Merger discussions with Local Government Employees FCU, that would end a 40 year business partnership.
  3. Introducing risk-based lending for loans.
  4. Expanding business/ commercial lending.
  5. Elimination of the $75 per member tax preparation service.
  6. Regional expansion beyond North Carolina.

The full description of each topic is in the presentation. Blaine subsequently set up a web site blog which continues to expound on these points in almost daily posts.

Since the meeting, SECU has continued the ongoing implementation of the topics mentioned.

The tax preparation service has been discontinued.  Changes in loan administration are on going shifting responsibilities from branch to more centralized oversight. The volunteer, non-employee credit review committee is no more.

Recently Local Government FCU announced its decision to go on its own and dissolve their partnership with SECU.

The credit union continues its technology overhaul with a priority on digital services.

The issue dominating subsequent Blaine communications to the board is risk based lending. These multiple messages cite a number of studies showing the disparate impact of FICO score based loan pricing.

The credit union conducted a series of dialogues with staff and advisory board members.

 SECU’s December 2022 VisionPlan

Early in 2023 the credit union posted its  Strategic Plan, “Leading with Care” fulfilling the second resolution’s request.  It is 15 pages with four goal areas and key success factors.  The goals are generic, like many plans, and primarily descriptive.

It is well written.  Almost academic in structure. There is nothing controversial.  Many current public themes are included such as environmental awareness, DEIB, affordable housing and investing in staff.

If it had been available at the 2022 Annual Meeting, the presentations of the Chair and CEO would have been much enhanced.

The plan could be a prototype for almost any billion dollar credit union. There is no market analysis or history of prior trends.  No future financial projections were included.

The document has one statement referencing current events: Our commitment to embracing different perspectives creates the positive tension required to weigh business decisions and their potential outcomes.

It omits SECU’s traditional vision statement:  Send Us Your Moma.  And its former mission: Do the Right Thing.  It largely ignores  the policy issues raised in the Annual meeting such as a broader FOM and relationships with fellow credit unions.

The Plan presents settled decisions, such as  the ongoing implementation of RBL, without any explanation of how this benefits members.

An Earnestness of Views

How do these different judgments about business strategy get resolved– Blaine’s dominating logical critiques versus incumbents’ asserting the power of position.

Continued public debate will cause cleavages in the 7,800 employees, and among  advisory board volunteers,  directors, and ultimately members. The credit union’s financial and market momentum could falter.

The internal dynamics of SECU’s decisions are unknown. Had the board a plan ready and then tell Hayes to move quickly? Or did he understand his remit as move fast and address priorities as he assessed them?  Whatever the circumstances, did it consider the “wisdom of elders” as the plan was developed?

Or, is the fundamental difference in approach elsewhere? The new Plan states: “As a financial cooperative, we take to heart that prudent stewardship of our member’s money is of utmost priority.”   Is that all a financial cooperative is about?

Can a solution or process accommodate both points of view?   That’s the subject of tomorrow’s post.

 

 

 

 

 

Posted on

Democratic Disruption at SECU’s 85th Annual Meeting

SECU’s October 11, 2022 annual meeting was a rare example of democratic cooperative governance.

Following the traditional annual meeting agenda, approval of minutes, the Chair’s report, election of directors, audit summary and President/CEO Jim Hayes’ update,  the Chair asked if there was any new business.

There was.

A member-owner presentation proposed two resolutions for the members to discuss and vote upon.

The first asked the Board to consult with staff and advisory board members to learn how six  changes he described would benefit the member-owners.  The dialogues should  be published for all members.

The second requested the board provide members SECU’s Strategic Plan at least 90 days prior to the 2023 Annual Meeting.

The chair asked  for comments.  One volunteer advisory board member said he had heard nothing about the topics raised.   A second member commented that he didn’t want the credit union “to become a Piedmont Airline.”  (merged out of business).  A current director spoke up supporting the second motion.

Both resolutions were approved by the approximately 1,000 members, with virtually no opposition.

The meeting was broadcast live on YouTube.  Here are the timing of key events: 29:50 Chair report; 54: Foundation update; 1:05 CEO Hayes report; 1:21 Call for new business with two resolutions at 1:48 with open discussion and member vote.

Should Credit Unions Care about SECU’s Debate of its future?

SECU at $51 billion is America’s second largest credit union. Its membership covers an estimated 25% of North Carolina’s population.

This event was covered in  a lengthy NC Business article and  in the North Carolina’s Banking Association’s weekly update.

SECU’s success and size extends far beyond its members or its home state.  It’s a model others study. It has an outsized influence in both state and national credit union organizations.

SECU’s leaders’ duties are more than managing a business.  The credit union has a position of influence and power beyond its balance sheet.  Its actions will be viewed by outsiders, the public and competitors, as an example of what a credit union is capable of becoming.

SECU’s reputation and widespread operating network means its choices are followed  by many in the cooperative movement as an example of credit union competence.

Blaming the Messenger

As events unfold, many observers will have opinions. Some, I believe,  will reflect  a capacity for missing the point. It will be framed as a conflict between a current and a former CEO as in the following LinkedIn comment:

As I read this article, I was saddened that a CEO who has retired and handed off the reins goes public when the new leadership makes strategic moves, and the retired CEO disagrees. This willingness to fight the new leadership’s right to make strategic decisions is wrong on too many levels.

This happened recently at SECU when Jim Blaine disrupted the annual meeting with a lengthy letter he read in totality because he was against the strategic direction the new leadership was taking the credit union. CEOs need to realize that when they step away, it is now someone else’s turn to lead forward. #ceo #leadership #retired

This is a position with which many CEO’s would sympathize. It absolves commenters from examining the issues raised.   But I believe this position is far too shallow.  Here’s why.

Very few member-owners would be capable of preparing the in-depth analysis of this presentation. But this was not a solo effort. In his opening Blaine comments there had been widespread concern from both employees and members about SECU’s apparent changes of direction and culture.

When individuals working in or interacting with an organization believe it to be going “off course” counsel will be sought from former leaders.   In the corporate world  this approach is shown by examples such as Disney, Starbucks and Apple where there were call outs to prior leaders.

When credit union members and employees are deeply concerned about  an event such as the mergers of Cornerstone FCU in Carlisle PA or Vermont State Employees, they reach out to former leaders. What do you think?  Will you help?

Former leaders are not one-person shows.  They understand the politics of leadership.  Any public role is carefully considered.

They become the messenger and therefore the face for larger issues.  Their previous roles give credibility to the concerns whereas an individual employee, member, director, vendor or credit union collaborator would not have the standing to raise.

Raising questions about  a strategic pivot in a “courteous and respectful manner” at the owners’ annual meeting is a vital process for cooperative governance.

An Example of Coop Democracy

This required annual meeting is a critical process for democratic cooperative governance.  It is the opportunity for the board (chair) and CEO to inform members where the credit union is heading, the reasons for change, and how it will affect them.

After outlining six new policy or business initiatives, Blaine closed with two summary questions: Who are we? Where are you leading us? 

Those are questions every CEO and board should be willing to answer for their member-owners.

Tomorrow I will summarize the issues raised, the credit union’s responses, and how SECU aligns with the nineteen other credit unions over $10 billion in assets.

 

 

 

 

Posted on

Stories That Made Us

The stories we tell, define who we are.   They preserve those moments in life that we value.  For organizations they communicate the culture.  For a country, they express its collective national aspirations.

Two of the brief stories below are from CEO Tim Mislanky’s monthly staff update for Wright-Patt Credit Union.  They honor the credit union’s commitment to service, its foundational value.

The third is an account of a father’s efforts to respond to segregation  an ever present legacy in their community.

These accounts are not mere history.  Rather they give meaning to life today. As you read, ask what story might you tell about your efforts?

A Greyhound Bus Trip to the Credit Union

A WPCU member, who is also ex-military, took a Greyhound bus from Cleveland to Columbus for a close reopen account. She is advanced in years so she could not do it online. She arrived at Graceland at 5pm and we had appointments till close at 5:00 PM.  Stacy Davison was the only financial coach for the remaining workday. Stacie gladly stayed to be sure that our member was taken care of.

Through the close reopen process,  Stacie found out that our member came all the way from Cleveland via the bus and hoped to get a bus back to Cleveland that same night. Stacie got online to try and help our member find a bus schedule to Cleveland, but there were no buses available until the next day.

Our member was then going to take a public transportation to a homeless shelter to stay the night. She had brought her dinner and breakfast with her to be prepared if she had to stay overnight.

It was dark and unsafe for our member, so Stacie told the member she would take her to the shelter. Stacie looked online to see if the Holiday Inn had a room, so she could pay for our member to stay the night in comfort, they did not, and the member would not let her do that. Stacie offered to drive her back to Cleveland, but the member declined.

On the way to the shelter Stacie tried to buy her a hot dinner, but the member said “I will eat what I brought from home.” The member said the shelter served dinner, so she could eat there also.

Manager’s comment: This is an example of going above and beyond for our member and, a great example of a servant’s heart.

One Hot Dog Per Day

Heidi recently worked with a member who shared personal details with her about how she was having financial difficulties and surviving on eating one hot dog per day. The member was having extreme difficulty being able to afford food in her home. Heidi went into action and found information about area food banks that she shared with the member.

A week or two later, the member returned to the member center. She told Heidi (while crying) that Heidi gathering those resources and sharing them with her was “life changing.” The member said that she was able to contact two food banks, and that both were able to provide food to her. She also shared with Heidi that she has now also secured a temporary part time job.

Manager’s Note: Because of Heidi’s work, we are developing a guide about food banks and area resources that can be shared with members.

Picking Up the Minister’s Food Tray

A family story prompted by yesterday’s post about Springfield, Illinois and integration in the 1960’s.

My father, editor of the afternoon daily in a small city in the mid-Ohio Valley (population about 40,000), was about the same time fighting an uphill battle to change the status quo there. He spoke out a lot in his editorials and made himself unpopular with a certain type of citizen.

Sometimes the telephone would ring during dinner and my father would slip away and answer. “Who was it this time?” my mother would ask. “Oh, just another one of my sidewalk editors,” he’d say. But actually, some of them were calling to threaten him—and us. He didn’t stop promoting integration in schools and businesses and elsewhere. 

As a ruling elder in the First Presbyterian Church he was hastily summoned to the church narthex one hot and un-air-conditioned summer morning where he weighed in successfully in an off-the-cuff decision to let a neatly hatted and gloved black woman stay for the church service.  

A visitor from Texas, she had just come in and sat down in a pew causing a flurry of concern especially with another ruling elder who came to my father and said: “What shall we do?”  No black person was thought to have darkened the church door before. There were supposedly only about 50 black families in the city and they had their own churches. Thankfully, nothing happened to the visitor and she worshipped unbothered along with the rest of us. But that kind of acceptance only went so far. 

I remember well my father’s repeated consternation about a popular downtown cafeteria where the local Brotherhood Committee met regularly to plan interfaith events designed to promote tolerance and understanding.  The Rev. Preston Smith, a loved and respected pastor of one of the local black churches was the only person of color on this committee that included a representative of the tiny Jewish community and Father O’Reilly of St. Xavier’s downtown catholic church.

Everyone except Rev. Smith went through the line and got his food, but someone else had to fill a tray for him and take it to the back room where the meeting was held. My father finally challenged the cafeteria’s owner: “Bill, why won’t you serve Preston just like the rest of us?” 

 “I’d like to. I really would, but I just can’t. It would ruin my business; people wouldn’t come. I’d lose everything.”  

Some years later, the cafeteria closed for other reasons. I still have a brass plaque of the Brotherhood Award from 1968  engraved to my father for “Distinguished Service in Human Relations” presented by the local chapter of the National Council of Christians and Jews.

 

 

Posted on

Credit Unions & Risk Based Capital (RBC): A Preliminary Analysis

From the June 30, 2022 call reports, NCUA reported:

  • 399 CUs opted into the Complex Credit Union Leverage Ratio (CCULR) framework with an average CCULR of 11.35%, or 26% higher than the 9% floor.
  • 304 CUs reported under the Risk-Based Capital (RBC) framework with an average RBC ratio of 15.39%, or 54% higher than the 10% minimum.

The 500 page, RBC rule and its almost 100 ratio calculations became effective January 1, 2022.  Just two weeks after NCUA board approval.

It was intended to provide greater insight about a credit union’s risk profile and capital adequacy. What can an analysis of the RBC adopters tell us from this initial implementation?

The Macro Totals

The 304 credit unions plus 4 ASI-insured who adopted RBC, manage $822.7 billion in assets.  But the risk weighted assets total only $479 billion.  That 58% ratio  is the NCUA’s discounting of total assets total by assigning relative risk weights.  For example some assets have zero “weight” (cash, treasuries) or negligible emphasis ( GSE’s 20%).

Compared to the traditional well-capitalized 7% of assets standard, this group holds $20.5 billion in excess capital above this ratio.

Using the minimum RBC ratio of 10%, this same group holds $26 billion in excess of the minimum.  As shown above, their average RBC is 15.4%.

The bottom line is that this group of credit unions is well capitalized whether using the 7% traditional level or the new RBC 10%.

Other Initial Findings

One intriguing fact is that 149 of these credit unions, or almost half, have traditional net worth exceeding 9%.  That  suggests most could opt out of the RBC calculations as they exceed the CCULR 9% compliance minimum.

For example, one credit union with assets between five and ten billion dollars, reports standard net worth of 12.5% and an RBC ratio of 48.3%.   Why did they report RBC versus CCULR?

One way CEO’s can use RBC is to show that even with a low traditional net worth  they are still more than well-capitalized.  A CEO holding 7.5% net worth may want to allocate future earnings for greater member value and avoid the 2% tax on net income  to maintain the 9% CCULR minimum.  Showing a high RBC to your board and members is a powerful defense of the lower traditional net worth measure.

A Look at Ratio Methodologies

However as shown by the banking example below, RBC captures very few risk factors. Its focus is solely on potential credit and/or principal losses on loans and investments.

One example: 250 of these 308 credit unions reported unrealized declines in the market value of investments that exceeded 25% of net worth.   Four credit unions reported a decline greater than 50% of capital.  This was before the five additional Federal Reserve’s  rate increases through the end of the year.  This situation is not recognized in RBC.

To compare peers and their capital performance is very confusing.  RBC credit unions can choose four different ways of calculating the ratio’s denominator.   Seventy two credit unions opted for a ratio  that did not use June quarter ending assets.  They chose one of three other options that  results in a lower total asset amount, and therefore a higher RBC outcome.

RBC ratio comparisons are further complicated when 152 of the RBC credit unions had a combined risk weighting of less than 60% of total assets.  In one case the risk weighted assets were just 24% of the total balance sheet.

Another difficulty in  comparisons is that there are other options for capital creation than retained earnings.  Seventy-six credit unions report that less than 95% of their “capital” came from their own earnings.  Twenty-four reported subordinated debt as capital and the majority of the remaining group were from equity acquired in a merger.

As a result RBC net worth ratios  reflect different capital strategies.  There is a difference in operating capabilities between institutions who rely solely on retained earnings and those who purchase capital.

Performance Outliers

The RBC spread sheet easily identifies those near the 7% minimum requirement-one is below 7% and 12 between 7 and 7.5%.

Using the 10% minimum RBC net worth, eight credit unions fall below this ratio and 15 have 10.5% or lower, and are close to the minimum.

These screens would be one way of assigning exam priorities.

Initial Observations About RBC

From both the macro numbers and the micro analysis, RBC does very little to inform about safety and soundness.

  1. The calculation is a backward looking indicator of soundness. It is at a point in time and includes no dynamic ratios.
  2. Comparisons of peer capital adequacy using ratio analysis is virtually meaningless because of the range of calculations possible and distribution of risk weighted assets.
  3. No current, critical performance indicators are included. No delinquency, no expense ratios, no liquidity indicators, no IRR or ALM measures, and certainly no growth factors of any kind.

Ironically, is it possible that a very high RBC ratio indicates very poor value creation for members? The very opposite outcome for a credit union to sustain success?   Are the 33 credit unions with RBCs in the 20%, 30% and 40% ranges really serving members as their below average  loan/share ratios leads to higher reported RBC?

A Preliminary Look

The above analysis is as of June 30, 2022.  I will revisit the RBC reporting credit unions at December 2022  to see if the numbers have significantly changed.  For example, how many of  the 148 above 9% net worth opt for CCULR?  Credit unions will then have a full year’s and four quarters experience exploring the pros and cons of using RBC.

At this preliminary analysis, RBC looks like an exercise for credit unions to select their most favorable capital presentation. It may even create perverse regulatory incentives  that undercut initiatives for enhanced member value.

A Case Study of RBC and Bank Reporting

The following is an excerpt of RBC analysis of a bank serving the crypto industry and its reported capital adequacy.  This was written by Todd Baker, 1stSenior Fellow, Richman Center at Columbia University. (#capital #regulation)

Silvergate Bank has officially reported, and there is a big lesson there for regulators about the failure of risk-based capital standards to adequately address the risks of #banks serving the #cryptotrading gambling emulation of finance.

The wisdom of hard equity leverage capital requirements for banks is clearly demonstrated. They lost a billion dollars and their risk-based capital ratios increased! . .

Again, kudos to whomever managed the process of securities sales, reclassifications, borrowings, etc. at Silvergate. He/she did an amazing job bringing the plane onto the landing strip with one engine in flames and half the tail falling off while keeping the Tier 1 leverage ratio over the 5% “minimum” (which is actually way below the minimum in practice). . .But they still have the need to raise new capital, and fast, because their Tier 1 leverage ratio is way, way too low for the inherent risk from the business, as everyone now knows.

Despite losing a billion dollars (likely more than the company made cumulatively in it’s entire history) in the quarter, driving its holdco ratio of common equity to total assets down to 3.61%, from 8.84% at the end of 2021, and immolating half of the bank’s Tier 1 leverage capital, the bank’s risk-based capital ratios are actually higher (!) than they were at the end of the prior year.

 

Why? Most of Silvergate’s assets were and are still government securities that are treated as riskless (0% risk weighting) or GSE securites that carry a 20% risk-weighting. Riskless, that is, until you have to sell them in a rising rate environment…

Compare these two disclosures, from year-end 2022 and 2021:

“At December 31, 2022, the Bank had a tier 1 leverage ratio of 5.12%, common equity tier 1 capital ratio of 53.89%, tier 1 risk-based capital ratio of 53.89% and total risk-based capital ratio of 54.07%. These capital ratios each exceeded the “well capitalized” standards defined by federal banking regulations of 5.00% for tier 1 leverage ratio, 6.5% for common equity tier 1 capital ratio, 8.00% for tier 1 risk-based capital ratio and 10.00% for total risk-based capital ratio.” Versus,

“At December 31, 2021, the Bank had a tier 1 leverage ratio of 10.49%, common equity tier 1 capital ratio of 52.49%, tier 1 risk-based capital ratio of 52.49% and total risk-based capital ratio of 52.75%.”

 

 

 

 

 

Posted on

Digital and Branching Options

As credit unions expand their market footprint, branches remain an important investment for growth.

Recently Credit Union Times reported on this effort by five credit unions across the country. Expanding their existing 75 branch network was Suncoast Schools, Tampa FL which is opening  three new branches in Orlando.  Truliant, Winston Salem, NC is investing in a South Carolina expansion involving five new offices in three years.

The Times story also described new branch openings by Blue FCU, Cheyenne, WY; Utah Community in Provo; and Brooklyn Cooperative FCU in New York.

In Person Matters

If digital transactions and virtual platforms are the future of financial services, why are these and other credit unions continuing to invest in real estate and a physical presence?

Part of the answer is that opening new markets is very difficult to do with a virtual only strategy.  Platform solutions bring individual responses to promotions.  However “seeing is believing” if credit unions want to have a continuing community presence and impact.

However another factor may be the reality that Stores Aren’t Dead, according to a February 10 article in Axios.

According to data from Coresight, “physical store openings exceeded closings on an annual basis in 2022 for the first time since 2016.”   Retailers are on a pace to open more stores at an even faster pace in 2023.

Why?   “While e-commerce platforms helped retailers manage the pandemic — but both retailers and consumers realized the limitations of doing business entirely online.”

Bargain hunters like to shop in person.  The top six retailers opening stores in 2022 were dollar chains and discounters, including Dollar General, Family Dollar, Dollar Tree, Five Below, TJX Cos. and Aldi, in that order.

Those customers would seem an attractive demographic for credit union services as well.

Digital transactions for existing members are an important option for supporting these members efficiently.  But a physical presence is what communicates commitment to a community.  And being there for an ongoing relationship.

Posted on

NCUA Board’s January Review of the 18% Usury Celling-A Shakespearian Event

Open board meetings are the public’s opportunity to see members officially at work.  Current practice is that all statements, questions, and staff answers are fully scripted in advance.

Even so these presentations demonstrate members’ grasp of issues, their knowledge of credit union operations and their view of cooperative’s role.

The one January topic with immediate effect was reviewing the 18% usury cap on  all FCU loan rates-except for PALS short term advances.

The Missing ALM Context

Setting loan and savings rates is an everyday event for credit unions.

The most important aspect of loan pricing is its ALM context.  The goal is to manage the net interest margin, the key factor in bottom line net income. That’s how credit unions “make their living.”

That fundamental ALM context was never introduced by either staff or board members.

As of September 30, the net interest margin for all credit unions was 2.79% up 20 basis points from the year earlier.   The average cost of funds to assets was 42 basis points.   As an approximation, a loan priced at 18% would have a spread of 17% over the average cost of funds.  Subtracting an average operating expense of 3%, would leave a net margin of 14%.

Loans are the fastest growing component of the credit unions’ collective balance sheet.  The year over year increase was 19% as of September 2022–the highest rate in decades.

There is scant evidence that the 18% is limiting credit union lending options or earnings.

The Board’s Discussion

Chairman Harper reported all three members had different positions on the ceiling.  He supported the 18%. The agency had obtained a letter from Treasury which concluded: As a result, we believe that presently there are not compelling reasons to change the current 18 percent loan rate ceiling for federal credit unions. 

This was the first time Treasury had ever commented on the topic.  Even more concerning was their offer to an “independent” agency:  Treasury is available to consult on any future consideration of the interest rate ceiling.  

Harper said he was willing to review the topic again in April along with the possibility of a floating rate cap.

The other two board members made no reference to the ALM context or operating margins.  Their intent seemed to find a way to give credit unions more leeway.

Both advanced an interesting economic theory: charging more for loans will actually increase demand.  To better serve members who pay high loan rates elsewhere, credit unions must charge higher rates themselves.  The cure for high member loan rates, is higher rates!

This view certainly supports the market’s practice that those who have the least or know the least, pay the most for financial services.

In the words of Vice Chair Hauptman:  Low-income and CDFI credit unions depend upon the ‘head room,’ the ceiling provides above the statutory rate of 15 percent. . . to serve their neediest members.

He then showed a bizarre slide of a personal example of the late fee assessed by a governmental authority when a required payment was not made on time. His apparent point was governmental authorities charge different late penalties which he equated to usury ceilings on loans.  He asked for further research and review of the issue in April.

Hood acknowledged: when you talk about the interest rate ceiling, we really need to think about how this impacts members. He gave several anecdotes such as:

One credit union told me that their concern is that if the NCUA maintains the interest ceiling at 18 percent, as rates continue to rise, they would have to deny potential credit card applications unless the credit union member had an excellent credit score.

NCUA staff seemed to embrace this view that higher rates are the only antidote for higher risk.

The reversion to a 15 percent interest rate ceiling would constrain an FCU’s ability to apply risk-based pricing to higher risk credits and reduce net interest margins in the current rising rate environment. In particular, a reduction in the interest rate ceiling would adversely affect a relatively large number of low-income designated FCUs (LIFCUs) and their members’ access to credit.

Much Ado About Nothing

Since 1987 the board has reviewed and approved the 18% cap twenty-four consecutive times.  All three board members voted for the 18% ceiling extension to September 2024.

This meeting displayed each board member’s understanding and approach to this hither to fore routine event. I can’t wait to see the sequel in April’s meeting.

 

Posted on

The Most Significant Omission in NCUA’s Performance Plan

At the January NCUA board meeting staff presented the Agency’s 2023 Annual Performance Plan.  It is 43 pages.  With many  outcomes.  As stated in the Chairman Harper’s introduction:  We have identified three strategic goals supported by ten strategic objectives and 19 performance goals. To meet these goals and objectives, the NCUA has also identified 45 indicators to measure performance.

Even with these many details,  the document has a significant omission.  The oversight  was not  mentioned by any board member. The absence may explain why the agency has been so ineffective in overseeing the most vital component of cooperative design.

The Missing Concept:  “Member-owner”

The term member-owner is used once, in the Mission Statement:  Protecting the system of cooperative credit and its member-owners through effective chartering, supervision, regulation, and insurance.

The term is never referred to again.  Where one might expect to see the concept, instead the words “consumer “and “individual” are inserted.  The word member does not even appear in the two highest strategic goals:

Goal 1: Ensure a safe, sound, and viable system of cooperative credit that protects consumers.

Goal 2: Improve the financial well-being of individuals and communities through access to affordable and equitable financial products and services.

Standard Plan Descriptions

The agency self description affirms that “the NCUA is an independent federal agency that insures deposits at federally insured credit unions, protects the members who own credit unions. . .   But the protection throughout is interpreted only as consumer compliance. Nowhere is there reference to member-owner rights, interests, responsibilities or even education.

Here are examples of how the agency describes its responsibilities in various sections of the plan:

The NCUA protects consumers through effective supervision and enforcement of federal consumer financial protection laws, regulations, and requirements.

Throughout the year, the NCUA will continue to adjust its examination program and operations to maintain safety and soundness, protect consumers, and ensure compliance with anti-money laundering laws.

Provide timely guidance to the credit union system and examiners related to changes in regulations established to protect consumers.

Monitor consumer complaints and fair lending examination and offsite supervision contact results to guide consumer compliance program development.

Continue to provide a responsive and efficient consumer complaint handling process in the Consumer Assistance Center.

The NCUA will enhance consumer access to affordable, fair, and federally insured financial products and services through the following strategies and initiatives:

Performance Goal 2.1.2 Empower consumers with financial education information.

No Ownership Role or Protection

Those who originally organized the coop and their heirs who today own the institution, at least in design, are now nothing more than consumers.

Owners’ rights are not part of  NCUA’s oversight.  The agency  protects “consumers” not owners, and safeguards “individual” not owners’ assets.  The agency is nothing more than  a cooperative CFPB with a safety and soundness function.

The Most Critical Function of Owners

In NCUA’s plan, member-owners have no standing, no rights and most of all, no regulatory attention.  This significant regulatory omission is why some credit unions feel empowered to push all of the boundaries of self-interest and business enterprise with actions disconnected from owners’ well-being and value.

Democratic coop design was intended to be a check and balance, the all important governance process that every organization requires to remain accountable, safe and sound.

Even NCUA asserts it has a governance process:  To ensure sound corporate governance, the NCUA will use the following strategies and initiatives: pg 29

The Consequences of No Member Ownership Role

Because of this regulatory omission, intended or otherwise, few credit unions  today  have any meaningful ownership participation.  The organization’s aspirations are only those of the  CEOs’ and boards’ ambitions. That often means business enterprise priorities over member welfare.

Credit unions are not subject to their peer’s competitive reviews as would be the case with a publicly traded bank stock. The institutional practices of mergers, sales and buyouts are not subject to any competitive process. Instead these executive transactions are private deals devoid of member input, meaningful public disclosures, no objective benefit and often lacking any economic rationality.

Just as NCUA has eliminated the ownership role of the member from its purview, so have many credit unions.  Without owners, just consumers, there is no accountability for institutional performance in theory or practice.

A Dangerous Design

That is a dangerous model.  Credit unions increasingly control billions in member funds and their collective savings (equity) in the hundreds of millions of dollars.  They increasingly commit to long term projects such as  subdebt borrowings, 20-year leases, and long term commercial real estate loans. The final outcomes of these decades’ length transactions may not be known until long past the tenure of the CEO who made the decisions.

Today most credit unions provide little to no transparency of their plans, priorities or projects to members.   There are plenty of product and service marketing messages.   But rarely are members informed about management’s goals.

The election of directors at the required annual meeting is fixed.  There is neither a choice for directors nor director statements of their reasons for serving.  Voting is by acclamation.

Without governance and a recognition of the owners’ role, the moral hazard of management decisions using the credit union’s resources increases.   Upside risks all benefit the incumbents; but the downside possibility of failure from a bank purchase, national expansion or fintech investment, means the members or NCUSIF will pay the price.

If one believes CEO/Board self restraint is sufficient to ensure members’ best interests, then they have not paid attention to practices such as; the $1.0 million dollar bonus to the manager of a merging credit union; the $10 million transfer of equity to a private foundation; or the change-of-control payments inserted in senior management contracts.

The list of self-serving actions grows daily.  Where money management for others is required, greed always lurks.

As just “consumers” or “individuals” member-owners no longer benefit from the most important reason for joining a financial cooperative.

Unless or until there is a meaningful acknowledgment  of member ownership and management’s obligations thereto,  the credit union system’s uniqueness, not to mention its soundness, will increasingly be at risk.

 

 

 

 

 

 

 

Posted on

An Incredible Chartering Story

The headline tells it all:  This Black Barber Opened The First Credit Union In Arkansas Since 1996.

It is the story of Arlo Washington’s journey to create People Trust Community FCU chartered in  September 2022.   The article in Next City describes Arlo’s journey after his mother died in 1995.  He followed a mentor’s model and became a barber.  His business instincts led him to open multiple shops and organize a barber college.

At the barber college he set aside $1,000 per month from profits to make small loans to the community.  This micro lending service grew until  the lending program was converted into a CDFI.  People Trust Community Loan Fund, the government recognized non-profit, then became the basis for his credit union charter application.

The Story within the Story

The author, Oscar Abello,  also weaves in another, longer tale, of the decline in new credit union charters.  Several of his observations follow:

It’s never been very easy to start a credit union, but it used to be easier and much more frequent than it has been in recent years. Prior to 1970, it was common to see 500 or 600 new credit unions chartered every year across the entire country.

People Trust was one of four new credit unions chartered in 2022; just 25 new credit unions have been chartered over the past 10 years. . .

There are almost always more interested groups looking to establish new credit unions, says Monica Copeland, MDI network director at Inclusiv, a trade group for credit unions focused on low-to-moderate income communities, “but it’s hard to track until they actually get through the process. It takes organizing groups years.”. . .

Or take Everest Federal Credit Union, which is based in Queens, New York and serving Nepali immigrants across the country. Its organizers started their work in 2015 and only recently opened for business. Part of their challenge was the startup capital they had to raise, from donations they ultimately gathered over the past seven years from hundreds of donors across the country.

Each of these efforts has had to go through the National Credit Union Administration – the federal agency that charters, regulates and insures deposits held at U.S. credit unions.  . .

There are multiple reasons for the dramatic falloff in new credit unions since 1970. Now a credit union consultant, Brian Gately worked as a credit union examiner at the NCUA in the ‘70s and ‘80s. According to Gately, the agency gradually lost touch with its purpose over the course of his tenure.

He started out winning awards for helping new credit unions get chartered to serve vulnerable communities in Puerto Rico and the U.S. Virgin Islands, but eventually left after refusing orders from higher-ups to shut down a new credit union serving a largely Puerto Rican migrant community on Manhattan’s Lower East Side.”

The article presents further examples of the chartering hurdles.  These challenges help a reader understand the miracle that any new credit union charter represents today.

Missing the Next Generation of Entrepreneurs

According to the Commerce Institute over 5.0 million new small businesses were started in 2022.  Only 4 new credit union charters were issued last year.  During the year credit unions announced or completed four to five times that number of whole bank purchases.

Credit unions are not tapping into  America’s inherent entrepreneurial market-based culture.  A system that fails to attract new entrants will slowly mature, consolidate and lose relevance. Other startups will arise  intent on  taking away a declining industry’s  current and future customers.

The article is an engaging description of one person’s efforts to pursue the possibilities of a credit union charter.   It also documents how difficult that process is, especially as it depicts NCUA’s role.

If a reporter who does not follow credit unions as a regular beat can so thoroughly document the new charter failings of the movement, why can’t credit unions see this challenge?

It raises the question as well of how many interested charter groups give up in frustration and look elsewhere for financial services?

 

 

 

 

 

 

Posted on

Losing the Cooperative Spirit?

This slide is from a November 2021 speech on credit union history at the Credit UnionLeadership Institute.  Facilitator:  Gary Regoli, CEO Achieva Credit Union.

It is a statement of the existential choice every credit union makes, often on a daily basis.

“Credit unions continue to lose ground with consumers, according to the American Customer Satisfaction Index’s most recent finance study. Credit unions’ score has dropped by one point to 75—falling behind banks for the fourth consecutive year.

Banks now surpass credit unions in nearly every service category as rated by U.S. consumers, according to this year’s survey. On the ACSI’s 100-point scale, credit unions now trail banks by three percentage points. Banks’ overall score (78) has remained relatively unchanged over the last four ACSI reports.

“The 2021-2022 study, which was based on more than 13,500 customer interviews, covers banks, credit unions, financial advisers and online investment. According to researchers, rapid membership growth fueled by the pandemic and ongoing industry consolidation could be affecting credit union customers, though the credit union industry’s traditional area of strength in the annual survey—in-person service—has remained consistent.

“Credit unions continue a long, slow decline in member satisfaction that is now in its fifth consecutive year,” said Forrest Morgeson, assistant professor of marketing at Michigan State University and director of research emeritus at ACSI.”

Source: ABA Banking Journal, November 16, 2022