In this latest test of political masculinity in Washington DC, the federal government has shut down.
NCUA says it is still open for business. As evidence the agency reissued this guidance from over 14 years ago:
This test of political will and messaging on both sides has an open-ended feeling about it. No one knows for how long or at what cost this standoff will continue.
This event and its aftermaths will only add to the many economic, financial and consumer uncertainties now infecting future outcomes.
This is not the first era of credit union’s navigating broad events outside their control. Recalling previous periods of change can remind that one of the most useful responses is to have options–not merely hunker down to weather the storms.
When Options Matter
The headline reads: Federal Credit Unions Eyeing State Charters as Rate Ceiling Hurts. It is from the Business & Finance section of the January 18, 1980 edition of the Washington Star newspaper.
The opening paragraphs:
Some federally chartered credit unions are trying to switch to state charters because the government’s 12 percent interest rate ceiling is shutting down their loan business. . .
In the last year, the 12 percent ceiling on loans has either shut down lending at some credit unions or generally restricted granting of loans in others.
Energizing the Options-NOW
Leadership is the art of changing before you have to. The Trump administration’s one consistent theme is disruption, if not the destruction, of traditional government functions.
Recently in an NCUA board meeting the single member Kyle Hauptman suggested that it was possible the agency might have no board members in the future.
Whether that was just a hypothetical musing or confirming his interest in another government position is unknown.
But assume that scenario. No board at NCUA. What would the administration do? What it has done with other vacancies, appoint an “acting Chairman” likely from Treasury. And then begin a process of assimilation like the OCC under that Department for the agency’s future.
Just one of many possibilities created when the status quo is not longer as political checks and balances are completely gone.
To protect the independence, integrity and unique role of credit unions, it may be necessary to go back to where the movement started and gained its credibility–the state chartered system.
State regulators (NASCUS), state insurance options, trade associations and every credit union, whether state or federal, should now be assessing the ability of the states to be their primary regulatory choice.
It is critical to reinvigorate the state chartering system as a real option as the federal government and NCUA seem to be careening away from any stable leadership and certain future.
Credit unions created the dual chartering system that has evolved into serving tens of milions owners. It may end up being their best hope for the future. That is just one history lesson from the 1980’s.

We live in odd times.
hashtag#CEOs, I know you’ve had frustrating encounters with auditors and regulators. They can feel burdensome, even annoying. But this latest move from National Credit Union Administration (NCUA) isn’t a win for the reduction of “regulatory burden”—it’s something far more concerning.
Although the headlines highlight the elimination of reputation risk, please read further. In addition to eliminating reputation risk as a rating, NCUA has discontinued assigning ratings to all seven risk categories:
• Credit
• Interest Rate
• Liquidity
• Transaction
• Compliance
• Reputation
• Strategic
Imagine someone removing all the smoke detectors from your building and telling you, “Don’t worry, we’ll let you know when we see fire.”
The purpose of these risk ratings was never busywork. At the aggregate level, they provided field offices, regions, and national leadership with a top-down view of where risk was accumulating. From a staffing standpoint, if a credit union’s liquidity risk was rated high, it signaled the need for additional expertise at the next examination.
Examiners and ERM professionals assess each category based on quantity, direction, and the quality of risk management. The point was never to penalize higher-risk profiles. It was to ensure that if you accepted a higher risk, your management practices were robust enough to handle it.
America’s Credit Unions, NASCUS, and American Association of Credit Union Leagues
How is this a win for the members and the safety and soundness of credit unions? Why do we only hear about tax status, and none of these moves requested are discussed with the same intensity?
A couple of foot notes: NCUA Credit Risk Webinar
On July 15, 2025, in an NCUA (https://lnkd.in/ednAJjCE) credit risk webinar, an examiner (Min 13:49) discussed the benefits of key concepts like risk appetite, risk tolerance, and risk capacity. Those are excellent tools for boards and executives. They’re the backbone of modern ERM.
But here’s the contradiction: NCUA is now saying those concepts are helpful for credit unions to adopt, while simultaneously discontinuing examiner use of risk ratings for the seven categories (credit, liquidity, interest rate, compliance, transaction, reputation, and strategic).
National Credit Union Administration:
Additional Actions Needed to Strengthen Oversight
On Sept. 23, 2021, the Government Accountability Office issued a report stating NCUA has opportunities to improve its use of supervisory information to address deteriorating credit unions. By more fully leveraging the additional predictive value of the CAMEL component ratings, NCUA could take earlier, targeted supervisory action to help address credit union risks and mitigate losses to the NCUSIF. As of today, one of the recommendations is still open, and another is partially addressed.
END
As Hauptman tries to burnish his reputation with the administration’s anti-government ideology, the dangers of a single political point of view determining regulatory priorities in a so-called independent agency becomes clear.
This press release is not about ensuring the safety and soundness of members’ funds or enhancing the cooperative systems critical roles. It is simply posturing for another assignment in an administration bent on governmental disruption.
The financial and institutional integrity of the cooperative system requires a competent, active regulatory oversight. Institutions that manage financial assets for others are especially vulnerable to self-dealing. That is why almost every form of money lending, transfer, safe-keeping and advice is subject to governmental licensing and oversight.
Without effective supervision not only will credit unions continue to be lost, the playing field will become crowded with internal and external predators trying to cash in on the abdication of, and disrespect for, regulatory oversight.