Category: Co-ops in Capitalism

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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?

 

 

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A Rare New Species Sighted This Labor Day

Rare bird sightings are often front-page local news.  Such was the lead story on July 5, 2022  in Rockland, MI: Rare Eurasian bird spotted in Michigan, first sighting in US:

A Michigan birdwatcher made a once-in-a-lifetime discovery this weekend when he spotted a bird known as a common redshank in a marsh near Detroit, a few thousand miles from the bird’s usual home.

Equally rare among the financial species is discovering a new credit union charter.  The local news headline says it all:   Somebody Actually Started a New Credit Union. Here’s How They Did it.

This was the second sighting of a new credit union charter this year.  NCUA’s press announcement described the event as an example of credit union’s purpose: Supporting underserved communities and providing capital for community development is at the core of the credit union mission. 

Few in the credit union movement are actively trying to spot new charters.   CU*Answers and its CUSO challenge is one multi-year institutional effort.  Two individuals have been public in their pursuit of this rare activity:  Denise Wymore and NCUA Vice Chair Kyle Hauptman.

Because this event is so unusual, the joy, passion and hope embodied in a new credit union today are often overlooked.

Many persons’ deep desire to create something new to serve one’s community is a defining characteristic of American enterprise.

Entrepreneurs are central for a market economy, especially for new credit union charters that begin with limited financial capital.

On this Labor Day eve, I am reprinting this August 30 story as I believe it describes the dynamic human spirit new charters bring to the movement.  Enjoy this description of Community First Fund FCU’s creation by OSCAR PERRY ABELLO:

A Credit Union in the Neighborhood:  It Just Makes Sense

Leo Rodriguez knew all he needed was $10,000 in startup capital to open his own hair salon, something he’d dreamt about doing since he was four years old and saw a poster of legendary hair stylist Vidal Sassoon. Twenty-nine years and countless clients later, he is more excited than ever to invest back into the only institution that believed enough in him to make that loan.

The year was 1993. Rodriguez had already spent the previous several years studying cosmetology and hair styling in New York City and London. He returned to his home city of Lancaster, Pennsylvania, where he landed a job working at a new downtown hair salon founded by local legend Paula Severino Standish. After a wildly successful year, gaining his own influential clientele, he knew it was finally time for him to go out on his own.

He just needed that $10,000. But none of the banks he went to around town were interested in loaning him the money.

“I wasn’t looking to, like, renovate a building, I just needed a couple chairs, just to get started,” Rodriguez says. “There were a lot of banks that just didn’t want to give you any money. It was very hard to start a business. Also being a minority, that was difficult.”

A Personal Connection

But as fate would have it, one day Rodriguez was catching up with his childhood friend, Daniel Betancourt, who had recently left his job in commercial banking to join a new loan fund created by another local legend, a Black civic leader named James Hyson. Now called Community First Fund, it invests in Black, Hispanic, immigrant and other entrepreneurs whom traditional financial institutions weren’t interested in serving.

Not only did Community First Fund give Rodriguez his first $10,000 loan, it also taught him the ins and outs of running a business, creating a business plan, proper accounting, and profit and loss statements. He soon repaid that $10,000 and borrowed another $35,000, then $50,000. Every time he needed to expand or renovate or move his salon to a different location, he went back to Community First Fund. During his prime — he’s 63 now and expects to semi-retire in a few years — Rodriguez had 10 stylists working in his downtown Lancaster hair salon.

“I probably borrowed over three or four hundred thousand dollars from them in total over 30 years,” Rodriguez says. “They’ve never turned me down. They were always, always there for me.”

Loyalty and a Credit Union

Earlier this year, Community First Fund opened a traditional financial institution, a credit union. Why? Because after serving entrepreneurs like Rodriguez for 30 years, the fund found that the families and communities around those entrepreneurs either weren’t getting access to banking and affordable credit elsewhere or would prefer access to banking and affordable credit from a name and face they’ve come to trust.

Rodriguez was one of the first members of the new Community First Fund Credit Union. He’s moving all his personal and business accounts over.

“I’m into loyalty, man. I’m into taking care of people. it’s what I do,” Rodriguez says. “When Dan was telling me they were gonna open up this credit union, I’m like, ‘Oh, Jesus, thank God.’”

New Credit Unions Much Rarer

Starting up a new credit union is much rarer than it used to be. Prior to 1970, it was typical for federal regulators to charter 600-700 new credit unions every year. But since then, for multiple reasons, the number of new credit unions chartered every year began a long, slow decline. The new Community First Fund Credit Union was one of only four chartered in 2021. That’s as many new credit unions chartered over the previous five years combined. With so few new credit unions starting up, and scores closing or merging with others every year, the total number of active credit unions has declined from a high of 12,977 in 1970 to just 4,872 today.

The new Community First Fund Credit Union is also an even rarer example of something else. It’s modeled partly after Hope Credit Union, based in Jackson, Mississippi — which itself is really a replication of a model for banking that was birthed either on the South Side of Chicago or Manhattan’s Lower East Side, depending on who you ask. The model explicitly combines deposits from inside the community with deposits brought in from outside the community that might otherwise be deposited in bigger banks like those on Wall Street.

CDFI Plus a Credit Union

“The very fact that a new credit union is chartering is something noteworthy,” says Clifford Rosenthal, who helped establish Lower East side People’s Federal Credit Union in 1986. “And it’s especially significant in the CDFI world that this loan fund has used its resources to establish a credit union, which in the optimal scenario will operate side by side with the loan fund and hopefully achieve some real synergies.”

CDFI stands for “community development financial institution,” a U.S. Treasury designation for loan funds, credit unions, banks and venture capital funds that have a primary mission of serving low-to-moderate income, historically marginalized communities. Rosenthal helped craft the legislation passed in 1994 that created the CDFI designation as well as the CDFI Fund, an arm of the U.S. Treasury that provides grants, tax credits and other forms of support for CDFIs across the country. Community First Fund is a CDFI loan fund, and after it gets up and running, the new credit union can also seek its own separate CDFI certification.

Based on his own experience helping to start a credit union to serve a neighborhood other financial institutions were leaving behind at the time, Rosenthal expected that the new CDFI Fund would provide assistance to other groups starting either new credit unions or banks — regulated, depository institutions. But that isn’t how things turned out. Most of the CDFI Fund’s support has gone to loan funds like Community First Fund. And, with assistance from the CDFI Fund, some of those loan funds have grown very large, with assets in the billion dollar range.

“Some of the loan funds clearly have the capacity to launch a depository institution if they choose, but none of them have until now,” Rosenthal says.

Five Years Planning

Betancourt, now the CEO of Community First Fund and its credit union, says he started mulling over the idea maybe around five years ago. Clients of Community First Fund would occasionally ask if the loan fund could maybe help them or their families out with a home mortgage, or a used car loan, or alternatives to payday loans. Maybe they had tried getting those loans elsewhere and couldn’t, maybe they just wanted to deal with an institution they already knew and came to trust. At the time, Community First Fund had no way to help with those situations directly, it could only refer those requests to others.

Betancourt says he also started reading books like Lisa Servon’s “The Unbanking of America,” which gave him even more food for thought. Community First Fund also partnered with Lancaster’s Franklin & Marshall College to do a study of underbanked populations in Lancaster County.

More recent findings affirm what Betancourt was starting to grapple with. A study released last week from the Joint Economic Committee Democrats in Congress found Black and Hispanic Americans are more than twice as likely as white Americans to be unbanked or underbanked. Similarly, families at the bottom of the income distribution are more than six times as likely as families at the top of the distribution to be among the unbanked or underbanked. In 2021, 46% of Black Americans and 37% of Hispanic Americans reported that they had been denied credit or were approved for less credit than requested, compared to less than 25% of white Americans. Evidence shows that while new financial technologies show less bias than face-to-face lenders, they fail to eliminate discrimination.

Social Change with Transformational Deposits

The year 2020 ended up becoming the moment that provided the fuel for Betancourt’s credit union fire. Between the racial disparities laid bare by the COVID-19 pandemic, and the racial reckoning sparked by George Floyd, Breonna Taylor and other Black people killed at the hands of police, individuals and corporations were looking for something to do in response. One of the options that emerged was moving money into Black banks and credit unions.

Hope Credit Union received a $10 million deposit from Netflix and another $10 million deposit from PayPal, on the way to raising $100 million in deposits from corporations and philanthropy. CEO Bill Bynum started telling corporations his credit union actually didn’t need any more, but he could refer them to others like Betancourt who were looking to secure such big dollar corporate deposits — which Bynum started calling “transformational deposits.” They aren’t donations. These are part of the large pots of money that all corporations keep around on their balance sheets as part of managing their finances, but historically they’ve left those deposits in big banks or short-term Wall Street investments.

Finding Capital

But Betancourt needed more than just transformational deposits to charter a new credit union. Federal regulators require depository institutions to set aside a small portion of cash as a cushion against potential losses. For banks the minimum is $1 set aside for every $11 in assets, for credit unions it’s $1 set aside for every $16 in assets. New banks typically raise that initial small portion of cash from their shareholders. New credit unions can’t do that. So Community First Fund instead launched a capital campaign, in the traditional sense of a nonprofit or church group capital campaign in which donors are asked to make multi-year pledges.

For every corporation that called about making a transformational deposit, Betancourt also approached them about making a multi-year pledge as part of Community First Fund Credit Union’s capital campaign. And of course Community First Fund went around to its long list of previous donors to see who else might be interested in contributing to the capital campaign. A pledge of $500,000 could be spread out over five years, as $100,000 a year in retained earnings for the credit union to set aside as part of its regulatory requirements.

A Wealthy Donor

Community First Fund might have needed more time were it not for MacKenzie Scott’s surprise $10 million donation to the nonprofit, $2 million of which it plowed into the capital campaign for the new credit union. Thanks to the capital campaign pledges, stretched out over as many as five years, the new credit union projects it will have positive net income starting from year one. That’s unusual for any new depository institution, most of which anticipate negative net income during the first few years of getting up and running.

With its target customer base, letters of intent for transformational deposits and capital campaign pledge letters, not to mention its decades of experience making 5,592 small business loans and counting, Community First Fund submitted all of that as part of its charter application to the National Credit Union Administration in December 2020. The agency approved the application in just six months — lightning speed by normal chartering standards.

Since then, Community First Fund converted its headquarters into its first credit union branch, serving the Lancaster metropolitan area’s 550,000 residents. The credit union eventually plans to open six total branches and also leverage online and mobile banking to serve Community First Fund’s entire footprint, which now includes Philadelphia and crosses state lines into Delaware and parts of New Jersey.

The loan fund will continue to do what it has been doing, providing loans to underserved business owners, 71% of whom so far have been people of color. But now it has an affiliated credit union as a way to meet those requests for home mortgages, auto loans, emergency loans and other personal loan requests from its existing borrowers and their networks.

A Credit Union in the Neighborhood: “It Just Makes Sense”

“I’m so happy that they got the new credit union,” Rodriguez says. “It’s almost like the old way, you know, where you had a bank in the neighborhood and it knew everybody in the neighborhood and you knew the bank was there to help you. I believe every client that they ever had will open up an account there. It just makes sense.”

 

 

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The Harm from an Absence of a Cooperative Policy Framework (Part II of II)

Yesterday (August 29) a press release from the North Dakota Credit Union League described NCUA’s turning a deaf ear to their request for their credit union members’ $10 million pro rata share of US Central’s AME surplus.

The final total may actually exceed $12.7 million based on NCUA’s March 2022 AME projected US Central distributions.

The NCUA’s Claim receipt states:  Upon final liquidation of the USC liquidation estate, this claim receipt will enable you to share  in the net proceeds, if any, to the extent of your PIC and MCA balances as of the record date.  No further action is required on your part to file or activate a liquidation claim.

The Dakota League’s title says it all: Time for NCUA to Do the Right Thing.  Its release points out Iowa credit unions are in the same situation. One might also ask how are all the corporate member shares of credit unions who were merged before AME payouts began being distributed? (example, Constitution Corporate)

Moreover, all credit unions  are still waiting for an update on the remaining $451 million of the reported $846 AME surpluses as of March 31, 2022.

These are just the most recent examples in which NCUA seems indifferent to its responsibilities to put credit unions and their members’ interests first.  This “me-first” approach is not lost on credit unions’ own activities.

Members’ Best Interests No Longer?

Lacking a cooperative policy framework, NCUA claims it is powerless when obvious conflicts of interest and direct subordination of fiduciary responsibilities by boards occur.   The members’ best interests becomes a forgotten standard.

For example, consultants overtly market “change of control” clauses for CEO’ contracts, a perverse interpretation of its real intent since coop CEO’s are the ones who initiate their own mergers.  The most recent example is a $750,000 payment in the merger of Global Credit Union. CEO contracts are a board responsibility.

A CEO and chair transferred $10 million of member equity to a private foundation they alone created upon merging.  The foundation is to be financed by another $2.5 million from the ongoing credit union-a clear conflict of interest. NCUA routinely approved this diversion of members’ equity to private party’s control.

Without a cooperative policy framework, the NCUA’s only test of a credit union’s sustainability is financial.  This is the “safety and soundness” mantra.

That standard is similar to saying that a person’s character and contribution is measured solely by their wealth. That is the value-agnostic success criteria that animates much of the capitalist system.

This policy vacuum undermines the unique advantages of the cooperative model and its long term safety and soundness.  Members become customers with profitability profiles.   A credit union’s resilience is nothing more than a quarterly tracking of net worth trends.

Soundness requires continual investments in members’ best interest, not merely fulfilling management’s personal ambitions.  A regulatory framework for cooperatives should be a collaborative effort.  It is not an NCUA internal task responsibility alone, like a budget, to be put out for comment.

Policy  would address current operational  issues that threaten the system’s character and integrity.  It will entail provocative conservations about current topics such as:

  • mergers of sound credit unions
  • the regulatory hurdles and lack of new charters
  • the suppression of members’ ability to vote for directors
  • the absence of member transparency on consequential decisions such as buying banks or adding ten-year debt/capital notes
  • reducing real regulatory burdens and enhancing NCUA transparency
  • the roles of CLF and NCUSIF-distinctly cooperative institutions reliant on credit union funding.
  • Increasing required disclosures for all credit unions including salaries for all federal credit union’s senior executives as is now required for state charters.

One outcome might even be a cooperative scorecard which would assess each credit union’s use of their charter’s unique abilities.

Not Perfection, but Setting Directions

A policy framework does not mean all the resulting regulatory judgments or approvals will be  uniform.   A regulatory framework should encourage better decisions  supported by objective data as well as the cooperative and legal documented processes of fiduciary oversight and care.  Conflicts of interest should be called out.

Experience suggests policy outcomes may be like the biblical parable of “weeds and wheat” grown together. That’s a risk but less so than the “anything goes” practices today.

Credit unions are and always will be a combination of good intentions and variable performance. They are run by human beings. Not all choices will be perfect. This mixed bag is the reality of freedom.

Both credit union leaders and regulators make mistakes. It is acknowledging when that happens.  Then  learning from the event, not defending the errors.

This mixed reality doesn’t mean regulators and credit unions can avoid the diligence and accountability that should characterize credit union decisions.  It’s not okay for self-interest to be the dominant standard for an action.

All are free to make mistakes and sometimes fail, but that does not mean there are no standards to be followed.

Cooperative assessments are important for another reason.  Credit unions, unlike their competitors, are not subject to the market’s daily judgments of management’s actions.   Coops lack bank’s  external check and balance on institutional performance whether through daily stock price fluctuations or the oversight of private ownership interests.

If cooperative standards are not part of the movement’s culture, then credit unions will tend to become just another financial option increasingly indistinct in a crowded marketplace. This will lead Congress to ask why this system should retain the tax exemption that would appear to be their only defining advantage.

The cooperative framework should enhance the never-ending task of credit unions becoming better cooperatives.  Nobody is perfect.  But reducing regulatory oversight to a standard that says  7% versus 14% net worth is better at meeting members’ needs is shallow and unhelpful.

Developing a Cooperative Policy Framework

In 1984 the credit union system redesigned its share insurance fund following 18 months of study, comment, and public dialogue about future options.  The recommended changes then required congressional approval.

This success was the product of extensive collaboration and interaction at every  level of the credit union system.  This effort was described in this brief introduction of NCUA’s implementation video by then chairman, Ed Callahan:

(https://www.youtube.com/watch?v=YjD0y6WRzOo)

A cooperative policy process should be collaborative, transparent and yes, controversial.  It should be democratic, public  and seek consensus on shared interests. Policy must encourage credit unions as communities of possibilities, not conformity.

An Alternative Path?

Without this policy framework, continuing examples of a “race to the bottom” business practices may put all credit unions on a path similar to the S&L industry with no turning back.

That does not mean credit unions (taxed or not) will disappear.   But it does suggest their separate regulatory apparatus will be absorbed by the FDIC, OCC and the FED. This is where the 602 institutions and $1.5 trillion savings industry is now regulated.

Why have a separate NCUA cooperative regulatory system if all it does is mimic the banking model?

 

 

 

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An Exchange On Credit Union and DEI Focus

In response to the August 8th post by Jim Blaine, (Deification: The Eighth Wonder of the Cooperative World) there was the following exchange between Jim and a reader. 

I believe their insights are very helpful for this topic.

  1. Chip,

    I’ve been waiting for people smarter than me to comment… I know they’re out there!

    My observation is that if you do the Seven Cooperative Principles right, DEI feels like it’s already built in. Raising DEI as an Eighth Principle seems like we need a collective kick in the butt for not getting the first seven properly implemented!

    Far from dismissing the idea, I see this as a challenge we need to take on. If anyone, either within the movement, or on the outside, isn’t feeling it, then it MUST be raised up – but not as a revolutionary new principle for us to debate, but as an EVOLUTIONARY opportunity to fix what’s already in place.

    Too many people are feeling disenfranchised these days, and the view from my soapbox is that credit unions specifically, and cooperatives generally, are the best way to restore power back in the hands of the people.

    By all means, credit unions should raise the DEI issue – not as a “checklist” item – “here’s our position in response to this issue” – but as a challenge to their own leadership, their staff, their members, and their communities, to GET INVOLVED.

    Our grounding principles are solid. If we erred in the how we built on them, we need that diversity and inclusivity to drive our evolution.

    P.S. I recommend the writings of Ray Dalio (don’t settle for watching him on the financial channels; really dig in to his 3 “Principles” books). I’m also a fan of Israeli historian Yuval Harari (3 books), as well as French economist Thomas Piketty for his work on participative socialism, and Thomas Hobbes for his ideas on the social contract… he was too late to save the heads Charles I, or Cromwell, but Charles II learned a few things.

    We seem to have lost that social contract, and have allowed a much larger Leviathan to form.

    Reply

  2. Leo, may I recommend a book to you – “Jesus and the Disinherited” by Howard Thurman. It’s a short read and don’t be put off by the title if you’re not religious. If you’re black you should read it, if you’re white you must.

    But, it is far more than just another sermon about race relations in the U.S. It is about the often dehumanizing psychology underlying any relationship between those with power and those without – an “unbalanced” equation which, in the economic world, credit unions were created to address.

    So many of our cooperative leaders seem to have loss sight of that original thought, that original principle. A financial cooperative with a social purpose is not a bank, nor should it be. Without a social purpose….?

    “Life is not the way it should be, it is the way it is”… with our task growing larger daily, perhaps we shouldn’t rest on our laurels – nor our principles.

    Hope you will take a look at what Howard Thurman has to say about all of us, including you and me…and credit unions.

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Leadership: Woven from a Different Fabric

(from Jim Blaine)

It’s a bit difficult to explain to folks who never met him, what “a force of nature” Ed Callahan was as a person. 

 He had an unusual instinct for listening to difficult issues, considering alternatives and options, and then “cutting to the chase”- clearly, decisively, on-point.


When leaving his position as NCUA Chair in 1984, he wrote a “Farewell Address” to President Regan about his view of the credit union movement. 

For those looking for a defense against unnecessary taxation, a rebuke against inept and intrusive regulation, or a simple, concise statement of the hope and promise of “the credit union alternative”, Ed Callahan’s message still rings true:

“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.”

“Credit union boards of directors have made, and will continue to make, individual and collective decisions from their vantage point on the front lines of the marketplace.”

“When left alone, they return to what they do best; providing basic financial services to their members on the most convenient and cost-effective terms possible.”

Credit Unions: Woven From A Different Fabric.

(Originally published July 2013)

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Abraham Lincoln and the Challenge Facing the Credit Union Cooperative Movement

In the Gettysburg Address Lincoln summarized the ever-present challenge of keeping alive the spirit of a  revolution’s  original intent.

Dr. Eva Braun’s essay describes Lincoln’s grasp of the declining motivation of later followers in his Gettysburg speech:

From Dr. Braun’s  analysis: Lincoln begins, “Four score and seven years ago.” “Four score,” With its long oh’s, sounds a more mournful, solemn note than could the words “eighty-seven years,” but the choice of the phrase is not only a matter of sound; it also carries a special meaning. It is the language of the Bible, as in Psalm 90:10:

The days of our years are threescore years and ten; and if by reason of strength they be fourscore years, yet is their strength labour and sorrow; for it is soon cut off, and we fly away.

With the psalm in mind the phrase implies: just beyond the memory of anyone now alive, too long ago for living memory.

Now, we know that from youth on Lincoln was concerned with a peculiarly American danger: the death of sound political passion. In his speech on “The Perpetuation of our Political Institutions,” of 1838, Lincoln drew a clear parallel with the early community of Christians, whose danger lay in the fact that the generation of disciples and eye-witnesses had been followed by a second generation which had only heard by word of mouth, by a third which had only read of Christ, and by a fourth which had begun to forget.

So in the American community; the scenes of the revolution, he said, “cannot be so universally known, nor so vividly felt, as they were by the generation just gone to rest.”  The men who had seen the Revolution, who were its “living history” are now gone.

“Beginning to Forget”  A Peculiarly American Habit

Remembering the contributions of earlier credit union founders is vital. Last week Jim Blaine described the legacy of Ralph Swoboda. As CUNA General Counsel and then President, he helped transform the movement through two system-wide challenges: business modernization and deregulation.

While leading NCUA in the early 1980’s, Ed Callahan and Bucky Sebastian in their presentations promoting deregulation would cite the original practice of common bond going back to the early years of state chartering.   They pointed out that some of the first fields of membership were often city-wide.  The intent was to be inclusive, not limiting,  for those who sought a cooperative financial choice.

But this reference to the spirit of the cooperative founders, where purpose surmounted existential challenges, can  dissipate as the “living history” passes on.

We cannot resurrect those who have left the playing field. But we can certainly rekindle passion for member advocacy in all its cooperative possibilities.   And in the process keep the “movement” alive.

The Current Challenge

When a motivated popular movement aligns itself with another cause to promote its  agenda, the hybrid effort can pervert its primary purpose.

An example is the tying of Christian nationalism with white nationalism.  Christianity becomes less about faith and more about political power.

A parallel confluence of activity is occurring in credit unions.  Since the imposition of PCA in 1998 through the Credit Union Membership Access Act, NCUA has increasingly equated credit union oversight  with banking practice.

The latest effort is the imposition of RBC/CCULR completely incorporating the full bank regulation in its rule. This embrace of banking models, a frequent standard cited by Chairman Harper, also includes the promotion of external capital.  It neglects the unique capabilities of cooperative design.

Collaborative institutions include the CLF and NCUSIF, both under NCUA management. CLF’s role is moribund.  As for the NCUSIF, NCUA has converted the insurer into an open-ended funding draw for the agency’s daily operations.

Another example of cooperative diminution is NCUA’s lockdown of the corporate network, especially its services for smaller credit unions.

Credit unions have read the regulatory signals.  “Treat us like banks, and we will follow that industry’s lead.”  Mergers, not collaboration, become a priority growth strategy.  Bank purchases, paying premiums to bank owners with credit union member capital, is promoted as an immediate expansion opportunity. In other words, “If we can’t beat ‘em, let’s just buy ‘em.”

The regulators are silent. As long as credit unions’ financials mirror bank’s, everything is OK.  Mergers, bank purchases and novel (SPAC) growth tactics are just the free market at work. Even when a CEO and Chair transfer $10 million of members’ funds to their control following a merger.

Let me be clear that these are not the actions of the majority of credit unions, but they  dominate the headlines.

Losing Faith

The credit union system’s unique capacities are simplified to  safety and soundness, defined by ROA and net worth with a dollop of growth thrown in.  Purpose becomes dressed as creative public relations campaigns and promotional branding efforts.

An example of this waywardness is VyStar Credit Union.  A member forwarded their most recent assessment of its recent flawed digital channel conversion:

In regards to VyStar, we have decided to move our account to another credit union.

Facebook posts (https://www.facebook.com/VyStarCU) have certainly slowed down.  I do not know if it is due to apathy or is X number of people who have just gone to other financial  institutions.

Login online has greatly improved.  There is little to no wait time.

They updated the mobile app on June 26th.  Many people had difficulty getting on the app, especially the android version.  

Getting a hold of someone in customer service is very difficult at best.  Very long wait times on the phone (in excess of two hours).  You can log into chat, I had almost an hour wait the other day.  While they have now added internal transfers, you still cannot do member to member (linked account) transfers (like to other family members).  You can only transfer funds internally within your savings, checking, MMA, etc.  

You still cannot see any account history prior to 05/13/2020 which was the day they shut down the system they used prior to the current one.  

You no longer get copies of your checks written online as before.  

I see no “Improvements” or new features in the new system whatsoever.  The new bill pay is cumbersome and not user friendly.  I filled in the bill payees into our new credit union with ease, it is almost exactly what  we used to have at VyStar before this poor unsatisfactory installation.  

Lastly, and most disappointingly, is the fact that the CEO has still not addressed the members directly.  I know of no statement to the press since about May 23rd.

I have no idea how many members have left and I am not sure we will ever know.  I hate leaving but, I have lost faith in them.

A Two-Way Street

The fundamental flaw in VyStar’s strategy is not a bungled conversion.  Many conversions have temporary problems.   Rather it is VyStar’s strategy that credit union membership is a one-way street.   Members just transact and are viewed as customers, not owners.  There is no respect for members’ “faith” which is the primary foundation for any credit union’s long-term success.

A two-way street means the owner’s role is understood, honored and continually enhanced.  The primary means  is seeking to expand the multiple ways value is created for members, especially those who have the least or know the least.

A Member Advocate

The credit union model is foremost an advocate for members’ well-being.   That was the original intent.

The vibe at VyStar is all about the institution and its size. This is a sentence from an April 2022 merger announcement before the digital debacle:  VyStar, which has more than 800,000 members and over $12 billion in assets, will remain the 14th-largest credit union in the country by asset size.

When the member relationship is always front and center, the owners return much more than transactions.  They give their loyalty, patience when necessary, and word of mouth endorsements with friends and family.

That was how the credit union movement achieved their current $2.3 trillion position while serving the fourth or fifth generation of members.   Members’ contributions are paid forward to benefit future members.

For the founding members’ spirit of purpose to prevail, it must  be constantly renewed in the words and actions of those leading cooperative charters now.

 

 

 

 

 

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Credit Unions and Small Town America

(This is an observation based on three previous write-ups about my 60th high school reunion.)

My reunion visit to Rensselaer, IN (pop.6,000) had some surprises beyond the high school alumni gathering.

Ten years before (2012), the town’s main street seemed in decline.  New school buildings, a strip mall with a Walmart and several assembly/distribution  plants were located on the outskirts, not in town.

In 2017  St. Joseph College closed due to financial shortfalls.  The college served as the creative ying to the farming yang of the community.  What could replace this intellectual and institutional resource?

The Changed Environment-Ten years Later

At the Rensselaer City Council’s June 21st meeting a presentation was made from a firm which specializes in attracting  new residents to smaller communities to support economic development.  This is  from  the Rensselaer blogspot report of that proposal:

A company called MakeMyMove gave a lengthy presentation to the Council. The company, based in Indianapolis, is a marketplace that connects communities with workers who work remotely. So far this year they have helped 14 Indiana communities with 52 relocations with 59 others being processed. The idea is that a community pays MakeMyMove about $35,000 to prepare a marketing package and a listing on their site. The community also prepares an incentive package that usually includes funds for relocation.

The State of Indiana has funds that might be used to help a community with these costs. Some members of the Council were intrigued with the idea but others had reservations about the cost and whether Rensselaer would compare well with the other communities using the service, all of which were bigger than Rensselaer.

The community that was given as a comparison was Greensburg, which is about twice our size. The proposal was taken under advisement, and what happens next is unclear.

The National Movement to Smaller Communities

At the same moment the Wall Street Journal published a story with a similar theme: Rural Counties are Booming, But Can it Last?

The article pointed out that pre-pandemic, rural areas were growing slower and losing population compared to larger towns and  cities.  Those trends have now reversed for a number of small towns as related in the article:

  • Rural counties saw a net gain in population in the twelve months ending June 2021;
  • Remote work possibilities were an important driver of these relocations;
  • Job postings in rural areas increased 52% in the three years ending 2021;
  • Wages were growing faster in rural (6.3%) versus urban (5.7%) areas  in the same three years;
  • Housing is much more affordable in smaller towns;
  • Persons appreciate being part of a tight knit community and still live within commuting distance of bigger cities.

My brief visit to Rensselaer supported many of these advantages.   As shown in my earlier posts, wages are high and workers in short supply.   There are new businesses opening and investment in older ones.

Here are two examples: a new brewery begun in 2017 and since expanded, and continued local ownership of the Ritz Theater first opened in 1925.

The local owner even works the snack and ticket line before the show starts.

The economy is becoming more diversified with new services opening including health care, retirement living, Walmart and new restaurants.    Rensselaer also has three radio stations, two country and one classic rock.

Even though St. Joe college is closed, there are continuous efforts to use the buildings and campus for further education.

The public mural project is an example of a town going through a unique transformation that brings visibility and fresh thinking to visitors and residents.

Rensselaer is driving distant from three major cities, Lafayette (with Purdue University), Indianapolis and Chicago.   The town continues to invest in public infrastructure and new government funded buildings such as the National Guard base, fire station and a government business office.

Credit Unions and Community Transitions: A Home Court Advantage

The origins of credit unions were common bonds, that is people who had pre-exiting relationships  that could  be the basis for pooling  funds to help fellow members.

This  “community” feeling is generally stronger in smaller towns and in rural areas which should make these a natural fit for a credit union, what might be called a home court advantage.

To succeed in these markets will require the same commitment, patience and creativity to support their transformation that  local leaders are providing.  Smaller size is an advantage in smaller markets.

Action Steps

Find out if there are Rensselaer kinds of opportunity in the areas you serve.   To grow larger, most people believe that an organization should seek out bigger markets.  In fact the opposite may be true.

Rensselaer’s five bank branches have an asset base of almost $400 million.  A 6-8% market share of the town’s deposits would be a healthy branch or in some cases support a standalone operation.   Once established, growing that share from out of area bank branches should be possible.

Almost  every state has many more Rensselaers needing credit unions than there will be big city options such as Indianapolis, Gary, South Bends and Evansvilles.

For a number of these smaller markets the quality of life, the cost of living and the opportunity to make a difference will make them an ideal fit for lasting impact with a cooperative charter.

As the sign in the jewelry store said:  Shop local, Buy local. 

 

 

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A VyStar’s Member’s Voice: Loyalty or Naïve?

A reader found my post on VyStar while searching the Internet for information.  Greg gave me permission to publish his experience.

Mr. Filson,

I just thought I’s share a few things with you concerning VyStar Credit Union (VSCU). As you are aware, they have been having trouble getting their “new improved” online banking system and mobile app back up and running. There are four things in this process that are very frustrating:

1. The CEO stated that this system was two years in the making and when they brought it up, the system was overwhelmed. What!? Two years of work have brought VSCU to it knees in a weekend. Didn’t they learn anything from the “new system” they employed in 2016? Did they not think that people would ‘Log On’ in the new system, even if they had no immediate banking need just to ‘see’ what the new features would be?

2. The mobile app (prior to the current debacle) was actually two apps. You had your normal banking app and a card control app. The card control app was a great feature. You could limit the amount to be charged or withdrawn but the greatest feature was you could turn your card on and off. With the card off, no transaction could occur at all. Well, my debit card is turned off. I can’t get cash withdrawals.

3. Transfers and linked accounts. For a while, after the new system was running, I thought it quite strange that you transfer funds to financial institutions outside of VSCU. Internal transfers were not possible (such as from savings to checking). They have since got that restored but there are still no linked accounts. In other words, I can no longer transfer funds to my wife’s checking account, and she can no longer transfer funds to our money market account.

4. Bill pay. I have had two utility bills scheduled to be paid this week. Neither have been paid when I check their websites. When I got a hold of VSCU via chat, I was told that yes, they went out and to not worry about it. Since it is recorded and I have a confirmation number, all is okay. Well, tell that to the utility companies who have not been paid. I paid both with a credit card to avoid late fees and disconnects.

Thank you.

In response to my question of how long he had been a member and when he found the post, he replied:

I have been a member for 35 years.  I joined when I was stationed in Florida.  VSCU has been vitally important in my family’s lives.  We have lived in several states and kept them as our financial institution. From, checking, savings, money market accounts, loans, and credit cards, they have been “ours”.  We now live in Alabama and are retired.  I have now seriously considered leaving VSCU but have been hesitant.  Call it loyalty or naive!

IRT some members have voiced concerns about the BOD in Facebook and voiced opinions about cleaning house.

I have posted on FB about one of the utility bills I mentioned.

As for where I heard about your blog, I stumbled across it.  I did a search on my browser “VyStar Credit Union in the news”.  In the browser search results was “When the music stopped for VyStar…”.  I’m glad I saw it and read it.  That is why I subscribed.

An update on the utility bill:

I have an update on one of my bills.  It was finally paid on the 17th, albeit four days late.  

For credit unions, trust is re-earned every day, even for a member of 40 years.  This goodwill is the foundation of every cooperative’s sustainability.

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Friday Updates

The following are updates from posts this past week.

VyStar’s Challenges: Continuing to Expand in Georgia

Both CU Today and Credit Union Times report that VyStar has called off its $195.7  million purchase of Heritage Southeast Banking Corporation, a holding company for three local banks located outside Atlanta.

The local TV station NEWS4JAX covering the story included the following quote from CEO Brian Wolfburg :  “Following a thorough evaluation of the transaction between VyStar and HSBI, we have mutually agreed that moving forward separately is the prudent decision. VyStar will continue to expand our services in Georgia.”

This Georgia expansion seems tone deaf to the concerns of members in the credit union’s legacy Jacksonville market.  This recovery challenge appears greater than a botched conversion.

There are dozens of comments posted after every NEWS4Jax story:

Mark 2 HRS AGO

It seems that Vystar management made a poor decision with NYMBUS and are having to force it down members (co-owners) throats, regardless of the inconvenience and future inadequacies of software capabilities. The NYMBUS salesperson probably made bundle of commission off of this sales job to Vystar.

BigSwifty500 21 HRS AGO

This story is worthless and full of non-truths. The login page still says it is “temporarily unavailable”. Time to move my accounts elsewhere.

B coffey 2 DAYS AGO

N Y M B U S….this is the name of the company vystar is sharing “relations” with. They performed, designed this mess. Both companies share Board members. Nymbus  is even located in their (Vystars) building in Jax. Vystar is listed as a Nymbus investor. Starting to see a forming problem here?????

john marshall 2 DAYS AGO

This “upgrade” (that isn’t one) ought to be called Wolfburg’s Folly!

Racemedic

Translation: “We know a dumpster fire when we see one and we know to run the other way. Sincerely, HSBI”

Jthall76

Glad I switched to Community First CU

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Crypto Crash: The Selloff in Crypto Assets Resumes (CNBD Disrupter article, June 16)

Bitcoin fell again today as a sell-off in global risk assets resumed, with crypto investors reeling from a dramatic plunge over the last few days that saw the world’s largest cryptocurrency almost drop below $20,000. . .  

Bitcoin is sitting at levels not seen since late 2020. The digital currency is down more than 20% in the last week and has dropped more than 60% from its all-time high in November. . 

The current bear market is often dubbed a new “crypto winter”.  . .

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“Good Angel-Bad Angel”-The House Hearings on January 6th Insurrection

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Should Credit Unions Be Offering Bitcoin and Crypto Currency?

Crypto currencies were supposed to be a store of value that would protect owners from traditional market risks as well as inflation.  Based on  block chain technology, they were intended to avoid the historical problems of fiat currencies backed by governments.

Both roles have now been shown to be faulty.  Here are some recent assessments.

Bitcoin tumbled Wednesday to a new 18-month low, spurring a sharp fall in crypto markets sparked by crypto lender Celsius freezing customer withdrawals. The world’s largest cryptocurrency fell to under $21,000. Bitcoin has lost around 28% since Friday and around 70% from its all-time high in November. (Reuters) 6-15-22

Bill Gates is a  crypto and NFT sceptic.  His latest observation is that the whole enterprise is based on the greater fool theory:

On Tuesday, the billionaire Microsoft co-founder described the phenomenon as something that’s “100% based on greater fool theory,” referring to the idea that overvalued assets will go up in price when there are enough investors willing to pay more for them.

A former crypto believer has written an appraisal of his experience with the title Crypto is Dead-Get out Now.

On May 18, 2022 Washington Post financial writer Michelle Singletary posted an article Six Signs Crypto is a Classic Ponzi Scheme.

CU Today reported that consumers lost more than $1 billion in crypto fraud in 2021 according to the FTC in a June 7 article.

Celebrity Hype and a Trillion in Losses

A critique from Jared Brock identifies the issue for why credit unions should be concerned about their involvement with crypto purchases.  He starts with a question in his June 6 article: Should Matt Damon and Reese Witherspoon Go to Jail for Promoting a Ponzi Scheme?

A trillion dollars in losses requires accountability.

But until two weeks ago, all sorts of celebrities were shilling for their favorite coin — or rather, whichever coin company paid them the most endorsement money.

Matt Damon.

Reese Witherspoon.

LeBron James.

Kim Kardashian.

Charli D’Amelio.

Jamie Foxx.

Paris Hilton.

Ashton Kutcher.

Gwyneth Paltrow.

Tom Brady.

Steph Curry.

Elon Musk.

Mark Cuban.

Tiger Woods.

Larry David.

And dozens more.

They made untold millions by convincing the ignorant public to late-join a Ponzi scheme.

Now they’ve all gone silent.

Because now that the industry is crashing back to reality, real people are losing their shirts.

Call me old-fashioned, but I think someone needs to be held accountable.

Should celebrity crypto boosters go to prison for promoting Ponzi schemes?

Two Credit Union’s Announce Bitcoin Purchase Partnerships

Even with this litany of false hype, fraud, documented  losses and ongoing uncertainties around crypto, several credit unions have moved ahead to facilitate the purchase of these “currencies.”

CU Today on June 13 reported Achieva Credit Union’s involvement with a bitcoin exchange:

Dunedin-based Achieva Credit Union is adding a bitcoin exchange to its mobile app through a partnership with New York-based NYDIG, a fintech platform that partners with mainstream institutions from banks to insurance companies. 

According to the credit union’s website, it is charging a 2% fee for any crypto currency purchased or sold.

Tracy Ingram, chief digital and infrastructure officer, told the Tampa Bay Business Journal that Achieva had noticed more of its members were becoming “crypto-curious.”  

The article also listed other CUs offering crypto services to members:  UNIFY Financial CU, Idaho Central CU, Stanford FCU, and Visions FCU.

The Credit Union Times report on Achieva’s new service described how the employees were asked to try out the new functionality resulting in over $2,500 in Bitcoin purchases. The purpose was to make them “trusted consultants” about the process.

Prior to launching, Achieva employees were invited to test out the new Bitcoin function. The employees who signed up were given $10 to purchase Bitcoin and learn the process. NYDIG also kicked in another $5 for the experiment. During the three-week employee pilot, those Achieva team members purchased more than $2,500 of Bitcoin.

According to Achieva’s Chief Digital and Infrastructure Officer Tracy Ingram,  the employee trial achieved two things: Employees learned how to use the new app and how Bitcoin works in order to help explain everything to members.

“Achieva employees are trusted consultants for members and it was vital that our team learn how this new Bitcoin functionality works so that they can answer questions for members,” Ingram said. “We always want to note that there is risk involved in investing in any cryptocurrency, and we want our members to feel comfortable accessing the trading services.”

Stanford FCU: a “Trusted Institution”

The Stanford FCU press release contained another important issue in its description of its partnership with NYDIG:

NYDIG is proud to partner with Stanford FCU to power its Bitcoin services in a secure and compliant way,” NYDIG Head of Banking Solutions Rahm McDaniel said. “A trusted institution like Stanford FCU wants to ensure the Bitcoin services offered to its clients meet the industry’s highest regulatory, audit and governance standards, and that is exactly what NYDIG provides. We are excited to partner with them to ensure their members have access to the opportunities associated with this emerging technology.”

According to Stanford FCU, the credit union saw nearly 25,000 buy and sell transactions by its members to and from crypto exchanges in 2021.

The Central Issue for Credit Unions

NCUA’s May 2022 letter in essence approved these types of partnerships but did not address one of their most frequent functions-purchasing crypto currencies.

Instead NCUA obfuscated the issue by talking about Distributed Ledger Technology.  For example:  As with the development of any new product or service, when deploying a platform, product, or service using DLT as part of the underlying technology, credit unions should find an appropriate balance between the opportunities and the risks.

DLT is not the same as crypto currencies which are based on this technology.  NCUA approved a practice of questionable purpose and uncertain value because of the underlying technology.  From many perspectives, purchasing crypto currencies is nothing more than gambling.

If NCUA did not understand the import of its letter, than how can credit unions avoid the marketing hype and celebrity marketing of this form of financial entertainment?  Not to mention the “crypto-curious” members?

In both credit union press announcements. NYDIG, the exchange and fintech partner, is relying on the trusted relationships and reputation of these two credit unions and their employees to not only offer, but also promote Bitcoin transactions.

I would just repeat the observations of Jared Brock above:

Call me old-fashioned, but I think someone needs to be held accountable.

Should celebrity crypto boosters (insert credit unions) go to prison for promoting Ponzi schemes?

In a future blog I will describe block chain, or distributed ledger technology, and how it might be useful for other purposes, not NFT’s and crypto currencies.