Three Observations on Sound Credit Union Mergers

Members Vote Against Merger

From the May 24th CUToday story:   In a rare development, members of Hoosier Hills Credit Union have rejected a merger with Centra Credit Union. The two credit unions had announced in January  their plan to combine to create a CU with more than $3 billion in assets. 

The credit unions said in a joint statement that “despite extensive communication from Hoosier Hills outlining the factual details of the merger, the vote was impacted by the circulation of misinformation.”

The credit unions did not say what that misinformation consisted of. The vote tally was not released.  

Why did members reject this merger? Here is a post on LinkIn by Hoosier Hills CEO Travis Markley, based on a Forbes article dated June 20, 2023 about the credit union.  The merger was announced six months later.

“Amazed and humbled to be a part of this organization and everything we do for our members, and so proud of the dedicated staff that make it possible!

“Hoosier Hills Credit Union is honored to be recognized by Forbes as one of the three Best-In-State Credit Unions in Indiana for 2023, joined by our friends at Interra Credit Union and FORUM Credit Union.

“This award, the result of an independent survey conducted by Statista, was based eighty percent on feedback from 31,000 US consumers, who rated their credit unions on criteria such as trust, branch and digital services, customer service, fee transparency, and financial advice. Twenty percent of the scoring was attributed to publicly available Google Reviews from the past three years.

“We are honored to serve our members, and appreciate this special recognition, which we could not have achieved without the dedication and character of our team at all levels,” states Travis Markley, CEO at Hoosier Hills. “Our knowledgeable and caring staff is committed to carrying out our company’s mission and continues to put the needs of our members and communities at the center of every decision we make and every action we take.”

This Merger Process Seems Suspect

Very soon after this positive external recognition, the merger process started.  The CEO would become the Chief Experience Officer of the new combined entity.

What is even more curious is that the merger proposal posted on NCUA’s website for comment says that Centra is merging “with and into” Hoosier Hills Credit Union, not the other way round as implied in the CUToday article. The Centra Chairperson, Jim Bickel signed the merger plan sent to members (whose?) on November 1, 2023 or five months after the Forbes “best” ranking for Hoosier Hills.

In this Centra notice to members there is an effective date of the merger of July 1, 2024. However, the credit union being merged is North Park, not Hoosier Hills.

This entire episode needs a good hard look by state and federal regulators as the documentation and explanations appear questionable.  There is reference to a detailed merger plan by Centra, but it is not included in the required posting even though the letter states it is enclosed with the Notice to Members.

This example reminds me of a recent post by credit union consultant and former OCC examiner Ancin Cooley.

Mergers are Feeling “Icky”

By Ancin Cooley

Is anyone else beginning to feel a little “icky” about the current merger frenzy in the credit union industry? Something about these transactions just doesn’t sit well in my spirit. . . what do credit union members get for their capital and assets when they merge?

Here’s an excerpt from a recent merger disclosure:

“Members will have access to more branches, a 24/7 call center, industry-leading online and mobile banking services, and will still receive the personal service they enjoy from the same employees they rely on every day.” 

This feels “icky” to me. The credit union I mention below is giving the acquiring credit union 7 million dollars in exchange for no board seats.

Would you give me your house in exchange for my cutting your grass?

The Game

And let me be clear: I do not think the individuals involved are bad people. The game is the game. If the cooperative movement is ever going to survive, it needs to be “guarded” by individuals who believe in its purpose. If your credit union or any cooperative has “unguarded” capital, someone will come and take it.

A Case Study

I’m reviewing the financials of a credit union set to merge as of May 1, 2024. The CEO, who has been there for over 20 years, inherited a credit union with over 16% in capital. By 2015, they ventured into indirect lending, and by 2019, it represented 60% of their total loan volume.

This credit union’s financial health started heavily declining two years ago. I’d be willing to bet that is right around when this CEO started looking for a merger partner. Indirect charge-offs were well over $600,000 last quarter. . . ending with a 7% capital ratio. This credit union was not lost due to technology, costs, or economies of scale. This was bad management and weak governance.

So, this person drives the credit union into the ground, receives a hefty retirement payout from the acquiring credit union, and retires happily. Ick… If you couldn’t earn a performance bonus payout while functioning as the CEO, getting one on the backend of a merger you brought to your Board doesn’t sit well with me.

Where are all the other voices? Where are all the credit union governance experts? Even if you disagree, please point out any errors in my logic or perspective. Don’t discuss this in small circles over dinner. Stop treating credit union capital like you invested in the organization with money out of your pocket.

What Are the Principles?

The evolving landscape of credit union mergers should invite deep personal introspection and discussion on the future of cooperative movements. Are these mergers truly beneficial for all stakeholders involved? Do they warrant a closer examination of the principles guiding such transactions?

Lastly, humans in general, often value relationships with people in close proximity to them vs. folks they don’t know. This manifests itself when directors, close to management, struggle to hold their executive teams accountable.

In the example of this post, if I named that CEO, I’d face more backlash than him or her for running the credit union into the ground.

Why is all this happening?

1) Because we value personal relationships over the member-owners of the cooperative movement. Some very smart and shrewd folks realized this years ago. Once the “old school” credit union folks passed away, it became a market free-for-all.

2) Where else are you gonna get 7 million dollars on a promise for better services? There’s too much money involved and not enough incentive to stop.

The only thing that could turn the tide is if some well-respected CEOs (and consultants) in the industry begin speaking up more. We may well continue to lose at least 15 credit unions per quarter for the next year or so. On my end, I’ll focus my energy on helping credit unions that want to grow, turn a profit, and keep their charters.    END

Another Interpretation of Credit Unions’ Personal Deal-making

The motivation for these so-called mergers of sound credit unions may have been best summarized by the well-known American entrepreneur, Al Capone who said: This American system of ours, call it Americanism, call it capitalism, call it what you will (cooperative mergers), gives each and every one of us a great opportunity if we only seize it with both hands and make the most of it.”

 

 

 

An Homage:  Report on Credit Unions

An independent press is essential for democratic governance, whatever the scope or responsibility of an organization or political entity.

Report on Credit Unions was in its twenty-fifth year in 1982.  The editors and contributors to the monthly printed publication were a who’s who within credit unions.

The publication’s founder was Rudolph Modley who “was born in Austria and earned a Doctor of Law degree at the University of Vienna. He came to this country in 1930 and in 1937 published the first of several hooks, “How to Use Pictorial Statistics.” In 1940 he was the coauthor of a study of the American system, with Thomas R. Carskadon, entitled “U.S.A.: Measure of a Nation.”

As described in his New York Times obituary: “Mr. Modley was also interested in the credit‐union movement and in 1957 founded the monthly publication “Report on Credit Unions.”

The staff and contributors listed on the January 1982 masthead (vol. XXI no. 1) were Larry Blanchard, editor; Frank Wielga and Jo Ann Ewalt, assistant editors.  The contributors J. Deane Gannon (former Administrator, Bureau of Credit Unions), Mandy Hellie, League President,  Kenneth Marin (former CUNA Chair) and Harold Black, one of the first three members of the NCUA board.  All had senior positions in the movement.

The News In January 1982

The lead story was the departure of Larry Connell from the NCUA board to become president and ceo of Washington Mutual Savings Bank, a $2.3 billion thrift based in Seattle.  The story quotes Connell’s farewell comments, “I’ll be back” and Ed Callahan who said, “Larry had done great things with this agency during his tenure.  . . he will be sorely missed.”

The six-page newsletter announced the appointment of former NCUA Board member Harold Black as an associate editor.   In his first “commentary” he wrote why he opposed Senator Garn’s bill (S. 1721)  which would have combined the FDIC, FSLIC and NCUSIF into a single fund.  Many of his points are still relevant today as the current NCUA chair seeks to convert the NCUSIF to be more FDIC-like.

This first edition of 1982 included articles on the upcoming speakers for the CUNA and NAFCU governmental affairs conferences, updates on insurance for IRA accounts, NCUA’s “dramatic deregulation concept,”  CUNA’s capitalization study, the accounting practice of ICU’s two common trust investments, how credit union owned data processor USERS “outranked the competition,” and a full page of individual credit union updates, From the Grass Roots.

The Report’s Purpose

As stated in the Harold Black appointment, “the Report has adhered to a strict policy of independent coverage, focusing on operational, legal, economic and general news for credit union volunteers and professionals. Its editors, assistant and associate editors are all drawn from the credit union community.”

The editorial standard in the Report helped to spawn an era of industry focused newsletters included CUIS (Credit Union Information Service) weekly mailed updates from the trade associations and leagues and the occasional private newsletter.

The quality of writing influenced these other publications including the monthly Credit Union Magazine and later iterations such as Callahan’s Credit Union Report.

The Report stands out for its comprehensiveness, longevity and singular focus on the industry.   NCUA upgraded its own publications creating NCUA News as a monthly.

The NCUA Chair and senior staff would hold public press conferences after each board meeting to talk with reporters.  Topics were open ended.  For example in July 1982: how would the Agency respond to the closing of Penn Square Bank and the losses credit unions might have on CD’s over the $100,000 insurance coverage?

The Impact of Quality

The Report set the standard for relevant, in depth factual analysis and commentary for the credit union community.  Its writers knew their subject matter.  They had access to senior leadership when reporting on sensitive topics such as the accounting for ICU funds.

The Report is an excellent, high level chronology of key events and personalities on the credit union stage in each edition.  Its success was due to the quality of its staff. It is a tribute to Larry Blanchard who maintained this approach during his tenure.

Ultimately more colorful, more timely (weekly) and ad-supported entrants, Credit Union Times and Credit Union News, pushed the monthly subscription model off center stage.

But this example of dedicated focused journalism and independent reporting is still the standard even in today’s digital era.   The Report raised all credit union coverage to a higher level of excellence while becoming  the “go to” source for capturing the first draft of the movement’s history.

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

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

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

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

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

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

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

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

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

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

The Meeting’s Outcome

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

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

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

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

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

Leadership Uncertainties

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

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

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

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

 

Alternatives to the Credit Union System

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

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

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

The Federal Home Loan Bank System

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

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

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

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

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

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

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

New Public Banking Legislation

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

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

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

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

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

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

Change is the Lifeblood of a Market Economy

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

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

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

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

Credit Union Mergers: The Final Solution?

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

      Credit unions are changing…

     … and disappearing.  

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

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

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

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

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

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

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

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

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

The Strategic Opportunity of a Shred Day

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

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

The Last Mile

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

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

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

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

The Experience

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

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

Why This Makes Sense

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

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

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

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

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

Hi there Chip,

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

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

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

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

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

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

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

 

 

 

 

 

 

 

Work, Trade, or Finance?

From an unknown source:

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

And cooperatives?

The Need for a Level Playing Field

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

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

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

Transparency and Accountability are Inseparable

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

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

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

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

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

“A Leadership Requirement”

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

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

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

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

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

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

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

 

 

How Long Have Bankers Opposed Credit Unions?

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

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

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

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

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

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

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