Category: Co-ops in Capitalism

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A New Class Act?

Risk based lending (RBL) was introduced to credit unions in the mid 1990’s.  Many credit unions now use this approach in some or all  of their lending offerings.

The debate continues as to whether this is consistent with coop principles.  Here is one CEO’s view.

(from Jim Blaine)

Balanced lending…

Many, many credit unions have successfully implemented risk-based lending to the benefit of each and every member. More and more members are calling out and demanding increased risk-based lending by credit unions. Never has one concept been so uniformly and enthusiastically accepted by the masses. RBL is the top requested service on every member survey – right?.


One CEO told me that RBL was an easy sale to the Board after one Board member got back from an RBL seminar cruise. Evidently, in the bar, the Board member was chastised by an RBL advocate with the arguments: “You mean you charge the same loan rate to an admiral as you do to an E-4? You mean your school superintendent pays the same rate as the first year teacher?  The blue collars get the same deal?! Do your maid and gardener get the same rate you do?  That’s not fair! You’ve got to start running that credit union like a business these days!”  

It’s an especially easy sale, when you lace the poison with a few high heat words like unfairness, subsidy, unprofitable, freeloading – free riders. Fairness, of course, is something every credit union person supports. Every effort should be made to assure fairness is a fundamental, core value of the credit union philosophy.


Evidently for the first seventy or eighty years of the credit union movement, boards and members didn’t care much about fairness in lending. Unfairness existed in all credit unions since none used risk-based lending….

Secret formula…

Critics try to make an issue out of the “unfairness” in RBL. They always want to claim that while RBL may achieve consistency in credit union lending decisions, RBL was never designed to achieve fairness. With RBL, members are divided into risk “classes” (A,B,C,D,E, etc.) based on a secret formula of risk criteria.  

Although the secret formula for risk criteria isn’t advanced enough to tell us which exact member will default, it is explicitly accurate in knowing which “class” to which you and I should belong. There are no shades of gray in an empirical, statistical model. Don’t tell me about the divorce, the flood, the death in the family, or the reporting error. Your statistical record speaks for itself. The secret formula knows who you really are in your heart of hearts.    Cut the whining, pay the rate; fair is fair!


Complainers also don’t seem to appreciate the need to eliminate the subsidies within a credit union to “low class” borrowers. The financial stability of the wealthy few is being imperiled by the working class majority. If the poor can’t pay their loans, logically they should be charged a higher rate. 

A New Class Act?

But we haven’t even begun to fully exploit the benefits of risk-based pricing for the membership. Hope we can use the secret formula to help make some of the other operations of the credit union fairer. We’re already getting behind on the innovations being implemented by our guiding lights over in the banking industry.

Some local banks have used secret formulas to determine even more precisely which customers are profitable and which are unprofitable. Who wants an unprofitable customer? And there certainly isn’t any difference between an unprofitable customer and an unprofitable member, is there? Hey, credit unions aren’t welfare states, are we?

Those creative banks have started coding customers into green, yellow, and red “classes” at the call centers. Regardless of how long you’ve been waiting, green goes to the head of the queue. Greens have separate, fast teller lines and receive special services. Bright, bright greens can even receive “private banking” services so they never have to rub elbows with “the riffraff”. Don’t we want to serve our “best” members, too?

Whose credit union is it anyway?

Serving the members based on the distinction of “class” will go a long way toward increasing a sense of fairness and building unity within the credit union. We certainly haven’t been “a class act” in the past but surely everyone agrees that – in a cooperative – some members are more equal than others.

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Can Credit Unions Be Uniquely Cooperative?

Apples and Oranges

(from Jim Blaine)


Comparing a b#!k to a credit union is as silly as comparing an apple to an…
Credit unions are uniquely different!!!

If you’re one of those cynics who think “nothing is unique”,
 then name one word in the English language which rhymes with orange…
Don’t rush I’ll wait….
Alright, alright if you’ve had a couple of craft beers, I will accept “door hinge“..
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The Power of the Credit Union Press

Many challenges confront credit union focused news reporting.  Publishing daily via social media is hard.   Staff is limited.  Original stories take time to develop.   Amplifying press releases is often an easy solution when faced with daily deadlines.

Credit Union Times and CUToday  have developed  important reporting niches however.   If readers  follow these original stories, they can provide insight into events that have consequences for the future of the cooperative system.

Following Court Documents

Peter Strozniak of Credit Union Times  follows  court cases about credit unions.  On October 4, he reported on the embezzlement at the $3.2 Prairie View FCU: Former CEO Pleads Not Guilty to Embezzlement Charges.   Some of the details in his coverage included:

  • The CEO’s scheme lasted from 2010 until August 2020;
  • She embezzled over $211,000 from 34 elderly members accounts;
  • Created fraudulent loans for over $791,000;
  • Formed 58 nominee loans by creating fake share loans in the names of relatives and friends

In eight of this ten-year fraud time frame, the credit union reported annual operating losses on its call reports. The credit union was merged in the first quarter of 2022 due to “its poor financial condition.”

The question that jumps out  is how could NCUA examiners have continually missed this illegal activity for ten years?

Peter did not go there with this story, but the details certainly raise a core question about NCUA’s supervision of the FCU.  It was small, with few employees and only 600 members.  The call reports showed  losses for most years.  What does this case imply about the  efficacy of NCUA’s annual examinations?

CU Today Goes to the Public Record

For most of this year, CU Today has summarized the merger activity posted from NCUA’s web site, Comments on Proposed Mergers.

Their latest reviews showed “CUs seeking to merge in multiple other CUs at once, combo’s in which the merging and acquiring CUs are both losing money, and several examples of credit unions reaching across state lines and even across country for merger partners.”

This reporting which includes the latest data and quotes from the member notices, takes a lot of work. Some examples.

One summary is for AIM Credit Union in Dubuque, IA.  It is merging two Keokuk credit unions.  Members of both merged credit unions were given identical Notice statements.  They will be voting on the same day at the same location, First Christian Church.  The two towns are 150 miles or about three hours apart.  Was a local merger of  the two credit unions considered?

In the merger of two Michigan credit unions, Community Alliance Credit Union ($108 million) with People Driven Credit Union ($355 million), the top three executives can receive a total of $542,000 in severance.

Community reported  midyear capital of 8.39% and  a loss of $73,000. The members were offered nothing of the over $8 million in capital being transferred.  Is this an example of taking the money and running away?

The three-year old Maine Harvest FCU with 56% capital is merging so that “its mission of lending to farms and food producers will be better preserved with a larger credit union that embraces that mission.”   Was this option researched at the start?  Why not create a partnership, versus merger, with a larger credit union if more services are needed?

The $210 million Emory Alliance Credit Union in Decatur GA is merging with Credit Union 1 whose main office is listed as Rantoul, Il.  One wonders why?  Were no local options available?   Did Emory do any due diligence on behalf of their members, especially of Credit Union 1’s recent initiatives before recommending this out of state takeover?

Finally, the $226 million Parsons FCU in Pasadena, CA  is merging with the   $1.1 billion Skyla FCU in Charlotte, NC.   Parsons has almost 11% capital.  Merging with a credit union across the country, especially with very strong instate options, would appear contrary to every common sense notion of member service and value. What is the reason for this  “merger” almost 3,000 miles away.

Presenting the Facts for the Public

CU Today and Credit Union Times are serving a vital public, cooperative service developing this fact-based reporting.

Both media raise important questions about motivations and fiduciary duty of persons responsible for these events.

This original reporting  raises critical questions about the directions of credit unions, the regulator’s oversight  and how members’ best interests appear to be so cavalierly and repeatedly disregarded.

Sooner or later the stories behind these events will come out.   The political and repetitional consequences will impact every credit union even when excesses may be the work of only a few.

A diligent, informed and questioning press is critical in holding those in positions of responsibility to account. CU Today and Credit Union Times are doing the job of the 4th estate.  Are credit union leaders getting the message?

 

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An Old Tale, Updated for Credit Unions

Down On The Farm…?

(by Jim Blaine)

George Orwell masterfully described the erosion of values and the rise of exploitation in his classic novel Animal Farm. The book written in 1945 is a satire of the decline in the Russian Revolution from idealism to the overlord State of Stalinism. To Orwell, what the Revolution had become in post-WWII Russia bore little resemblance to the high hopes of 1917.

In case you’ve forgotten the plot; in Animal Farm the slothful, tyrannical human proprietor of Manor Farm is overthrown by his much abused and neglected farm animals. The revolutionary animals quickly come to realize that when united in cooperative effort, they are quite capable of sensibly managing the farm and their own affairs. 


Each animal, by nature and design, has different capabilities and unique qualities. Separately they are weak. But, cooperatively, working together; the united effort becomes far greater than the sum of the individual parts. Each animal contributes in full measure, in its own special way, to the overall success of the enterprise. 

The cows and chickens provide milk and eggs for food. The sheep provide wool for cloth; the dogs provide protection; and the horses provide strength for plowing. The pigs, who seem to be the brightest, provide direction and management (surprise, surprise!).

Every civilized society, every social movement, every cooperative effort needs and creates a set of guiding principles – a social compact, a credo, a charter which explains shared beliefs and values. The animals of Animal Farm were no different. They carefully crafted rules for their new social order and painted them on the side of a barn for all to see.  

                  ORIGINAL PRINCIPLES:
 
 1. Whatever goes upon two legs is an enemy.
 2. Whatever goes upon four legs, or has wings, is a friend.
 3. No animal shall wear clothes.
 4. No animal shall sleep in a bed.
 5. No animal shall drink alcohol.
 6. No animal shall kill any other animal.
 7. All animals are equal.

Over time, several incidents occurred which seemed to be out of keeping with those original purposes. The pigs were found sleeping in the former owner’s bed; alcohol reappeared at social gatherings of the pigs; an animal who complained about the changing values was killed; and the pigs seemed to be working less and consuming more than their fair share. 

When the animals returned to the barn to review their original principles; they found, much to their surprise, that those principles somehow had evolved into something a bit different!

“EVOLVING” PRINCIPLES:
 
1. Whatever goes upon two legs is an enemy.
2. Whatever goes upon four legs, or has wings, is a friend.
3. No animal shall wear clothes.
4. No animal shall sleep in a bed with sheets.
5. No animal shall drink alcohol to excess.
6. No animal shall kill any other animal without cause.
7. All animals are equal, but some animals are more equal than others.

The pigs, however, were always there to explain away questions, concerns and objections. Bad became worse at Animal Farm! Eventually, when the animals returned to the barn, they found a whitewashed wall with just one remaining principle.

“CURRENT” PRINCIPLES?

“All members are equal, but some members are more equal than others.”

“Isn’t that what we originally revolted against?,” some quietly asked.

So, what’s the point? In the beginning, there were several essential ideas which formed the core values of the credit union movement: one member, one vote; cooperative; non-profit; equal service to each member; consumer advocacy; volunteer leadership; unstandard answers; shared concerns; us not me. 

 Have you checked the barn lately?    
 
When did we abandon the average man and woman – the working class; change our focus to the primacy of the bottom line; lower ourselves to worshipping before the false altar of market share; begin acting in the best interest of “the credit union” – not the members !?!; and start offering excuses rather than solutions?

Hey really, what happened…   

Who let the pigs in?



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False Prophets and Chasing Idols

The email marketing headline read:  Is there a merger in your future?

Another suggested the opportunity to protect the CEO’s fate by adding  a “change of control” clause to the manager’s contract.

Many credit union leaders and most vendors are selling a vision of the future they want to help implement.   The focus is on the future, not the present circumstances.

The more apocalyptic the future predictions, the more urgent the message.   These prophets pretend to know the unknowable.   But the failure is not in their projections.   It is their misunderstanding of the present.

What Prophets Do

When leaders present their vision, they are making predictions about the future they hope to bring. In fact, prophets do exactly the opposite! They insist the future is highly contingent on the now.

From all the flotsam of events, beliefs and analysis, real prophets  have the ability to identify what really matters.  Focusing on this is essential for ongoing success.

That’s not predicting the future as much as it’s naming the way human reality works today and tomorrow.  The true prophet dares to tell what is essential in the face of marketing hype, rhetorical cliches and the latest innovation that will cause members to leave current institutions behind.

An Example

Decades ago I first met Rudy Hanley, the long time CEO of SchoolsFirst FCU in California.   He asked how I approached strategy.   As I outlined the model and summarized  growth options, he stated that the credit union’s primary goal was not growth.  It was ensuring the members’ trust.   No matter the circumstances or cost, the critical success factor was continuing to place member confidence at the center of every decision.

If member relationships were built on this foundation, he believed growth would naturally follow.

This is not every CEO’s priority.   Some believe size guarantees success, the bigger, the stronger and the more resilient.   Others put their trust in technology and introducing the most compelling solutions or latest crypto offering.  When winning in the open competition of the market seems to slow, others will chase the chimera of buying out or merging competitors.

All these approaches can bring short term success.  However member-owned cooperatives were established and succeeded as an alternative because of the unique consumer-member relationship.   Emulating the corporate strategies of banks and other commercial firms is following false idols.

There are a host of idolatries at the center of the cooperative system today.   Many aspire to the prestige and stature of banking competitors.   Making money becomes the number one priority albeit always clothed in the phrase of serving members.

Instead of seeking those who are often victims of current financial choices, credit unions aspire to serve everyone.  Speaking truth about why coops exist becomes prophetic because the “powers that be” that benefit from the system, cannot see this simple message.

The Transition of Leadership

The challenge of understanding who coops are and how credit unions are unique is especially front and center in leadership transitions.

One CEO who recently oversaw this change in his institution observed these dynamics:

It’s hard for today’s leaders to make their bones when they are up to bat.

Then lazy new leaders simply fall in line with the best practices of the day, currently community banking tactics 101.

New leaders will not see staying the course as the means to their hopeful ends.  They have been given the reins for change, not just continued success.  They are vested in their peer’s approval not their members, nor history’s standards.  

The new actors today are vested in their choices.  Logic will not be enough – it’s too nuanced to turn back the belief that change is the catalyst to bigger things.

These are a prophet’s words for the present.   Will anyone hear the message?  Or will there have to be a cost to chasing idols versus trusted service,  the core of Rudy Hanley’s leadership?

 

 

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When The Bullet Hits The Bone…

Two credit union press releases this week reminded me of the 2012 post below by Jim Blaine.

The first was the announcement that five Minnesota credit unions had loaned $31 million to Opal Holdings, a New York real estate developer and investment firm, to purchase a 17 story office tower in Bloomington, MN.  “The financing included two senior secured notes on equal footing issued in June: One for $22.1 million at 5.1% for 36 years and the other for $8.1 million at 5.32% for 40 years.”

The second from Summit Credit Union stating it had completed the purchase of the $837 million Commerce State Bank  “in the largest credit union acquisition of a bank in the state’s history.”

“Twilight Zone”  (by Jim Blaine)

Nobody said it better than Golden Earring.  No, this is not the golden earring you fearfully imagine sprouting some day from your teenager’s nose or navel.  It’s the late ‘70s rock group and the song is “Twilight Zone”.  The question:  “Steppin’ out into the twilight zone.  Entering the Madhouse, fears that have grown.  What will become of the moon, and stars?  Where am I to go, now that I’ve gone too far?”…  The answer:  “You will come to know, when the bullet hits the bone!  Yes, you will come to know, when the bullet hits the bone!”

The Heartland….

The Amana Colonies, 26,000 acres of picturesque Iowa farmland, sheltering seven immaculate villages, are up Highway 151 about 100 miles east of Des Moines.  This is the Midwest, the Heartland.

The place where the Deere and the antelope play.  A warp in time through which, you may, perhaps, be able to catch a glimpse of the future – the future of the credit union movement.

The Amanas were settled in 1855 by the Society of True Inspirationists.  The sect was formed in Germany; adopted a communal structure; and had unique, idealistic, and firmly held beliefs – sound vaguely familiar?  The communities were self-sufficient and prospered richly.  

All things were shared.  Products, such as woolens, handmade furniture, meats and wines, were sold to the outside world.  A sterling reputation was built upon high standards of craftsmanship and a close attention to detail.  The “Amana” name – remember that refrigerator? – became synonymous with quality and value – sound vaguely familiar?

“Why don’t you download this app…”

The Amanas appeared to be the true Utopia, the new Eden.  But trouble, eventually, always comes to Eden.  At first, the Inspirationists called it “The Reorganization”, then “The Change”, and finally, “The Great Change”.  It started as a murmur, became a grumble, heightened to an argument, and ended in 1932 as a split.  

Eighty years of success forced onto the scaffold of change by a diminished intensity of beliefs, a cooling of religious fervor, a forgetfulness of original purpose and vision – sound vaguely familiar?

Their world, however, did not come to an end in 1932.  The Amana Colonies continued on.  The communal structure was abandoned; the religious and the secular were separated.  Homes and personal property were divided; stock was issued in the businesses and agricultural interests.

The Amana Society Corporation now controls and manages the businesses.  The Amana Church Society now deals with spiritual matters.  Today, the Amanas are on the National Registry of Historic Places and the Amana Heritage Society strives diligently to preserve the cultural heritage of the community and its descendants.  Today, the Amanas are still many things, but mostly the Amanas are a novelty, an oddity, a quaint museum of past hopes and ideas.  

Why did this happen?  The guidebook says:  The Amanas were… “a goal:  visioned through faith; created and established by faith; named for a faith and dedicated to a faith”.  And, “the first generation had an idea and lived for the idea.  The second generation perpetuated the idea for the sake of their fathers, but their hearts were not in it.  The third generation openly rebelled against the task of mere perpetuation of institutions founded by their grandfathers.  It is always the same with people.” – sound vaguely familiar?Which credit union generation is this?  Are you still living for “the idea”?  Is your heart… still in it?

“… destination unknown.” 

“Steppin’ out into the twilight zone.  Falling down a spiral, destination unknown.  What will become of the moon and the stars.  Where am I to go, now that I’ve gone too far? 

…You will come to know, when the bullet hits the bone.  Yes, you will come to know when the bullet hits the bone.”

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Keeping the Credit Union Difference Alive

A timeless observation from Ed Callahan:

The disturbing word banded about this year so far is “comparability.” It came up in President Bush’s plan for solving the S&L mess-to make the NCUSIF’s accounting comparable to those other funds. . .

Comparability is also echoed in the phrase, “bank envy” the desire of some credit union people to enjoy more of the powers of banks. . .This comparability stems from a kind of inferiority complex.  Those that embrace the notion that by becoming more comparable, we are somehow elevating ourselves. In fact, the opposite is true. . .

Credit unions are different.  They were set up to be different and should remain different. They are different because we put the emphasis on the people we serve.  Our strength is we help people.  

Callahan Report, July 1989

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Cooperative Democracy: an Oxymoron?

Mark Twain Was Right: If Voting Mattered, They Wouldn’t Let Us Do It. There’s only one way to make your voice heard and it isn’t by protesting.

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James Clear: “Every system is perfectly designed to get the results it gets. If you want better results, focus on your systems.”

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When the coop’s democratic owner advantage is not used, it goes away. Co-ops become indistinguishable from banks. Members are just another name for customers. And leadership progressively presumes its judgments and choices are the primary basis for all decisions–even those ending the charter’s independent existence.

When democratic practices are habitually circumvented, they are difficult to restore. Without regular succession processes, the ability to find new leaders, or even generate interest in leadership is squelched. And at any moment, the sirens of self-interest can appear, canceling the credit union’s future for all members.

Democracy matters until it doesn’t. The good news is that this is a fundamental flaw that every credit union has in its own power to fix. (CUSO Magazine)

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From Mike Mercer:

‘The extent to which cooperation is the norm depends on the extent to which the behavior is nurtured by the institutions of a society.’  In a time when power is concentrated in the hands of individuals with lots of capital or those with the keys to redistribution of wealth, it is hard to imagine that decentralized cooperation will organically be embraced from within the citadels of existing power. Rather, the cluttered path to a more civil economy will have to be cleared by those who lead democratically structured organizations that have already been formed to foster cooperative behavior.

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Notes from the Field

The notes below are from  three CEO’s monthly staff updates to all employees.  All report excellent financial results with above plan loan growth and strong earnings. The  comments illustrate these credit union leader’s efforts to reinforce their distinctive cultures.

Taking Care of Employees: Stimulus Checks and Health Care at WPCU

Thank you to all the people who expressed their gratitude with an email, a handwritten note or a thank you in the hallway. The management team was thrilled to do this for all our Partner-employees and the myCU experts. Though I want to make sure I remind you that every dollar we paid out in the stimulus check (and every other dollar WPCU spends) comes from the members – and that is why it’s so essential to take better care of members than anyone else does.

CREDIT UNION RECOGNITION: I am excited to share that WPCU has once again been named one of the healthiest employers in Ohio by Healthiest Employers®. Since 2009, Healthiest Employers has been the leading recognition program for employer wellness. Healthiest Employers has over 10,000 employers from all 50 states, including 72% of the Fortune 100.

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A Credit Union Member Story from WEOKIE

Ms. Member came into the credit union to speak with a mortgage loan officer about how she could consolidate her debt to make ends meet each month. Ms. Member stated that she is 79 years old and still has 23 years left on her mortgage. Due to the economy, she is unable to make ends meet each month. She got very emotional and told me there are times when she eats very little to make sure all bills are paid. I told her I would take good care of her and look at all her options.

She told me she wanted to consolidate all debts, if possible, into one monthly payment. We added up all debt payments totaling $1879. She only receives $3000 total a month between social Security and retirement. After reviewing all the products Ms. Member settled on the low-cost 15yr fixed. I was able to shave eight years off her mortgage and put $970 back into her pocket each month. Not to mention we closed her loan the last day of the month therefore, she was able to skip September. So that’s an additional $909 (the new mortgage) in her pocket. I told her to go enjoy a steak dinner with her grandson, who she talked about every time we met.

Partnering with local nonprofits.

The WEOKIE Foundation is proud to be partnering with two new local nonprofit organizations. One organization called NorthCare works with the community to recover from mental illness, substance use, and trauma. They have 400 awesome employees in multiple facilities and have asked our team to assist their employees with their finances by providing education, tools, and 1:1 counseling. We kicked off the program the last week of August with a presentation to their staff and have many other future events planned.

Another group that we are working with is ReMerge, a local nonprofit offering a second chance to women battling trauma, poverty, and incarceration. We’ll be working to assist these women as they rebuild their lives in regards to their finances.

We have many exciting things planned for both nonprofit groups and look forward to helping our community with some practical tools to improve their financial lives. Both of these nonprofits are doing amazing work in our community. The Foundation is honored to be assisting with more than just monetary donations.

Connecting with a 90Year Old Former NCUA Mentor.

Kim and I were able to travel to Palm Springs last week to celebrate the 90th Birthday of a long-time mentor and friend Hap Blaisdell. Hap was an early mentor to me and is recognized as the “father” of the Student Credit Union movement while serving as Executive Assistant to then NCUA Vice Chair Elizabeth Burkhart. Hap eventually became my “first hire” as the Executive Director of the Campus Credit Union Council (CCUC) when I served as its chair. Hap has been “uncle Hap” to thousands of young credit union leaders over the years. The occasion also facilitated a new friendship for Kim and I with Georgetown Student Credit Union Alumni Peter and his wife Agnes.

See Harry Blaisdell’s role 1986 in this blog on student-run credit unions in a New York Times story.

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Employee Appreciation Event

It was a little hot Sunday but there were clear skies as about half the Day Air team and their families came out to Day Air Ballpark for the Associate Appreciation event.  The Credit Union is once again having a “best year ever” so there’s a lot to recognize and appreciate.  A good time was had by all, especially by the little ones.  Thank you to everyone on the team for living the mission and making a difference in the lives of our members each and every day.

Member Feedback on the Net Promoter scores of 1 through 10.

  1. Ten is for everything I have ever needed help with was taken care of. Things were taken care of quickly and done right. Also day air saved my family; my car didn’t work anymore. I was in a bad time in life and needed a new car like an emergency. I went in to get a loan with not very good credit. Day air helped and gave me a loan and changed my life forever. I will forever be greatful.
  2. Many times you have helped me during a financial crisis

A Member note.

“When i came in to open my personal and business accounts I had a problem with my tax# and Palisha Boyd was great she was patient with me and she navigated me through the process to get my tax# straight. I was so grateful that’s what I would tell anyone who I refer to dayair. Something else I love about dayair is that you have a relationship with re-entry people trying to get their lives back after incarceration.”

Keeping in touch with state legislators.

I met with State Rep Andrea White last week. She left very impressed with all that Day Air is doing in the areas of home ownership affordability, financial literacy, and supporting the local economy.  She was receptive to and will likely support several bills endorsed by credit unions, including county recorder modernization and residential PACE loans.  She was interested in the history behind the public funds issue (credit unions are prohibited from accepting public funds in Ohio) and requested information that led other states to move in favor, which will be provided to her.

Supply Chain Issues.

The HVAC system in the suite level of Day Air Ballpark is operating at 50% capacity and replacement units aren’t available for 30 weeks due to supply chain issues.

 

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“The Public Purpose” of the Credit Union Cooperative System

In every new administration and most assuredly  following economic or other national crisis (Covid, natural disasters), the need to review governmental and agency responsiveness is raised.  Are changes needed?

Whether prompted by political priorities or  performance shortcomings, this is how existing policies are reassessed.

Another motivator is when market competition carries over to the political arena . Firms call out their rival’s more favorable regulatory  or tax status in their lobbying messaging.

In last week’s posts listed below, I noted the current absence of a policy framework at NCUA for the cooperative system.  I believe this leaves the system vulnerable to priorities set by others or to purely personal agendas.

The Reviews Begin

Last week the Director of the Federal Housing Finance Agency (FHFA) announced a review of the FHLB system.  FHFA, created in 2008, is the successor to the five person FHLB board.  This single administrator oversees the eleven FHLB’s and the conserved Fannie Mae and Freddie Mac.

The assessment of the 90-year old FHLB’s $ 1 trillion assets is to determine if  its modern day activities fully match its original mission of supporting mortgage lending.

FHFA Director Thompson’s purpose is to ensure the banks “remain positioned to meet the needs of today and tomorrow.”  One outside observer noted: “The home-loan banks lack a well-articulated contemporary purpose.”

Similar to credit unions, the FHLB cooperatives are exempt from corporate federal, state, and local taxation, except for local real estate tax.  For individuals, all FHLB bonds are also exempt from state and local taxes.

Credit Union’s Tax Exemption On the Agenda

A month earlier on July 27, columnist David Bauman wrote how the GAO was urging the OMB to study tax expenditures,  a budget category that includes the credit union tax exemption.  Are numerous tax exempt organizations still fulfilling their mission?

Bauman points out  the Treasury Department estimated the credit union tax immunity will cost the federal government $25.3 billion between 2022 and 2031.  This issue he wrote is “part of an ongoing battle between the banking and credit union industries.”

Scrutiny Not a New Process

From 1981 through 1985, the credit union system was part of four national studies directed by the Regan administration.  These were in  response to record high inflation, unprecedented interest rates,  disintermediation, financial innovation and growing concerns with institutional solvency.  For example, the Penn Square Bank’s 1982 failure was the largest FDIC liquidation post WW II.

In addition to the normal inter-agency or industry councils such as the FFIEC, NASCUS and multiple studies such as CUNA’s CapitalizationCommission, NCUA’s Chair was directly assigned to these four government-wide  assessments.

  1. The Depository Institutions Deregulation Committee (DIDC) was a six-member committee established in 1980 by Depository Institutions Deregulation and Monetary Control Act passed on March 31, 1980. DIDC’s primary purpose was phasing out interest rate ceilings on deposit accounts by 1986.

NCUA Chairman Callahan was one of five federal depository regulators. Chaired by Treasury Secretary Regan, all banks and S&L’s were given until June 1987 to end all federal controls on deposits.

NCUA chose not to follow the banking group’s timetable, eliminating all regulations in one new rule in May 1982. The decision effectively gave credit unions a five-year head start in the new market-facing era for financial intermediaries.

  1. The Garn-St Germain Depository Institutions Act of 1982, known as the “Deposit Insurance Flexibility Act” mandated that the three regulatory agencies study their insurance funds and make any recommendations for future changes.

On April 15, 1983, NCUA forwarded its 71-page, five-chapter study containing four policy recommendations.  This study became the foundation for the NCUSIF’s financial redesign approved by Congress in The Deficit Reduction Act  signed by the President  on July 18, 1984,

In Chairman Callahan’s forwarding letter to the study he noted:  “For credit unions there are very clear answers to the issues raised by Congress.  This is because credit unions . . .have actual experience with the options and alternatives suggested. . .Our responses are based on historical facts and current operational realities rather than academic theories or untried options. The credit union experience with insurance has been substantially different from the other agencies and our recommendations accordingly reflect this unique heritage.”

  1. The Private Sector Survey on Cost Control(PSSCC), commonly referred to as The Grace Commission, was an investigation requested by President Ronald Reagan, authorized in Executive Order 12369 on June 30, 1982.

The focus was waste and inefficiency in the US Federal government. Its head, businessman J. Peter Grace, asked the members of that commission to “Be bold and work like tireless bloodhounds, don’t leave any stone unturned in your search to root out inefficiency.”

The Grace Commission Report was presented to Congress in January 1984.  The Report included this observation:   “NCUA Chairman Callahan is a role model for government agency executives.  In one year NCUA reduced Agency staff 15% and its budget, 2.5%, while maintaining their commitment to preserving the safety and soundness of the credit union industry.” (NCUA 1983 Annual Report, page 3).

  1. The Vice President’s Task Group on the Regulation of Financial Services was formed in late 1982. Treasury Secretary Regan, the five financial regulators, the Attorney General, Directors of OMB, chairs of the SEC and FTC and state regulators raised the total principals to thirteen. The Group was given one-year to make recommendations to address the challenges of the emerging financial markets after deregulation and the potential repeal the Glass Steagall Act.

A final report was issued in November 1984. The Group’s recommendations were summarized by John Shad, Chairman of the SEC, in a later speech. He closed saying:

The lines of demarcation between the financial service industries have eroded. These activities should be regulated, and permitted to compete, according to their functions, rather than outmoded industry classifications.  

NCUA and the independent cooperative system were not mentioned in the Group’s regulatory recommendations.

NCUA and credit unions thrived in this transformative period of rapid financial change and increased scrutiny by completing the institutional, regulatory and policy foundations for a separate, unique and sound cooperative system.

Why a Cooperative Policy Framework is Essential

Without a clearly stated understanding of credit union’s role, every government study above could have drawn credit unions into their macro policy recommendations.

Instead NCUA demonstrated its ability to develop, document  and implement  how the deregulated cooperative system was successfully meeting its public purpose role serving members.

The cooperative system’s soundness was based of the values of self-help, self funding, and democratic volunteer leadership.  The “moral hazard” concern from FDIC/FSLIC insurance of private financial ownership  was absent in  cooperative’s creation of “common wealth.”

Today the ability to articulate this purpose is missing.  Regulations, especially the recently imposed RBC/CCULR were defended as being virtually identical to bank capital requirements.  New charters are rarely issued raising the question of credit union relevance today.  Whole bank purchases are routinely approved by NCUA even though  this use of member savings would seem contrary to why a cooperative system was created.

Absent an awareness of cooperative history and precedents, policy pronouncements or priorities of board members may just seem  like comfortable generalities.

In Harper’ July 2022 investiture address, he reflected on his year and half tenure as Chairman:

In achieving each of these things (regulatory activities), we have followed a philosophy that should guide all financial services regulators. Specifically, we were fair and forward looking; innovative, inclusive, and independent; risk focused and ready to act when needed; and engaged appropriately with stakeholders to develop effective regulation and efficient supervision. This philosophy will continue to drive our actions in the years ahead.

Is this the regulatory understanding that credit union cooperatives are seeking?

Sooner or later credit union’s special identity will be challenged by some governmental or political process.

The cooperative system navigated the multiple reviews from 1981-1985  because NCUA and credit unions earned a reputation for trust, expertise, mutual respect, shared purpose and performance.  This achievement was recognized by the industry and throughout the executive and legislative branches of both state and federal government.

NCUA Chairman Callahan in the Agency’s 1984 Annual Report observed:  The only threat to credit unions is the bureaucratic tendency to treat them, for convenience sake, the same as banks and savings and loans.  This is a mistake, for they are made of a different fabric.  It  is a fabric  woven tightly by thousands of volunteers, sponsoring companies, credit union organizations and NCUA-all working together. (page 3) 

Should  the movement aspire for anything less in this time?