Category: Cooperative Design

Posted on

What “People-Helping-People” Means—A Cooperative Labor Day Story

Many credit union practitioners describe their employment satisfaction by citing the credit union slogan of People Helping People.   This explanation is contrasted with the traditional business priorities of profit, market share, growth and personal financial rewards.

There are definitely credit unions whose culture and employee interactions exemplify this aspiration.  In practice however, many member interactions are straight forward: opening accounts, making loans and other service assists that mirror those of many other community financial institutions.

When a consumer or member really needs “help” the circumstances are often not pretty.   There are financial problems frequently aggravated by other issues of health, job loss or family misfortune.   “Helping” in these situations means the credit union and its staff are now becoming more involved with a member’s circumstances.  They learn about personal difficulties and must often become part of a solution.

“Helping” Starts at the Top

In a recent CEO’s monthly report to staff there is a case study of how the credit union tries to implement this oft quoted standard.

The CEO reminded staff that he puts his email address in the member’s monthly newsletter and invites them to “talk with him.” He wants to recognize their role as owners.  This also demonstrates the credit union’s vision of being their “members most trusted financial partner.”

On August 15, 2023 a member wrote to the CEO as follows (names omitted for privacy):

Dear Mr. (CEO):

I was a previous member of the credit union a few years ago and I am a current member as of 11/2019.  I’ve had some life circumstance and made some mistakes as many of us have.  I tried and I’m still working really hard to do better and to be better financially.

I’ve tried to get a loan to consolidate my debt but the only answer I get told is no.  Which is discouraging.  After adopting my niece and nephew at 19 months, who just happen to be twins, like me, I’m just trying to make ends meet.  They are now 15 years old, and like any other teenager, have their share of troubles.   I just want to be able to pay off all my bills, including the debt I owe to you, so that I can spend more family time with them without struggling. 

Thank you for taking the time to read this. God bless!

The CEO asked two staff to call the member, learn about her situation, and see what the credit union might do. Could she pay us back?  Is this where we might make a difference “one person at a time?”

On August 22, 2023, just seven days later,  the member wrote back to the CEO as follows:

Good afternoon Mr. (CEO’s name).

I just want to say thank you for trusting me.   There are no words to describe how grateful I am to you and your staff for giving me a second chance. I can breathe and enjoy my family with peace of mind. 

I failed to mention my sister is in the late stages of dementia.  I can now possibly visit before she succumbs to her illness.   Thank you again, from the bottom of my heart for lightening the financial burden I’ve been carrying.  I hope to do more business with the credit union in the future as I pay down my second chance finance with you all. 

God is good!  Have a Blessed Day.  Thank you.

A Labor of Service and Peace of Mind

The CEO explained the restructure saved the member over $450 per month in payments.  It may be years before the credit union knows the outcome of the story.   The two credit union employees did the “hard work” by investing their time and experience to find a better way for the member.  They went beyond the credit score and payment history to see who she was and her commitment to learn from prior mistakes.

All members have choices of financial services, even those in difficult situations where predator’s options are close at hand.

This credit union has almost 65,000 members, but believes in serving each member individually, one at a time. 

This is why this cooperative team and millions of others are proud to be part of organizations fulfilling the at times difficult jobs of People-Really-Helping-People.  

As this member might say this holiday weekend, may your labors in coops continue to bless for years to come.

 

 

 

 

Posted on

The Greatest Credit Union Market Opportunity

I subscribe to a resource called Visual Capitalist +. The firm transforms data into  pictures and graphs that present the meaning from the numbers.

Below is an example of income distribution in the US using information from 2010.  I suspect the outcome would not be much different today.

I believe this visual illustrates where credit unions have their largest market opportunity.   If the cooperative’s goal is to serve the greatest number of members, versus the members with the greatest wealth, then 80% of Americans owning less than 7% of the country’s financial wealth should be the primary target.

This distribution  is one reason Congress created cooperative credit unions founded on self-help.

Posted on

An Opportunity for the Combined Trade Group: America’s Credit Unions.

The merger of CUNA and NAFCU proceeds apace.   The 60-day voting period by members began yesterday. Already scheduled NAFCU educational and network meetings continue. CUNA President Nussle will attend NAFCU’s Congressional Caucus in September to show a united Washington effort.

Joint transition committees have been appointed.  One initial product was a proposed dues structure. As I read the announcement, members of both organizations are expected to continue  paying the same dues  to the new organization until 2027 (three more years) following the same fee structure in place at December 2023.  It seems illogical  to pay dues for a nonexistant organization three years past its demise.

If credit unions are members of both trade groups, “Dual members are encouraged to pay membership dues for both organizations” even though NAFCU nor longer exists.  Apparently, economic efficiency is not a current goal of the merger.

An Immediate Opportunity for a Unified Effort

The merger process has been focused on the political steps necessary for member approval and  less the potential offered from a “unified voice” in DC.  Even though the political agenda may emerge down the road, there is one immediate opportunity that could demonstrate the possibilities of a combined lobbying capability.

An NCUA board position is now open as Rodney Hood’s term expired this month.  This new member’s six-year tenure should outlast the two current members.  It could extend over two presidential election-administration cycles.

For many recent appointments the expectations, even needs, of the credit union community have not been seen as a factor in the Administration’s choices.   The result is that new board members are strangers to both the Agency and the credit union system.  Think Metsger, McWatters and Hauptman.  Having prior NCUA experience as a staff or board member (Harper and Hood) may be useful, but it still does not bring an industry or coop perspective.

One longtime, now retired, CUSO CEO Randy Karnes (CU*Answers) commented during an earlier appointment cycle: “Cooperative principles make us different. When the NCUA believes that and Washington believes that, we have a stronger system.  But when nobody believes that, then it’s simply about banking regulations. I think our system’s position is weaker, and NCUA is not even thinking about their own brand.”

“Congress didn’t create the credit union charter because the nation needed “nice banks.”

In that same appointment cycle, there was a public White House petition, CO-OPS 4 Change, asking that the administration,  “choose NCUA leaders who understand cooperatives.”  And, “who recognize the shared economic value for people and communities created by the Cooperative model from the seven cooperative principles.”

Jobs for the “Boys” or for Cooperative Leadership

All NCUA appointments result from political ambitions and relationships.   That need not be inconsistent with cooperative leadership.  Earlier NCUA appointments included candidates with credit union experience such as retired and active CEO’s, state coop regulators, CUSO executives and even some with trade association connections.

Knowledge of the evolution of the credit union system and its current status can make regulatory decisions more informed and relevant. The unique structure of the NCUSIF, the potential for a fully engaged CLF, the self-interested trends in mergers, the paucity of new charters, and the continuing use of members’ savings to pay off bank shareholders are critical industry topics.

Even with experienced senior advisors, appointees without credit union knowledge easily default to Agency staff perspectives.

As the combined America’s Credit Union marches forward under a single banner, this appointment is an immediate test of its potential role.  Will the promise of enhanced influence bring forth potential nominees who have cooperative experience? Or will the person be another unknown to credit unions? Can the industry hope members’ needs will  be paramount in a proposed board member’s regulatory views?

The appointment, whenever announced, could provide vital insight about potential benefits of a united credit union voice in DC.

Posted on

The March on Washington and MLK’s Speech: The Financial Metaphor

On August 28, 1963, an estimated 250,000 people gathered in the nation’s capital for the March on Washington for Jobs and Freedom — the largest civil rights gathering of its time. Today, that landmark protest is remembered for Martin Luther King, Jr.’s famous “I Have a Dream” speech.

Many can recall almost verbatim parts of the content of his “dream.”  Politicians of all beliefs, for example, use his phrase, “that one day all people will be judged not by the color of their skin, but the content of their character” to support vastly different views on affirmative action.

To Cash a Check

The dream’s words are still aspirational and inspirational.   For credit unions however, his metaphor about justice and freedom is a reminder of why coops exist.   Here are his opening words with emphasis added:

Five score years ago, a great American, in whose symbolic shadow we stand today, signed the Emancipation Proclamation. This momentous decree came as a great beacon light of hope to millions of Negro slaves who had been seared in the flames of withering injustice. It came as a joyous daybreak to end the long night of their captivity.

But 100 years later, the Negro still is not free. One hundred years later, the life of the Negro is still sadly crippled by the manacles of segregation and the chains of discrimination. One hundred years later, the Negro lives on a lonely island of poverty in the midst of a vast ocean of material prosperity. One hundred years later the Negro is still languished in the corners of American society and finds himself in exile in his own land. And so we’ve come here today to dramatize a shameful condition. In a sense we’ve come to our nation’s capital to cash a check.

When the architects of our republic wrote the magnificent words of the Constitution and the Declaration of Independence, they were signing a promissory note to which every American was to fall heir. This note was a promise that all men — yes, Black men as well as white men — would be guaranteed the unalienable rights of life, liberty and the pursuit of happiness.

It is obvious today that America has defaulted on this promissory note insofar as her citizens of color are concerned. Instead of honoring this sacred obligation, America has given the Negro people a bad check, a check which has come back marked insufficient funds.

But we refuse to believe that the bank of justice is bankrupt.

We refuse to believe that there are insufficient funds in the great vaults of opportunity of this nation. And so we’ve come to cash this check, a check that will give us upon demand the riches of freedom and the security of justice.

Why a Financial Metaphor?

America is the world’s leading capitalist society and its wealthiest.   For many the American dream is about becoming financially well off, even wealthy.   Everyone is financially accountable for important areas of their life.

He uses this metaphor because financial services are at the heart of the American enterprise.  People know what cashing a check means.  Checks  only work if people trust that there will be sufficient funds in their account.   In using this analogy, King says all Americans were given this promissory note of freedom and justice.

Credit unions, the cooperatives founded on democratic governance, self-help and common purpose, embody a critical means for this dream of individual equality to be realized.

Financial services as King presents the metaphor are built on trust, confidence and solvency.   I believe that whenever any credit union for whatever reasons compromises these fundamental principles, the integrity of the entire system is eroded.

Whenever any person’s freedom is limited,  the entire system of justice is compromised. Freedom is not an overnight event.  Its meaning, like financial opportunity, is constantly evolving.

Since 1909, credit unions were intended to be one of the important financial options for bringing  equity for all. Especially for those “who have the least or know the least, but today pay the most for financial services in America.”

On this 60th anniversary of the March on Washington, may it remind those of us who make a living from cooperative financial services, to once again acknowledge and embrace our role in bringing Martin Luther King’s dream to reality.

 

Posted on

A Friday Morning Homily

From author and speaker Greg Satell’s article: Values Always Cost You Something

“The truth is that, to mean something, values always cost you something. Otherwise they’re just platitudes. . .

“Values are essential to how an enterprise honors its mission. They represent choices of what an organization will and will not do, what it rewards and what it punishes and how it defines success and failure. Perhaps most importantly, values will determine an enterprise’s relationships with other stakeholders, how it collaborates and what it can achieve.

“The problem is that values are often confused with beliefs. When you’re sitting around a conference table, it’s easy to build a consensus about broad virtues such as excellence, integrity and customer service. True values, on the other hand, are idiosyncratic. They represent choices that are directly related to a particular mission.

“Make no mistake. Real values always cost you something. They are what guides you when you need to make hard calls instead of taking the easy path. They are what makes the difference between looking back with pride or regret. Perhaps most importantly, they are what allows others to trust you.

“Without genuine commitment values, there can be no trust. Without trust, there can be no shared purpose.”

 

Posted on

When Directors Fall Short as Fiduciaries

Yesterday I quoted from  an NCUA letter which emphasized directors’ primary fiduciary responsibility is to the members, not the organizational entity.

What happens when this principal duty falls short?

Sometimes dissenting directors will just give up and resign.   Other times, the entire board votes to hand over their duties to another credit union via merger.

And the members?  Most of the time they just lose interest and take their business elsewhere. But very occasionally, they revolt. That is happening at SECU in North Carolina.

The former CEO Jim Blaine resurrected his blogging skills when he was contacted by current employees and members concerned about the direction of the credit union under a new CEO.  The daily blog SECU-Just Asking was began in December 2022 with this note:  Caution: Rant in Progress.

The website’s posts of events and opinions would not have become a rallying point if it had not touched on issues of interest to many.

Members Go Democratic

Now that public dialogue has transformed into action.

The primary check and balance on directors’ oversight  is voting to fill board vacancies in the annual election.

Rarely is this process effective.  For nominations and election procedures are controlled by the incumbent directors who try to avoid any election with more candidates than vacancies.

SECU members have become engaged.   The result of the public dialogue is a contested election according to  an article from Business North Carolina.

Social Media Mobilizes Members

Members turned to social media to rally support.  Here is a Reddit example.

How NC SECU is being turned into an elitist piggy bank (and the narrow window to prevent it)

For almost 100 years the State Employees’ Credit Union (SECU) provided low cost loans and financial services to North Carolina’s active and retired state employees, teachers, and their extended families. SECU historically has been one of the only financial institutions that charges the same low interest rates on mortgages, car loans, credit cards, and financial services to all members regardless of whether they come from a rich, middle income or working class family.

Unfortunately, this approach to treating everyone fairly is changing because of actions by the current SECU Board of Directors. This group – for the first time in the history of the Credit Union – has decided to charge middle class and lower income members and their families HIGHER interest rates so that they can give upper income people LOWER interest rates.

And that’s not all the current board has done. They’ve also:

-Cut services, like the tax preparation assistance program that was available to all members.

-Raised interest rates for the majority of members and their families, while failing to raise interest rates for savings accounts.

-And finally, in an attempt to prevent their opponents from running candidates and entrench themselves in power they’ve changed the longstanding rules and bylaws for SECU Board elections.

This is wrong and we must fight back to save our Credit Union!

The current board is made up of 11 people that no longer represent the interests of the hundreds of thousands of active and retired state employees, teachers, and their families that the Credit Union was founded to serve.

What can you do to fix this?

The board changed the rules to make it extraordinarily difficult for anyone new to serve and to try to silence members’ voices. The board’s new rules require a candidate to get 500 signatures, obtained in person, in 5 days time.

In order to stop this board’s attempt to convert SECU into another traditional bank that looks out for rich elitists at the expense of regular folks, please sign the petition allowing these three candidates who support returning SECU to its historic mission to be on the ballot for the board election this fall.

(the three candidates and brief credentials were then listed)

Again, you are only signing to allow these candidates the opportunity to run for the board, so that we may continue this discussion. If they aren’t on the ballot, there will be NO discussion.

Please go to www.secujustasking.com and request a petition form to submit.

Thanks y’all

Over twenty comments were posted to this appeal. Some supported, others asked questions.  Here is one:

I sense that SECU is currently being run by bankers who don’t understand the competitive advantages the credit union historically had. Banks long ago outsourced much of their lending decision-making to people looking at an application and a credit score on a computer screen. That saved them a lot of money (those local loan officers weren’t cheap), but it created an opening for someone like NCSECU to have an advantage. . .

. . .there’s no question that SECU could have made a lot more money over the years by risk-adjusting lending rates (preferably by something a little more sophisticated than just credit scores), but they were able to keep rates flat, because that fit their ethos as a non-profit better.

I just don’t buy that this is necessary now to keep the institution afloat–I have yet to hear a cogent argument for why this is the case now. It apparently wasn’t necessary in 2008 or 2001, but we’re supposed to believe that rates being hiked back to something more like historical norms is threatening the institution? 

Or to put it another way, what have they been doing so wrong lately that they aren’t able to weather this storm the way they weathered storms in the past?

A Test Case

Democracy is a difficult process in all circumstances.  American elections are just the most obvious example.

SECU may be the test that illustrates whether the cooperative model of governance can be a real check and balance by members.  Can democratic voting be the means to counter the ever present temptation to become an “elitist piggy bank”?

Posted on

NCUA’s General Counsel On Directors’ Number One Responsibility

Fiduciary Duties “Are Properly Owed to People, and Not to Entities”

Credit union leaders often state priorities for their financial institution’s future but not how members will benefit. The following is NCUA’s view of directors’ principal fiduciary duty.

This analysis was in response to a state league CEO’s concerns about a proposed rule on directors’ responsibilities. NCUA General Counsel Bob Fenner wrote on March 15, 2011 as follows:

At the very beginning of your letter, you do not state that you are writing to NCUA on behalf of credit unions. Instead, you and your fellow authors state that “[a]s associations representing 18,280,456 members in nine states . . . we want to call your attention to several key issues.

. . . .” I presume that by “members” you mean the people who are members of the credit unions in your states, and I commend you for attempting to look beyond credit unions as entities and through to the people that credit unions were structured to serve. As our rulemakings make clear, the directors of federal credit unions must also represent the interests of the members of their credit unions.

The “Interests of Members”

I do not believe that a rulemaking clarifying that FCU directors owe their fiduciary duties to the membership of the FCU is a difficult concept or one that should surprise or concern directors. Section 701.4 is intended to make clear that the law with regard to federal credit unions is in direct alignment with the credit union philosophy; that is, that credit unions exist to serve their members; that credit unions are about people, not profits; and that the members own their credit unions. As the NCUA Board stated back in 2006 . . . when making important decisions affecting the FCU, directors should ask themselves the following questions:

What financial services do my members need and want? How do I know this? [And] [w]ill my decision today help the credit union provide these member services in a quality manner and at low cost to the members?

Fiduciary Duties Are Owed to Members

Your letter, however, states that “[i]t is our position that the director’s duty should be to the credit union as an organization, and not to the members of the credit union.” I disagree. As the NCUA Board has discussed at length in rulemaking preambles going back to 2006, for federal credit unions the law (as determined by the FCU Act) and philosophy align: the directors’ duties flow primarily to the membership. Id. at 77154-55.

As a practical matter, however, we believe that in the vast majority of situations what is good for the credit union will also be good for the members. See 75 Fed. Reg. 15574, 15575 (fn. 5)(March 29, 2010). . .

 . . .we also believe that fiduciary duties are properly owed to people, and not to entities. FCU directors must understand the people who are affected by the directors’ decisions and identify which people the directors are serving.

The danger is that, if the directors are allowed to focus only on the credit union when making a decision – without regard to how the members are affected – the directors can justify making self- serving decisions, or decisions that serve primarily the FCU’s insiders, under the guise that the directors are simply doing what is best for the credit union.

Ed. (emphasis added)

Posted on

Cooperatives and Business Ethics

On August 2, Credit Union Times reporter Jim DuPlessis published a followup story to Colorado Partners Credit Union’s (CPCU) sale of its cannabis CUSO business Safe Harbor.

The main news was that CPCU reported a $10 million dollar loss in the second quarter on top of a $40 million first quarter deficit, thus wiping out any gains from what was  announced as a $185 million sale of the business in 2022.

When asked about the $10 million, second quarter increase in salaries and benefits, the article quotes the CEO Doug Fagan:

“The loss in Q2 was due to the final pieces of contractual deal expenses that were not recognizable, per GAAP, until the second quarter. I am not at liberty to disclose any further information on those expenses,” Fagan wrote. “We did not have any write downs in Q2 that were directly related to the sale of Safe Harbor.”

The question is who received the $10 million?  For what contractual obligation?  After $50 million in losses, there is more than money at stake.  This is about the integrity and accountability to the member-owners by CPCU’s board and management of a deal gone bad.

Are Coops More Ethical?

This situation reminded me of a Financial Times November 6, 2013 article following the failure and restructuring of The Cooperative Bank in Great Britain.  The following excerpt suggests business ethics are not as simple as doing the right thing.

“Honest is the best policy, but he who is governed by that maxim is not an honest man.”  Richard Whately, Archbishop of Dublin, was a 19th Century theologian, but the observation is very relevant to the modern debate about the nature of business ethics.

The Cooperative Bank has just announced a restructuring that wipes out the value of existing equity.  Over many years the message of the bank’s advertising has been its aspiration to higher standards of ethical conduct than its competitors. The devil’s advocates might seize on the bank’s financial problems as evidence that honesty does not pay, but that s not what happened here.

The Coop Bank failed for the usual reason banks and businesses fail-bad lending in commercial property and the misguided acquisition  of another business by management whose ambitions exceeded their abilities. . .

Ethics are about what to do when good behavior and profitable business are not necessarily the same thing.

Bishop Whately noted the difference between the honest man and the man for who honesty is the best policy.  When you deal with the man for whom honesty is the best policy, you never know when it might be the occasion on which honest is no longer the best policy.

Bankers, not bishops, deliver lectures extolling their own personal integrity; the man who repeatedly reminds us how honest he is rarely acquires, or deserves our trust.   The integrity we value is a personal or organizational characteristic, not a business strategy.”

 

 

Posted on

The Skill of Keeping Honest People Honest

When humankind invented places for reflection, knowledge, good deeds and community leadership, the laws of nature were not repealed.

Organizational design wether this be a church, non-profit driven entity, a credit union, or political office, leaders are all members of the human race.  With their bundles of good intentions and temptations.

Money is an especially potent allure in critical moments, from petty cheating on travel claims to large self-dealing transactions.

So organizations develop checks and balances to,  in the words of my college roommate, “keep honest people, honest.”

Designs Are Not Enough

Returning from a weekend reunion in Chicago, this was the new design for the Metro exist at Bethesda.

The gates have been altered to heighten the exit to prevent “jumpers” from leaving Metro without paying.  Metro had announced that it was losing so much in unpaid fares, that this redesign was necessary to discourage an ever growing temptation.

The “Barriers” in Credit Union Design

There are three elements of organizational structure in credit unions to discourage the ever present temptations when managing money.

  1. The credit union supervisory committee and its system of internal and external audits;
  2. The oversight and review of policy, process and results by external regulatory exams;
  3. The political check and balance provided through the democratic oversight of members in the annual required election of directors.

When these checks and balances are listed, it is easy to see why credit unions can go “off the rails” in terms of personal and organizational shortcomings.

Human temptation is not overridden by organizational design.  For ingenuity can work around the most explicit of processes or checks and balances.

That is why the most critical aspect of leadership is integrity.   One of the best indicators of this quality is the words leaders use when describing an organization’s activity.   In cooperatives those who talk about MY members, MY credit union, MY board or even MY agency reveal potential misunderstanding of their responsibility.

In cooperatives, the operative word should be OUR.   OUR collaborative system, OUR dual regulation, OUR insurance fund, OUR communities’ needs . . .

Designing barriers can help reduce temptation.  Leaders’ integrity is necessary to keep them meaningful.

 

Posted on

FDIC Reports $12 Billion Fund Decline for First Quarter;  NCUSIF Stable and Growing

On June 23, the FDIC released its quarterly financial update as of March 2023. The Fund had fallen by $12.1 billion to $116.7 billion, or a ratio 1.11% of insured savings.

The largest factor in this decline was an increase of $16.7 billion for the loss provision expense for the two bank failures and potential shortfall on the resolution of First Republic.

The Fund’s revenue was primarily from quarterly premium assessments of $3.3 billion (83% of total).  Earnings from investments were only $661 million.   In addition to the loss provision and operating expenses of $508 million, the fund realized a loss of $1.7 billion on sale of investments.

The FDIC’s Assessment Practice

The quarterly premiums are calculated on average consolidated total assets minus tangible equity, not insured savings.   This assessment base is $20.7 trillion or twice the $10.5 trillion of insured deposits at the end of March.

These quarterly fees are not a single rate for all banks.   Rather for the first quarter they are based on CAMELS score and balance sheet complexity.   The range from a low of 2.5 to 42 basis points of each bank’s assessment base.  The annualized total premium for the entire banking system using the first quarter total is approximately 6.4 basis points.

The FDIC presents no other information about the quarter such as a standard balance sheet, income statement and cash flow reports.   So it is not possible to track other performance indicators such as the total loss provisions and management of the FDIC’s investment portfolio.

The March quarter was the first significant bank failure in at least the past eight years as shown in the historical table II-C.

The FDIC’s conclusion about its financial situation is that it will return to its statutory minimum reserve ratio of 1.35% under the DIF Restoration Plan approved on September 2020 by the required time frame of September 2028.  What is unstated is how high the quarterly premiums will be will have to be to make this goal.

The NCUSIF’s Status

NCUA posts the NCUSIF’s monthly financial statements for public review.  The latest is for May 2023 and shows a stable fund  with positive earnings $70.2 million which is an increase versus the prior year’s $67.2 million.

This result is due to the $50 million increase in revenue from the rising yield on investments.  This offset a $14 million increase(16.5%) in operating expenses and a $10 million higher loss provision expense compared to the first five months of 2022.

The fund’s retained earnings as a percentage of insured shares has stayed stable throughout the first five months at .297. Adding the 1% required deposit gives a normal operating level of almost 1.3%.

The most challenging part of the NCUSIF’s management is the investment portfolio which reports a YTD return of 1.76%.   The overnight portfolio shows a yield of 5.23% for May but the remaining $18.4 billion earned only 1.4%.

The investment portfolio’s market value is $1.4 billion below book.  This fall equates to 27.7% of the NCUSIF’s retained earnings.    As the fund continues to add to its overnight total, the average duration has slowly declined to 2.86 years at the end of May.

Learning By Comparison

The FDIC’s premiums will continue to be an open-ended fee paid quarterly to build back the FDIC, a process that will continue for the next five years.

The NCUSIF is at the traditional NOL of 1.3%.  As it adjusts the management of its investments, the Fund’s primary source of income, this should result in credit unions looking for a premium from their cooperatively designed fund in the years to come.