Category: NCUA

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Dollar’s Merger Claim: Merger Guidance From the Experts

Garrison Keillor of Prairie Home Companion fame, is taking his radio performance on the road around the country in one night stands.

Recently he was in Des Moines and drove across the Iowa farmscape prompting this post:

It was dramatic to drive for hundreds of miles and see no barns or silos, no windmill or grove around a farmhouse, the Grant Wood landscape of rural America, and see what corporate industrial agriculture looks like. It looks like Siberia. A place you send people as punishment.

A culture is slipping away that raised some fine self-reliant relatives of mine like my Aunt Eleanor who could handle a rifle, hitch up horses to a wagon, bake bread, plant a garden, throw a baseball, kill a chicken, sew clothing from a pattern, do basic repairs, and speak her mind in firm declarative sentences. The farm made her a strong woman and I say the world could use more like her.

Well, cultures are mortal, just as we are, and it’s a shame when the worthwhile peter out and the worst prosper, such as the culture of consultancy. Some of the stupidest managers I’ve encountered in my life now hang out their shingles as consultants prepared to advise on strategic planning and team building, who when I knew them were adept at strategic blather and creative imitation. I believe that AI will devastate their ranks and soon we’ll encounter them at drive-up windows, consulting on condiments and large vs. medium shakes.

Mortal Cultures

I found myself reflecting on the idea that cultures are mortal in this obsevation  which Keillor titled Looking Around, Not Looking Ahead as I read the following ad via a virtual credit union daily subscriber list:

Dollar Associates has successfully guided over 400 credit union mergers in their 22 years in business.  As their tagline says, “We know credit unions backwards and forward.  Especially forward.”

Mergers as a so-called growth strategy began in earnest following PenFed’s national McKinsey-like strategy of seeking mergers nation-wide in 2016.  The first big success was acquiring Fort Belvoir FCU,  a local well-entrenched competitor.  The standard gambit was promises of a better future combined with multi-year sinecures for the CEO, plus bonuses for senior management, three-year employee commitments or large separation payments to staff.  And of course, nothing for members except a bigger organization.  All details wrapped up with non-disclosure agreements including non-disparagement clauses for everyone who cashed out.

The solicitations were overt.  And PenFed’s over two dozen mergers from a post office credit union in Wisconsin to a Sperry Associates in New York did not add a single member, loan or asset to the movement.

But it changed the merger game from historical rescues of faltering credit unions in return for expanded FOM’s by regulators, into a wide-open pursuit of non-organic growth strategies.  Mergers looked easy, quick and most importantly, the continuing credit union gets paid in-free capital.  Just for taking over a business you already know how to run.

These are not market based transactions despite occasional regulatory utterances suggesting the same.  They are private deals, done in secret without any member input or notice, documented by signed “definitive agreements” and then sprung upon members. Often accompanied with a PR barrage with videos of the two CEO’s proclaiming a new promised land all executed without any member input or knowledge.

This is the merger world today.  Dollar claims to have “guided over 400 credit union mergers” which it would be fair to assume the bulk have taken place in the last decade of the movement’s merger frenzy.

Not Business Combinations But Political Events

These transfers of control of an entire credit union’s operation, net worth, facilities and its legacy franchise value are not business transactions.  The only “negotiations” involve how much the selling CEO and senior staff and sometimes board members will gain from the deal.  If there are enforceable agreements about future commitments, they are never disclosed or done so with the caveat “if conditions permit.”

While members have a say in all states except Illinois state charters which use proxy voting, the process, transparency and information for informed consent is a charade. Almost all votes are returned by mail ballot with the official Board Notice letter urging member approval—as the event has already received regulatory blessing, subject only to the member vote.

The Need for Facilitators and Go-Betweens

Because these are political events not real business transactions, facilitators are needed.  Brokers to quietly solicit candidates, test the waters and make introductions. Accountants, “strategic” consultants and lawyers to draft the private definitive agreements, Most importantly, external professional experts, such as former regulators, to assure boards, for whom this will be a singular and the final event of their tenure.

These volunteer board members need external assurance that they are doing the right thing, because it is irreversible. The so-called professionals will assist getting the necessary regulatory sign-offs-just look at our track record of 400 cases. Trust us, everybody else is doing it as well. You are in good hands.

The facilitators all take their cut of the pie, the vendors who are eliminated get cancellation fees, and staff promised greater professional opportunities. The member-owners receive nothing and lose their accumulated net worth. Most consequential is that  the legacy relationships and goodwill which built the credit union as a community resource to be paid forward for future generations is now gone.

“Looking Backwards”

Invoking Dollar’s hindsight, almost all mergers in this decade long period of private deal making have been of credit unions at least three generations old, with long serving records of meaningful community relationships and contributions.

Per Dollar’s claim, the industry now has lost 400 independent charters, their several thousand volunteer board members, and the CEO and other professional community leadership roles.  Their local and state political standing is gone.

Most importantly their function as an economic intermediary, taking the savings of local members and reinvesting back into loans for those same owners, no longer exists.  For now all these functions and responsibilities are controlled by a new board, often without any connections or knowledge and whose priorities are set following their historical ties and priorities.  The merged entity has no standing or recourse as the new brand and culture assert their sway and  operational model over the merged field of membership.

“Looking Forward”

The facilitators and apologists for this cooperative self-annihilation claim they are positioning credit unions for the future. Consolidation is inevitable, just let us show you the charts.  You need to get ahead of the game before all the “best” options (read payoffs) are gone.  Or worse, there might be a new regulatory change that would make it harder to get your cash prize payout.  Or worse, you may have to be more transparent in your intent and process.

Let’s be clear.  No one knows the future, Change is inevitable.  The current culture and political example of getting yours while you can, may indeed continue.  The animal spirits of capitalism, the drive for monopoly power may infect credit unions so thoroughly that the industry goes the way of the S&L’s.  The big go away.  The small and traditional, still around, but humble, toothless in all except a few communities and a charter neither sought by individuals or desired by the public

But change could also come in the form of a backlash–public, political or regulator.    New coop regulatory  leadership might start asking questions such as,  what is the public duty credit unions owe in return for their federal tax exemption?  What is the common good member-ownership is supposed to inspire?  Are credit unions following their own principles of governance and historical values?  Has cooperative leadership been usurped by self-interested individuals oblivious to their inherted legacy, current members’ welfare and their future generations?

The credit union system knows full well what this period of merger manipulation and self-dealing entails.  For at the same time credit unions are actively buying whole banks as part of their “external growth” strategies.   And in these events, the owners get paid out for their common equity interest and then a premium on top as credit unions can only pay cash, not stock to bank owners.

Certainly, one potential path to the future is the Dollar model.  The firm claims 400 success points to prove it can get the job done.  Cash out now, forget the past legacy, take the money and let someone else worry about the future of your members.

Will That Be With Large of Small Fries?

I may just be like Garrison Keillor surveying the loss of the family farms to the industrial agriculture industry today.   I would prefer a different, more diverse set of credit union options and leadership voices drivng the future.   But sometimes the next generation’s responsibility may be to clean up past excesses before creating something that inspires again.

 

 

 

 

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A 1982 Credit Union Leader’s Video “To All the Girls I’ve Loved Before”

I just received this video of six credit union state league Presidents recording a song in a studio.

The six state CEOs will be familiar to many CU veterans.  From left to right they are: Tony Schumacher , Gene Farley. Carroll Beach, Brad Murphy,  David Dinning and Bob Biancini. 

Note: Skip ahead to 17 seconds to begin the video.

To All the Girls

The Video’s Story (from a participant)

I thought you might get a kick out of this . The video was shot in 1982 I was at a meeting in New Orleans with a number of Credit Union League CEO’s . I do remember our gang walking from our hotel to a restaurant, “The Court of 2 Sisters” (still in business!) On our way we passed this recording facility where you could watch people making mostly silly videos.  The general consensus was, why would anyone embarrass themselves like that ?

On the way back from the restaurant after consuming about a bottle of wine each, this was the result.

The Significance of 1982 and State League Directors

The song’s lyrics might not pass muster today, but you have to admit they put on an excellent show.  But I think it tells a lot more about credit union leadership than the changing culture attitudes on relationships.

In this year of credit union history, the state league system was at its peak strength.  In some states credit unions were so numerous that there were even competing state level  organizations.

Leagues were vital pillars of the movement in this formative decade as credit union entered deregulation.  State charters were the only option until 1934.  Leagues were the driving force in the federal law pasage providing proof that credit union could be run by ordinary people.  State leagues were the vital organizers of  both federal and state charters.

At this moment there were 16 state insurance options along with the NCUSIF.  States were the incubators for change, innovation and creativity. These included activities off limits to FCU’s such as field of membership flexibility, share drafts, home mortgage loans, ATMS and  regulatory oversight and access. NCUA had become a three-person independent agency only in 1977.  The Agency was on its second chair, whereas some of these local leaders had served decades.

The state leaders founded CUNA at Estes Park.  CUNA was headquartered in Madison with a regulatory office in Washington DC.   Through ACULE these leaders coordinated legislative priorities and national leadership.  The corporate network was supported by the leagues initially with cross board membership which NCUA ultimately banned.

The system also spawned other organizational support groups with credit unions of similar fields of membership.  For example the League of IBM credit unions, Educational. Credit Union Council, the Airline Credit Union Association, and many more with like sponsors.

The results were a strong, grass roots state level system rapidly expanding their growing  role in communities in every state.  The movement’s success and the system’s support structure were closely linked and interdependent.

The Illinois Example

Leagues provided support services, education and chapters to promote local social and political interactions.  As a state supervisor from 1977 to 1981, I spoke at chapter meetings, annual meetings and worked with the league when examiners found problems. We would ask if someone from their two dozen or more field representatives might help out as we pursuded the shared the goal of a sound system.  For in 1977 there was no mandatory share insurance requirement for state charters.

Illinois had the largest number of credit unions of any state with over 1,100 active charters.  We wanted the Illinois system to be a national leader in serving Illinois residents. When the Suburban Bank Group sought a charter for  its employees, we granted the new charter. Then we hired the energetic person who organized the effort, Wanda Mallow,  to promote new charters across the state.

One of those new charters went o Baxter,  the medical services company.   The company then hired Rex Johnson who was deputy supervisof of DFI’s Chicao credit union office, to be its first CEO.

Through NASCUS, we learned  how other state supervisors in Texas, Michigan and California operated. NCUA was rarely present on the ground,

Together the League led by Dick Ensweiller and the Department recodified the Illinois Credit Union Act in 1979 introducing deregulation and flexibility for a changing financial marketplace.

The Cooperative System Today

The shape and character of the movement’s system is very different today.   Leagues have merged,  The number of credit unions has fallen from over 16,00 in 1977 to 4,300 today.   Large credit unions operate on their own, some with national ambitions in multiple states.

CUNA moved its operational leadership to DC and focused on national advocacy withdrawing from many support services often offered through the leagues.

Large credit unions dominate the industry. National issues of technology adoption, CUSO business partnerships and regulatory responsiveness  leave many smaller organizatons feeling left out or  irrelevant.  There is no system support for new charters,  In fact the opposite is happening with mergers of long serving, sound credit unions a seeming priority for leaders.

The strong capital ratios averaging over 11% and with long serving safe   franchises  have caused many credit unions to rely less and less on system support, except as an independent  business decision.  CEO turnover at both credit unions and support organizations has caused the shared efforts from the past to be just memories.  NCUA has been leaderless for over a year.  Since the 2008 financial crisis, it has strived to be “independent” of credit unions or as one board member more bluntly stated, don’t look to Washington for advice.

The critical question facing the movement is whether a support system is even necessary and if so, for what purpose.   The shadows of many of these groups still exist, but there is little to no shared sense of priority or direction.  Advocacy means protecting the status quo.

The sense of purpose and serving the common good are sometimes referenced in local planning, but rarely are part of national conversations.  At a time of increasing shortcomings in many ways and at many levels of political and business activity, credit union identity is becoming more and more market-like.  Coop leaders are playing the merger and growth games they find, rather than defining the game they want to play.

So maybe the nostalgic message of prior relationships recorded by these State League Directors is more prescient than they could have realized.  Is the system that spawned today’s credit union industry just is a nostalgic moment of an era now gone forever?

To all the girls I once caressed
And may I say I’ve held the best
For helping me to grow
I owe a lot I know
To all the girls I’ve loved before
The winds of change are always blowing
And every time I try to stay
The winds of change continue blowing
And they just carry me away

 

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Government Protecting Us From… Government

by Will Rogers, Jr.

I was recently asked my thoughts on NCUA’s current policy priority of ten rounds of rule reviews.  This earlier article makes the point that an ideological driven policy to eliminate to the maximum government’s oversight responsibilities will end up in a backlash.  And put the coop movement in a bad place politically.  Here’s why this prior commentary is more relevant than ever.

It takes a special kind of Washington brilliance for a regulator to decide the greatest threat to the republic is its own discretion and then propose a rule to rescue us from itself. But here we are.

The NCUA has unveiled a proposal that essentially says:  “We hereby forbid ourselves from misbehaving. We don’t trust ourselves either.”

In a normal world, regulators create guardrails for the people they regulate. Only in our nation’s capital does an agency build guardrails to keep itself from driving off the road.

The Rule’s Premise: Reputation Risk Isn’t Real

This proposal seems to assume that reputation risk is some imaginary creature—like Bigfoot, or a cheerful airline fee.

One wonders whether the drafters have heard of a quaint little story called Wells Fargo, where an institution spent years rebuilding trust after opening millions of fake accounts.  But perhaps NCUA thinks that was all just a marketing misunderstanding.

If the agency truly believes reputation risk is fictional, one hopes they never Google “NCUA failures” or, heaven forbid, read their own Inspector General reports.

Who Exactly Is Being Protected Here?

The proposed rule claims to stop NCUA from pressuring a credit union to decline accounts for certain businesses: liquor stores, cannabis operations, burlesque venues, adult-film producers, and so forth.

One might ask:  Has this ever happened? Even once? Anywhere?

No.
This is Washington’s favorite sport: solving imaginary problems so it can avoid the real ones.

Meanwhile, the real harm that does exist: merger-driven CEO enrichment, member disenfranchisement, sham elections, and sending member savings to buy out bank shareholders’ at premiums, goes unaddressed –because someone must ensure the men’s club dancers of America are free to open checking accounts. The republic is safe.

The Greatest Burden: Fixing What Isn’t Broken

Fixing real problems is difficult. Fixing imaginary ones is far easier, and far more wasteful.

Rules like this drain time, staff attention, and credibility. Worst of all, they distract the agency from the issues actually hurting members:

  • selling strong, local credit unions to distant ones,
  • conducting board elections with all the transparency of a papal conclave,
  • and using member capital to fund bank-acquisition premiums.

But at least NCUA has now protected the nation from the nonexistent threat of ideological debanking.

Reputation Risk: It Exists (Even if NCUA Pretends Otherwise)

Reputation isn’t a theoretical construct. It is the currency of leadership.
It evaporates when leaders substitute ideology for competence.
It collapses when institutions forget who they serve.
It disappears when regulators look the other way, or worse, when they look inward and pass rules to restrain what they themselves might do.

If NCUA doubts that reputation risk is real, a previous post about NCUA’s morally incompetent General Counsel and Chief Ethics Officer has already written the case study for them: A Culture of Impunity, a chapter the agency should revisit with a box of tissues handy.

The Real Absurdity

This proposal doesn’t make the agency strong. It makes it look frightened. afraid of its own staff, its own judgment, and its own shadow.   It solves a problem that does not exist, while ignoring several that are eating the system alive.

Proposing this in order to curry favor with ideological overseers does not enhance NCUA’s standing. It diminishes it. It invites laughter in all the wrong places.

A Modest Suggestion

If NCUA wants to improve its reputation, there is a simpler way than pretending reputation risk doesn’t exist: Let this rule die quietly.  Slip it into a drawer. Close the drawer. Lose the key.

As Will Rogers, senior advised: “Never miss a good chance to shut up.” 

(first published Dec 4, 2025, updated May 1, 2026)

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NCUA’s  Financial Fairy Tales

It is a leader’s deeds, more than words, that create confidence in those who rely on an organization’s performance.

Chairman Hauptman became the only NCUA board member and its primary  publicly accountable leader when President Trump fired his two other board members in April 2025. That Presidential executive  action is still in litigation.

Hauptman has repeatedly stated that his solo leadership will be business as usual at NCUA even citing  previous precedents. One would assume a single point of authority could result in more direct  staff outcomes. Constituent credit unions could have clear direction. No need to compromise to gain board approvals.

However Hauptman’s leadership intentions are not clear.  Are his priorities to implement executive orders from Trump to show his political fealty?  The administration has made no secret of its intent to take a wrecking ball to government agencies.

Or is he motivated by the circumstances  of the cooperative system which NCUA regulates?

How will his previous statements as a minority board member shape his current priorities on regulatory burden or the NCUSIF’s financial structure?

He is a lame duck whose term has expired . He has already been nominated to a board position at the PCAOB for twice his $156,000 NCUA salary.   Does agency staff have any incentive to implement changes knowing a new leader or full board may be just months in the future?

What interest and capability do Hauptman and his team have in managing Agency outcomes? Or are results staff’s responsibility and he is just an orchestra conductor, waving his verbal policy arms?

Hauptman’s  First Leadership Test

It was with great interest, and some trepidation that Chairman Hauptman’s first significant  initiative was to implement the President’s executive order to reduce agency headcount  by at least 20% in 2025.

Later in the year the agency proclaimed  targeted staff cuts had been exceeded.  Moreover,  NCUA was still fully capable of doing its work even with much reduced staff resources.

The Reveal: Annual Costs Went Up, Not Down

On April 1 ,  2026, the NCUA’s 2025 Annual Report of almost 200 pages was published.  The press release included Chairman  Hauptman’s statement:  “As promised, we’ve delivered millions in cost savings to credit unions. Our agency-wide effort on efficiencies has paid off, as NCUA will emerge from our reorganization a nimbler, more focused agency. . .”

However a day later Credit Union Times released an analysis that showed there had been zero cost savings,  In fact the agency spent more on salaries and benefits than the prior year.  Here are some excerpts from the article: NCUA Report Shows Highter Costs for Fewer Workers.

The NCUA’s 2025 annual report released Wednesday showed the agency spent more money on fewer employees last year.

The NCUA went from 1,211 employees on Dec. 31, 2024 to 940 on Dec. 31, 2025 after instituting a voluntary separation program. . . a 23% headcount reduction. . .

The article’s writer created a spread sheet because operating numbers for 2024 had been omitted from the current edition.  His analysis showed the following comparison for NCUA’s most recent two years salaries and benefits:

Employee wages and benefits were $121.7 million in 2025, up nearly 10% from $111.1 million in 2024. Those expenses rose 8% to $102.772 million in 2024 as its workforce grew by four employees.

Based on year-end employment, the NCUA spent an average of $129,461 per employee in 2025, up 41% from $91,718 in 2024.If you divide by the year’s average employment (averaging the year’s starting and ending employment), average pay rose 23% to $113,150.

Overall, the NCUA’s operating fund expenses grew 6% to $160.7 million.  (bolding added)

Subsequent Events in 2026

The Times article quoted an NCUA spokesperson explaining that there were multiple incentives paid to meet the agency’s staff reduction goals.  In essence NCUA had to spend more to save money.

I followed up this explanation across all three funds whose costs are paid by credit unions.  So far the trends in total salaries and benefits are exactly the same as in the article-higher costs for fewer employees.

Operating Fund salary and benefits for January 2026 versus 2025:

2026: $ 10,791 million versus 2025: $10.112 million  a 6.7% increase.

NCUSIF does not show separate salary and benefits expense.  However the OTR for 2026 increased by .1% and presumably the salary pass throughs would show he same increase.

The CLF presented its annual budget at the January 2026 board meeting. The initial slide was highlighted by the statement:  CLF’s 2026 Budget is 12% BELOW its 2025 Budget

The CLF will spend less, right? No, instead it will spend more! Through February 2026, salaries and benefits are $329k versus $267k in 2025, or a 23%  increase.   Not the forecasted message of a cost reduction.  This increase funded by almost $1 billion in credit union capital for a facility that has played no role in credit unions since 2008.

The Bottom Line

NCUA is spending more on salaries and benefits so far in 2026 after a 23% reduction in total headcount  at the end of 2025.

The failure to actually reduce expenses shows a lack of management oversight at the highest level of the agency.   One of the truisms of government reorganization when delegated to staff, and not overseen by top leadership, is that success in the staff’s terms is not about cutting back, but about getting more.

If Chairman Hauptman’s words about millions of dollars in cost savings to credit unions is not correct from the agency’s  own numbers, one has to be skeptical of more subjective claims  such as, being a more nimble and focused agency.

If NCUA leadership does not manage their own internal financial trends, what does that suggest about their knowledge of the most critical credit union issues?  Are changes in credit union merger payoffs and fintech investments  leaving regulators in the dust?

Are the current multiple public announcements of NCUA deregulation proposals any more than agency PR “proceduralism”? That is government pretense for appearing to seek change, but nothing is different in the end.

For if NCUA really sought to reduce burden then the largest, most involved and unsubstantiated rule ever imposed on coops, risk based capital, would be at the top of the “burden” list. Or at a bare minimum resetting the NCUSIF’s NOL at its historical 1.30%. This has been the outcome for the prior four years as shown on page 165 of the Annual Report.  But no dividends have been paid to credit unions as board keeps the NOL at 1.33%.

This is Chairman Hauptman’s time at the helm.  There are no other board members to appease.  He proclaims NCUA is doing business as usual. The question is, what does usual mean?

This could be a special opportunity to align agency priorities with actual, urgent cooperative  system needs. Or usual may just be more words, fairy tales, to curry political points or create a  flawed impression of leadership.

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Thoughts on Natural and Artificial Worlds

The view from my desk window.   Nature’s beauty brings comfort and joy.

 

Two AI Moments

Artifical intelligence brings hope with worry.  Credit unions and consumers are using this capability very quickly.

On March 26, NCUA’s acting director of examination and supervision testified before Congress on the agency’s reviews of credit union technology.  Here is an excerpt on AI by NCUA staff:

Beyond supervising how credit unions adopt technology, NCUA is also exploring how technology can enhance our own operations. NCUA is currently using artificial intelligence for content generation, to flag anomalies in Call Report data submissions, forecast loan performance to support risk analysis, identify credit unions with elevated risk, and enhance cybersecurity operations.

The foundational AI  concern is from a post by writer and financial analyst Andy Tobias:  We need — urgently — to figure out (a) how to protect humanity from a superior species; (b) how to avoid economic catastrophe and, instead, harness A.I. for the benefit of all.   (link)

He cites one expert’s observation:  The experience that tech workers have had over the past year, of watching AI go from “helpful tool” to “does my job better than I do,” is the experience everyone else is about to have. Law, finance, medicine, accounting, consulting, writing, design, analysis, customer service. Not in ten years. The people building these systems say one to five years. Some say less. And given what I’ve seen in just the last couple of months, I think “less” is more likely.

Here is the full article, Something Big is Happening.

Andy  recommends this new  documentary that interviews five CEO’s of the  largest investors in AI as well as academic experts.  In sum, the dangers are real as AI become pervasive in all activities.

On  Apple TV:  The AI Doc: Or How I Became an Apocaloptimist.

Watch the trailer here.

Now  back to the yard:

 

 

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A Chance for NCUA Chairman Hauptman to Make His Mark

NCUA leadership is critical to the integrity and character of the cooperative system.

The board whether one, two or three members is responsible for setting priorities and precedents that are the foundation of NCUA’s relationship with the credit union community.

As a regulator of cooperatives and overseer of the system’s mutual solutions, NCUA’s role is much different than other financial regulators.

A critical example of this innovative industry collaboration was the  redesign of the NCUSIF as the system’s collective capital fund.  It was a joint effort with all parties making commitments to each other about their future stewardship of this unique federal model.

Many of these undertakings were so vital they were included in the enabling legislation as well as described in detail in the Agency’s Annual Reports and other official communications.

An important agreement to the 1% open-ended funding was the requirement that credit unions receive a dividend when the yearend fund balance exceeds the normal operating level (NOL) fund cap.  The cap was set  at 1.3% by law.

In the credit union Membership Access Act, the board was given flexibility to raise the NOL to as much as 1.50%.  In 2017 the board elected to do this to accommodate the surplus funds from the Temporary Corporate Stabilization Fund merger.  Those excess funds were then used to write off losses in the taxi medallion failures.  But the NOL was never set back to its historical level.

 Hauptman’s NCUSIF Oversight Statement

A critical role of the NCUA board is setting the annual the Normal Operating Level (NOL) cap of the fund.  Earnings beyond this level are distributed as a dividend to credit unions recognizing not only their collective performance but also their open-ended funding commitment with the 1% true-up of their capital deposit.

Kyle Hauptman explained his understanding of this board’s responsibility in a December 2022 board meeting when Vice Chair.  (link) This is the text.

Just to review, the Normal Operating Level (NOL), as described in the Federal Credit Union Act, can be set by the NCUA Board from 1.20 percent to 1.50 percent. The NOL is our desired level of equity in the Share Insurance Fund.

The NCUA Board has the discretion to assess a premium when the equity ratio falls below 1.30, but only to bring the ratio up to 1.30 as allowed by the Federal Credit Union Act.

The 1.33 Normal Operating Level represents the point at which the Share Insurance Fund is required to return funds back to insured credit unions should the equity ratio exceed 1.33.

Now a few months back, I voted, along with the rest of the Board, to lower the NOL to 1.33 from 1.38, where it had been for several years. Now I don’t pretend to know that 1.33 is the magic, perfect Net Operating Level. I do know that, for the moment, moving it from 1.38 to 1.33 is a moot point because the Fund isn’t close to either number.

And if someday we wind up back in that range, the correct NOL level will be a high-class problem to worry out. Given the current rate environment, I do not believe any of us believes we will be getting close to that number. That said, every basis point over 1.30 represents money credit unions could put to good use.

I appreciate the additional information on how the Normal Operating Level is calculated. We need more of this kind of transparency. In the spirit of more transparency, I ask that we acknowledge our responsibility to show why 1.30 is not adequate — as I said, every basis point over 1.30 is money credit unions could be investing in their members.

It’s worth emphasizing that credit unions are doing their part. I would like us to recognize this fact via finding ways to factor actual losses incurred into our loss reserves calculation. After all, the higher the loss reserves, the lower the equity ratio. More importantly, the actual losses incurred year-over-year may be a decent predictor of the fund’s reserve needs. But of course, I acknowledge that insurance isn’t about normal circumstances. The whole point of insurance is for the unexpected, the unusual, the chaotic.

One additional factor in determining the adequate level of the fund’s equity is how well we manage our budget. Coincidentally, the budget is also on today’s agenda. The cost of managing the risk in the fund directly impacts the equity ratio. The more NCUA spends on itself, the lower the equity ratio. NCUA can’t, in good conscience, spend additional millions on programming for ourselves, the 1,200 NCUA employees, while also claiming our Insurance Fund needs more cash.

I realize today’s briefing is strictly about the Normal Operating Level calculation, but I hope you’re picking up what I’m putting down. (underlining added)

Hauptman’s Opportunity

The NCUA stopped presenting any analysis justifying an NOL above 1.3% for the past three years.   In the December 2025 NCUSIF update there was no mention of reviewing the NOL.

I asked NCUA’s public affairs office how and when the NOL for 2026 was set:

The reply: Regarding Normal Operating Level for the  NCUSIF: 

The latest update of this referenced NOL process is shown as: Last modified on  01/25/22.  However, the last two times staff provided their analysis and assumptions for a 1.33 NOL cap the model when run supported a lower cap.  

Hauptman’s second factor in NCUSIF’s net income is NCUA’s operating expenses transferred via the Overhead Transfer Ratio (OTR).  Chair Hauptman’s view is clear:  The more NCUA spends on itself, the lower the equity ratio.

The public affairs office’s March 17, 2026 response when asked about the OTR rate: 

  • The final 2026 OTR is 61.8 percent, 0.1 percentage point higher than the 2025 OTR.  The remaining 38.2 percent of the 2026 budget is collected through the operating fee billed to federal credit unions. Based on a $2.16 million average asset exemption, the operating fee charged to federal credit unions in 2026 will decrease by approximately 24.65 percent compared to 2025. (underline added)

As the sole board member Chairman Hauptman is uniquely able to implement his views on the NOL, or as he stated,  “Pick up what he put down.”

That would be a legacy worth noting and a mutual commitment reestablished.  Or as he so clearly argued:  every basis point over 1.30 is money credit unions could be investing in their members.

 

 

 

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Democracy Takes Work-At Every Level of Society

As I went downtown during rush hour yesterday, a gray haired, older lady appoached me with a small handout at the escalator.  It was a snall flyer for where to stand locally in the No Kings rally  this Saturday around the country at over 3,000 locations.

But democratic duties are not limited to national and local politics.  Virtually all volunteer, non-profit and community organizations have some form of member oversight.  This can be the elections of representatives or to changes in bylaws and/or structure.

If one  owns any publicly traded stocks, it is likely there will be reminders of the annual meeting with proxy solicitation calls. In this case the voting is based on share holdings, but voting none the less.

Credit unions can learn from these other exercises in organizational governance.  Especially what can happen when democracy is usurped by those in control at the moment.

The Tools of Democratic Oversight

Jim Blaine the former CEO, observed that an organized minority in authority will always defeat a disorganized majority.  And democratic majorities are, by definition, rarely in unanimous agreement.  Not everyone in Virginia thought the idea of Give Me Liberty or Give Me Death, was a great choice.

One of the most important monitors of our various democratic processes is the press.  This can be public press and broadcasts, industry publications, bloggers and those using social media to raise concerns, and even individual actors writin opinions for their local outlets. Here is how the press is covering a story of usurpation of democractic control in a major local powerful institution.

Democratic Control Removed-A Press Investigation

Recently the Houstan Chronical completed a five-part investigative series of a takeover of one of the largest Baptist Churches in the city by its pastor.  (link)

While the details are behind a paywall, here is a summary of events.

Houston’s Second Baptist Church, with about 90,000 members, is a church at legal war with itself, since a group of influential congregants calling themselves the Jeremiah Counsel sued church leadership in 2025.

They’re challenging revised bylaws established in 2023 that deny lay members a vote in important church decisions, including the selection of senior pastor Ben Young, son of the church’s popular long-time leader, Ed Young.

The bylaw change was in a single sentence that seemingly slipped by most people and put the church at odds with its own faith: “Members are not entitled to vote in person, by proxy or otherwise.”

With those 12 words, the congregation at the now 98-year-old church lost more than its vote. It parted ways with a core tenet of Baptist doctrine: democratic rule. 

The revolt started when a group of members realized they had given away their authority to vote on church business after an election in which hardly any congregants participated.

It didn’t take long for several influential church members — who are now suing to reverse changes made in that crucial vote — to realize where the new bylaws came from. They bear a striking resemblance to the bylaws of Fellowship Church in Grapevine.

Fellowship Church in Dallas, is another megachurch with family ties to Second Baptist. Second Baptist quietly copied Fellowship Church’s bylaws — and silenced its members.

One article in the series is headlined:  How Second Baptist Church sacrificed its Democratic Principles: ‘You can’t fire the king’

 Democracy vs. No Kings

The human tendency to rule by authority versus the more complicated exercise of democratic leadership is present in all organizations.  But especially in credit unions.  Because money amd, its use, is combined with power.

The result is that boards and senior management strive to limit any meaningful say in their oversightand leadership roles.  Nominations for board seats are controlled by existing directors and limited to the exact number of vacancies.  No voting needed, just ask members to approve by acclamation.

But when there is the prospect of members rising up, the next step is to copy the practice of Second Baptist.  Specifically change the bylaws to make it impossible for members to self-nominate or to challenge the board’s control of the election process.

In the traditional FCU bylaws, members can submit a petition with 500 names for board nomination or to call special member meetings.  The top three credit unions by assets,Navy FCU, SECU  (NC) amd  PenFed all took steps to make this member option impossible.  Instead of a fixed number, the bylaws were changed to require a percentage of total members to sign the petition.

PenFed’s change came after a self-nominated candidate qualified for  election.  SECU’s board changed its bylaws after members challenged the closed board process in an open election. The board changed the bylaws and election procedures to make the process very difficult for member-nominated candidates to qualify.

All three bylaw changes to the long standing democratic process were approved by the reglators with members having no say or even knowledge.

Democratic oversight takes integrity, character and continuous vigilance. It requires a free press in all forms to cover uncomfortable truths and lapses in duty by those in power. Power  in terms of community and local influence and those charged with responsibility for public oversight.

Firing a Credit Union Leader

One of the landmark events in credit union land was when CUNA fired its presient.  The story in brief:

Herb Wegner was an avid pilot and owned his own plane. He had an agreement with (CUNA) to be reimbursed the equivalent of a first-class ticket whenever he flew his own plane for work. However, disputes over these expenses became a major point of friction with the CUNA Treasurer, Fred Krause.

At a board meeting in 1979, Krause reportedly announced he was “tired of fighting Herb about airplane expenses” and unexpectedly moved to fire him on the spot. The motion passed, stunning most of those in attendance.

While there were other factors at play, today the highest honor credit unions bestow on their leaders is called the Herb Wegner award.  An irony which shows the cooperative system’s ambivalence in managing its own shortcomings.

What Everyone Must  Do.

Democracy takes practice which is the root of the word participation.   Here is my sign for Saturday.

 

 

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To BEE or Not to Be: The Most Vital Question for the 2026 Credit Union Governmental Affairs Conference in DC

This week is the annual credit union political Woodstock festival in the Nation’s Capital.  There will be vendor halls filled with new and old names; speeches from industry leaders promoting unity and forecasting threats; praise from both sides of the congressional aisles; and non-stop breakfasts, lunches and receptions/dinners to catch up with peers.

Is it possible in this choreographed cacophony that the most important voice and movement issue may not addressed? The concern comes from 2,700 miles away, written by a longtime member-owner and printed  in the local newspaper, the Sacramento BEE.

In this week of celebration I believe this person is raising the most important existential issue facing the movement-will anyone pay attention.

https://www.sacbee.com/opinion/op-ed/article314780377.html

The Movement’s  Critical Issue

The Bee opinion is a current example of the increasing frenzy of secretly initiated intra-industry  acquisitions reshaping the unique structure and role of cooperatives.

The proposed SAFE-BECU  combination takes the future away from their member-owners.  It now rests in the control of self-appointed boards and management’s personal ambitions.  Regulatory oversight is entirely absent.

The Context for this 2026 Endgame

Existential moments in credit union history are not new. In February of 1982 Chairman Ed Callahan, in his first speech to GAC, asked CUNA President Jim Williams the most critical issues facing credit unions.  Jim used one word: “survival.”

At that time, the movement counted 20,784 credit unions with $72.3 billion in assets serving over 45 million members.  Growth had stalled.  Inflation with double digit interest rates and money market funds were taking away shares.  Credit union expansion a forgotten  dream,  investments (GNMA 8’s) were way underwater, and losses were looming high.

Drawing on his five years overseeing the largest state charted system in Illinois, Callahan proposed a new policy following credit union principles of collaboration, self-help, local advantage and ever enhanced member-owner value.  The resulting changes in NCUA institutional oversight and industry initiatives created a movement that not only survived but thrived,. The movement transformed to the market driven realities of open competition from the era of government issued licensing for protected financial franchises.

Today’s Threat Is  Internal

Today the nation’s 4,200 credit unions manage $2.5 trillion in assets for over 140 million members with retained earnings approaching $285 billion. The NCUSIF is overfunded.

Unlike 1982, the system’s present danger is neither financial nor the various external warnings  about fintech, stable coin options or other competitive innovation.

Today the existential end arises from two simultaneous practices. One is expanding efforts of self-destructive acquisitions of long-term large sound coops by their fellow credit unions. These efforts mimic the  old fashioned capitalistic efforts to gain market dominance by takeovers, not competition.

As described in the BEE opinion editorial, the deals are done in secret with payouts and new roles negotiated by the principals, their advisors and then signed off routinely by regulators. No one represents or protects the member-owner’s rights and financial interests in these deals rife with conflicts of interest.

There is a second social and political factor at work. Today’s  political ethos is the example of the strong, ambitious and single-minded pursuit of wealth and dominance, not democratic collaboration.  Traditional credit union virtues of cooperation and sharing seem naïve.  So leaders will bow their knees, compromise legacies of trust, to those in authority who in turn will stand aside as they pursue their goals of  industry superiority.

The movement’s future has been steadily removed from member-owners’ hands through self-perpetuating boards and CEO turnover whose successors have no obligation to the legacy they now control. These changes of control  transactions are now greased with payments in the millions of dollars from members’ common wealth.

Standing Up to  Self Destruction

Can this increasing  cooperative  cannibalistic destruction be challenged.? As more and more leaders are caught up in what one observer calls the emotional urgency of FOMO risk,  can credit unions’ unique purpose be revitalized?

Two sources of hope and example.

The first is a renewed vision and embrace of  what success looks like as a coop.  Here is a classic, timeless statement by a longtime, very successful CEO, now retired.  The Ultimate Vision:

(https://www.youtube.com/watch?v=tE_3-ipOiPE)

Will The Grassroots Rise Up?

The second factor must be the old fashioned calling that all Americans believe in democratic governance.  It is not the rich, those in positions of power or the inheritors of wealth that control our future.  But We the People.

Scott Rose, in his BEE opinion, is the example Doug Fecher said would be the test of credit unions’ ultimate success.  Scott is sounding an  alarm for his community’s future.  His effort is the same that has  animated the best of American patriots for 250 years.  On behalf of his 245,000 fellow owners, the greater Sacramento community and the missing regulatory oversight, he is alerting all of us to this takeover of not just his credit union but the entire  cooperative model.

His willingness to take a stand will create public awareness, debate and an uprising from  the grassroots.  For as he says, “member-owners, local leaders and potentially impacted community organizations must speak out.   What is lost is not simply and accounting abstraction—it is real control of wealth. . . Once approved, a merger cannot be undone.”

Will someone at tonight’s Herb Wegner award festival dare to honor the voice of this member-owner who is calling all of us to remember who we are and what we stand for?

The challenge is both present and ageless.  In words of the Bard’s most famous character:

To be, or not to be, that is the question:

Whether ’tis nobler in the mind to suffer

The slings and arrows of outrageous fortune,

Or to take arms against a sea of troubles

And by opposing end them.

 

 

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Will NCUA’s Journey Be From Chartering a COOP Movement to a Regulatory Dead End?

What kind of financial regulator would be most effective to carry on the purpose of the credit union system stated in the FCU ACT? (see note on Congressional purpose at end)

Should the credit union system be overseen by a regulator of cooperatives or of financial institutions?

The arc of federal regulation from 1934 to today is simple.  The federal regulator evolved from the role of chartering, promoting and supervising cooperatives to just another financial supervisor safeguarding an insurance fund.

The coop design is unique in American financial options. The users are the sole owners of the service.  The intent was to create shared community resources not private wealth.  The structure was to be perpetual with the common equity always “paid forward” to benefit future generations.

Moreover, financial soundness was underwritten by  this shared purpose of borrowers and savers.  Governance was democratic–each member-owners had one vote. No proxies.

The Impact of NCUSIF On Coop Regulation

The  turning point in cooperative regulation was the 1970 passage of a federal deposit insurance (NCUSIF) option modeled after the FDIC and FSLIC.  The banking funds were created in the early 1930’s in response to the  “banking holiday” failures in the depression.   The nascent state chartered credit union movement had no such system failures.  Deposit insurance was not  part of  the FCU act passed in 1934. It wasn’t needed.

The need for the NCUSIF was much debated by credit unions in the lated 1960’s.  CUNA opposed the option arguing such an institution would eventually dominate the system’s functioning.  A new trade association, NAFCU, was formed to lobby for and pass this federal option for cooperatives.

The NCUSIF was not created because of system failures.  Rather it was a recognition that cooperatives, while different in design, were just as safe as any for-profit banking option.

As NCUSIF insurance spread, so did federal regulation mimicking other banking regulations.

From Cooperative Partner to Financial Overseer

When implementing deregulation from 1981-1985, NCUA Chairman Callahan asserted credit unions were unique.  The so-called level playing field arguments, he believed, would undermine the cooperative advantages of member-ownership.

Callahan believed regulations should promote cooperative purpose and collaborative actions.  Both tenets were key tp the financial restructure of the NCUSIF and achieving 100% credit union participation in the unique CLF’s-coop system liquidity partnership.

But the bureaucratic pull of Washington prompted later NCUA leaders to emulate the example and practices of banking regulators.  Safety and soundness, not member service, became the regulator’s mantra.

Both NCUA and credit unions sought Congressional hearing seats at the tables with the titans of America’s financial services.

Today NCUA has copied banking regulators with rules such as risk-based capital and, expanding market sources of capital.  New charters are non-existent.  Cooperative purpose is never mentioned in supervisory priorities.

NCUA oversight has fluctuated between laissez faire (let the free market decide) to embracing the administration’s political ideology from DEI to government downsizing.

The absence of any reference to coop design is that there is no protection for for member-owner rights or their collective savings.  NCUA like the banking regulators has reduced their oversight to merely offering a $250,000 payout in the event of institutional failure.

This neglect of member-owners’ rights has resulted in boards staying in power perpetually.  Owners are kept out of any governance or voting role.  Bylaws are modified with NCUA approval to prevent member initiatives.  Boards and CEO’s feel free to take a credit union’s business model and its billions in legacy assets in any direction they choose.

Transparency for cu leaders’ conduct is non-existent.  Director fiduciary duties flouted. Accountability for outcomes occurs only after a financial crisis. Then the system’s leadership shortcomings are quickly swept under the rug via mergers.

When new CEO’s arrive from outside the coop system, often former for-profit financial professionals, they bring their prior experiences with them. They act like teenagers given a new high-powered formula 1 car.  With board assent, they jump into the driver’s seat and try to see how fast they can make their new institution grow.

The NCUA’s Future

Today NCUA acts and sounds like the other banking regulators.   Credit unions applaud the Trump adminisration policy of government tear down and relaxed o exam oversight.    NCUA appears  alongside the other financial overseers in Congressional hearings, states all is well, and makes no effort to describe how the tax exempt coop system is fulfilling any public duty.

The consequence is that credit unions no longer see their organization as part of an interdependent financial system. Institutional success is celebrated versus cooperative’s  ability to create better financial solutions for those who have the least or know the least about personal finances.

Individual credit union priorities look more and more like capitalist business plans.  They attempt to acquire, not support their peers, via merger takeovers.  If that fails, just buy a bank.

With self-perpetuating board oversight, regulatory withdrawal, no transparency about transfers using tens of millions of member-owners’ capital, the cooperative system may lack the capacity for self-correction.  Industry hegemony, not cooperative purpose, becomes the institution’s endgame.

How much longer will Congress or public policy think tanks not pose the existential questions: Why does America need a financial system that emulates its competitors, but with a tax exemption?  Will NCUA become part of Treasury’s financial oversight, just like the OCC?  Why have two federally managed deposit insurance funds that provide the same function?

“It Makes No Sense:” One Analyst’s Assessment

Yesterday’s post gave a brief history of federal regulatory evolution, It  tracked the various federal governmental departments that shepard credit union’s evolution.  And subsequent events under NCUA as an independent agency. This is that author, Ancin Coolley’s  concern, about where the coop movement stands today.

 When you read credit union regulatory  history and go back to the arguments, it keeps bringing me to this point: the FDIC and other agencies did not want credit unions. And it calls to mind the question, why did they not want them? 

They did not want them because credit unions were not treated the same way as other financial institutions. They were viewed as something that drifted into a social-services posture.   

And honestly, the more I dig into the history and the legal history, the more it feels like I’m finding out Santa Claus isn’t real. The more I learn about the lack of standing for members in court, and the reality that there’s often no remedy for members against directors who effectively give away capital, the more disorienting it feels.  

It’s like there’s the reality I want to believe in, and then there’s the legal reality of what a credit union actually does.  

And what I can’t even begin to reconcile conceptually is this: credit unions want to maintain their tax exemption while also purchasing banks. In good conscience, I can’t even argue against someone who says, “How are you going to maintain your tax exemption if you’re buying a bank, when you were originally given a tax exemption for not being a bank?”   

It makes absolutely no sense.  

Editor’s Note on Cooperative Purpose:

Congress added the following language to the Federal Credit Union Act on August 7, 1998.

The text was included as part of the Congressional Findings in Section 2 of Public Law 105–219, also known as the Credit Union Membership Access Act.

This specific language was crafted to affirm the Mission and reassert that credit unions serve people of “modest means.”

The Congress finds the following:

  1. The American Credit Union movement began as a cooperative effort to serve the productive and provident credit needs of individuals of modest means.
  2. Credit unions continue to fulfill this public purpose, and current members and membership groups should not face divestiture from the financial services institution of their choice as result of recent court action.
  3. To promote thrift and credit extension, a meaningful affinity and bond among members, manifested by a commonality of routine interaction, shared and related work experiences, interests, or activities, or of an otherwise well understood sense of cohesion or identity is essential to the fulfillment of the public mission of credit unions.
  4. Credit unions, unlike many other participants in the financial services market, are exempt from Federal and most state taxes, because they are member-owned, democratically operated, not-for-profit organizations generally managed by volunteer boards of directors and because they have the specified mission of meeting the credit and savings needs of consumers, especially persons of modest means.
  5. Improved credit union safety and soundness provisions will enhance the public benefit that citizens receive from these cooperative financial services institutions.
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The Power of a Single Person

Most of us bristle a little bit when we feel our agency is really limited and there’s nothing we can do about it,

One of the potential advantages of credit union democratic governance is that each person has an equal vote on the annual election of directors and mergers which end a charter’s life.

In both cases this potential for a single member to make a difference often creates anxiety and pushback by those in power.   A current example of this fear is the reaction  by the board of SECU (NC) to former CEO Jim Blaine’s repeated critiques of the credit union’s direction and lack of transparency.

After two years of contested board elections in 2023 and 2024, SECU’s Board made sure in 2025 there would be only the number of candidates as there were vacancies, thus ending a brief span of democratic member choice.

SECU’s conduct is not alone. It is the SOP for most large credit unions.   And in mergers, the process is even more controlling as there are billions of dollars up for “change of control.”

So can one person make a dfference when all the traditional forces are aligned against democratic practice, when regulators are AWOL and the members seduced by their unrequited loyalty to their coop?

One Person’s Effort to Challenge Exploitaton

History shows again and again that one person can change the world, one event at a time.  Here is the story of Bernard Devoto as told in Garrison Keiller’sThe Writer’s Almanac from Sunday, January 11, 2015.

It’s the birthday of historian Bernard DeVoto, born in Ogden, Utah (1897). He loved the wide spaces and big skies of the West, but he felt like an outsider in his hometown — he was raised Catholic in a Mormon town, and he was too bookish and unathletic to feel comfortable there.

He studied English at Harvard. After graduation, he taught at Northwestern and then at Harvard, although he never succeeded in his goal of becoming a full professor there. He wrote a novel, The Crooked Mile (1924), and dreamed of writing the Great American Novel. Then he wrote a book on one of his literary heroes, Mark Twain, a book called Mark Twain’s America (1932). It blended literary criticism and history, and DeVoto found he had a knack for nonfiction, and especially for history.

In 1935, he began a monthly column for Harper’s, “The Easy Chair,” which he wrote until his death. He covered a huge range of topics: the evils of McCarthyism, detective novels, the Civil War, railroads, the Western landscape, the best way to make a martini, and international politics. . .

In the summer of 1946, DeVoto took a three-month road trip through theWest. He had been writing about the West on and off for years, and had just finished two books set there — a novel and a history of fur trading. He wanted to revisit the place in preparation for a book on the Lewis and Clark expedition, and he thought he would write some essays during his trip.

He was horrified by the land abuse that he discovered there. The novelist Wallace Stegner, who wrote DeVoto’s biography, said: “DeVoto went West in 1946 a historian and tourist. He came back an embattled conservationist.” Commercial interests — especially cattle grazers and big timber — were attempting to take back huge amounts of public land, and DeVoto coined a phrase to describe it: a “land grab.”

Instead of the lighter travel pieces that he intended to write, he wrote a series of essays for Harper’s criticizing the assault on natural resources and the exploitation of wilderness. He described how politicians and businesspeople were conspiring with cattle ranchers to open public lands for grazing, and how timber companies were trying to clear-cut national parks.

In one of these essays, “The West Against Itself,” DeVoto wrote: “So, at the very moment when the West is blueprinting an economy which must be based on the sustained, permanent use of its natural resources, it is also conducting an assault on those resources with the simple objective of liquidating them. The dissociation of intelligence could go no farther but there it is — and there is the West yesterday, today, and forever.”

The preservation of Western land and resources became his life’s work. DeVoto lived for just nine more years after his summer road trip, but in that time he published more than 30 essays about Western conservation. . .

The Liquidation of Public Property

I chose this eample of one person’s influence because of the many parallels with today’s credit union’s practice of exploitive mergers.

In almost all these transactions now, members are showered with promises of future benefits while their legacy heritage is taken away and given without compensation to unknown third party control.

Credit unions like the natural wildness on public lands, grow organically from the ground up.  They must start with a core group of common interest to be chartered.  Afterwards it will take a generation or two of member loyalty to become self-sufficient.

Today these merged firms with millions and billons of dollars of asset growth funded with public purpose and tax exemption. are routinely chopped down  after generations of growth and prosperity.

These naturally created dynamic organizations are broken apart for their individual pieces of market value. The member-owners who supported these “forever” institutions are left with nothing except the rhetoric of marketing and PR phrases never defined and quickly forgotten. And the financial spoils are dispersed among the arrangers.

The question remains.  In a democratic institution can one person make a difference, sound the alarm and mobilize others to oppose this predatory behavior?

I’ll give an example of one who had the tenacity to throw back the covers on mergers.  Then see who else might be willing to come forward.