Category: NCUA

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The Most Consequential GAC Speech in Credit Union History

NCUA Chairman Ed Callahan  spoke to CUNA’s GAC conference in Washington DC on February 8, 1984.

He urged his listeners to support the most vital change in the system since the passage of the FCU Act in 1934.

His title was Finish the Job.  He challenged credit unions to strengthen their NCUSIF insurance fund by backing legislation redesigning it using cooperative principles.

The talk is  11 minutes.  Ed provides an update on the state of the credit union system in one word, “fantastic.” He puts the current situation in the context of 75 years of credit union history.  He describes how deregulation is meeting the needs of the country’s changing economy.

An Advocate for Credit Unions

His closing is a call to support a Better Way for  the NCUSIF.  He asks credit unions to compare the cost savings under the 1% solution to the current two premium model.  And then to champion the change in a bill introduced by Senator Jake Garn.

The recording is from a cassette of the live speech with the video overlays added later.

(https://www.youtube.com/watch?v=1UcXPyUMtic)

This is an example of the profound change possible for credit unions when all parties work together to benefit members.

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GAC: NCUA Board Members’ Most Critical Talks

The annual Governmental Affairs Conference in Washington is the largest and, many would say, the most important convening of credit union leaders.

In the nation’s capital, attendees from around the country will hear from their congressional representatives.  And from all three NCUA board members on the state of agency policy.

Today’s Washington is not a kind place. Tens of thousands of public servants  have been summarily fired.  Many remaining are at best uncertain and at worst fearful for their personal and professional futures.

The pretense of eliminating waste has been quickly demonstrated to be a political fraud.  An unelected,  billionaire, Elon Musk, who recently used a chainsaw to present his approach to responsibility is in charge of this political stunt.

Trump’s purpose is not governmental efficiency. Rather it is  eliminating any federal role that acts as a check and balance over the animal spirits of the “free market” and its billionaire oligarchs.

The NCUA Board’s Opportunity

Institutions, no matter how well funded and designed, cannot in themselves be constraints on abuses of power.  Or destruction of the democratic process.

It is the people who are appointed as well as those who are elected that must exercise this critical responsibility.

For credit unions, their immediate representatives are the three-person NCUA board responsible for the agency’s management.  That is why their views  are so important.

What credit unions want to hear is how they are interpreting their responsibility having taken this oath of office:

I, [Hauptman, Harper, Otsuka] do solemnly swear  that I will support and defend the Constitution of the United States against all enemies, foreign and domestic; that I will bear true faith and allegiance to the same;  that I take this obligation freely, without any mental reservation or purpose of evasion; and that I will well and faithfully discharge the duties of the office on which I am about to enter. So help me God.  (emphasis added)

The US Constitution requires the practice as explained in this 2019 article:

The reason is simple – public servants are just that – servants of the people. After much debate about an Oath, the framers of the U. S. Constitution included the requirement to take an Oath of Office in the Constitution itself. 

Article VI of the Constitution says, “The Senators and Representatives before mentioned, and the Members of the several State Legislatures, and all executive and judicial Officers, both of the United States and of the several States, shall be bound by Oath or Affirmation, to support this Constitution .  

The author, Jeff Neal,  states the intent:  One purpose of the Oath of Office is to remind federal workers that they do not swear allegiance to a supervisor, an agency, a political appointee, or even to the President. The oath is to support and defend the U.S. Constitution and faithfully execute your duties. The intent is to protect the public from a government that might fall victim to political whims. 

Where Political Power Lies

The three NCUA board members’ remarks in this current effort to concentrate political executive power in one person will be telling.

Will they simply state their role is to “comply” with the administration’s numerous directives of unlimited executive authority over an independent agency?

Or might they simply state their role as guardians of the NCUSIF purse and “protectors of the taxpayer” is their highest duty?

Or will they simply ignore reality and give an AI-like generated talk on regulatory priorities?

NCUA board members’ press interviews and comments at last Thursday’s public board meeting suggest they are still uncertain what their stance should be. One can understand their personal jeopardy and hesitancy to speak up.  In their remarks, all three were like  bipartisan deer frozen by the Trump administration’s headlights shining on all federal agencies.  The sense of an overriding mission was at best formulaic.

But as the board members look out over the thousands of attendees in the convention center, they will see where their responsibility and true power really lies.  It is with the people.  For the grassroots may be slow to mobilize but will be unstoppable when activated for purpose.

The political temptation is to always seek a middle way, a consensus.  All Americans and the rest of the world saw last Friday that we no longer live in “normal times.” When a leader of the free world visited the Oval Office and was publicly scolded by the President and his colleagues for not being “grateful,” for not having any “cards” to play, for “threatening WW III,” we know we are not living in normal times.

The people to which NCUA board members will be speaking at GAC and beyond hold the ultimate authority.  How will they fulfill their oath of office?  The circumstances are not easy, but leadership in crisis is what the Constitution depends on.

 

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Tomorrow’s Critical NCUA Board Meeting:  An Opportunity to Demonstrate the Strength of an Independent Cooperative System

The prime agenda item for Thursday’s NCUA board is the NCUSIF’s year end audit and setting the NOL cap for December 2025.  The political context in Washington at this moment makes this  meeting critically important.

Will the public discussion reinforce the understanding of the Fund’s  extraordinary performance and its unique  cooperative design?   Will its decade long performance of insured losses below a basis point, confirm its critical role in credit union’s unique purpose in America’s financial system?

The Political Context

The 2024 external CPA  audit was released last week.   It continues to show the financial stability of the cooperative system and the strength of its unique deposit insurance model.

This track record  is especially vital in this time of an administration challenging all aspects of federal agency performance.  This includes the federal regulatory structures, including FDIC’s oversight. For some the NCUSIF’s functions appear quite similar.  Could its future also hang in the balance?

It will be vital that the Fund’s uniqueness be affirmed during this update.  Especially these three characteristics:

  • A unique funding model; Every credit union member contributes directly 1 cent of their insured savings dollars to the NCUSIF’s 1% deposit base.  This member-centric capitalization is a direct copy of cooperative business design.
  • Explicit statutory guardrails on fund performance: There is complete and timely transparent reporting marked by the annual  independent CPA audit and monthly public financial postings.   Statutory limits are provided on total balances and a dividend paid to the owners, when this CAP is exceeded. Premium assessments in the event of catastrophic events, are clearly defined.  Premiums have been used only three times in the fund’s 40 year history.
  • The right to withdraw. If a credit union changes its charter or insurer their accumulated 1% deposit is returned. All 1%  deposits are returned if NCUA ceases to manage the fund.

How Board members present the NCUSIF’s demonstrated financial success may be crucial to its continued independence, not to mention NCUA’s.  If credit unions lose their fund in a regulatory realignment, would the singular credit union system be far behind?

Key Performance Issues

We knew yearend 2024 financial outcomes would be superb based on the November 21, 2024 NCUSIF board update as of September 30.  The yearend equity ratio is above .302%  showing the importance of the NOL cap. If it had been at its longtime cap of 1.3%, credit unions could have received a small dividend for 2024.

Will the Board’s discussion of this and other topics be anchored by full transparency, supported by real facts and the historical record versus hypothetical conjecturing?

The fund’s effectiveness is not based on its total assets, but rather, as in all insurance underwriting,  its size to relative to insured risk.  For example, the allowance account at $237 million is set aside from retained earnings.  It equals 1.3 basis points of insured savings at yearend.  Only once in the past ten years have total cash insured expense losses exceeded reserve level.

Specific areas of importance for board oversight include:

  1. How will the NOL cap for December 2025 be set? This limit triggers a dividend when earnings raise the yearend ratio above this number. There was no data provided when the Board set the NOL for 2024.  It simply extended the prior year’s limit,  no analysis provided. Even the detailed assumptions used by staff in the prior two years did not support their 1.33% recommendation. Will  real numbers be provided with full details of any hypothetical assumptions? Or, might the board simply endorse the historical 1.3% cap used in the first 33 years following its redesign?
  2. The greatest internal risk to the Fund’s effectiveness is the management of its $23 billion investment portfolio. Since December 2022, the portfolio’s maket value  has been less than its book, that is underwater.   The portfolio’s 2024 full year return is 2.5%. The overnight cash portion yields  approximately 4.5%.  The below book term portfolio earned just 1.92%.

Yet the fund continues to invest long in November, extending its duration risk, at a time of a reset in what a normal yield environemnt may be.  To sustain the Fund’s equity ratio a yield between 2.5-3.0% is necessary based on 40 years of actual operating results. The critical topic is what will the board require to improve the Fund’s interest rate risk management and turn around this continuing portfolio underperformance?

  1. The fund’s transparency is critical to its public credibility and trust. The allowance account is determined using an “internal econometric model.”   The model’s details and assumptions should be included in the staff’s presentation.

The continued use of Federal, not private GAP accounting misleads, mischaracterizes and  distorts the fund’s actual financial standing.  The terminology and schedules used with the Fund’s accounts are totally irrelevant since the NCUSIF is not an appropriated entity.

Federal GAAP removes specific information accounts from the NCUSIF’s financial statements.  For example is the portfolio’s actual value $22 or $23 billion?  Where is the net income total?  Or  retained earnings?  These traditional GAP terms do not appear.

The federal terms and schedules used are not relevant for the NCUSIF and convey an incorrect impression that the NCUSIF is somehow a federally appropriated fund. Or red meat for an uninformed DOGE analyst.

At a minimum private GAP financial statements presentation should be presented alongside the Federal GAP.  For private GAP is how all three of NCUA’s other managed funds are presented.

I am looking forward to the meeting.   Every credit union should as well.

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A Q & A on NCUA and Trump Policy Priorities

What has been the impact of the Trump administration’s executive orders on NCUA operations? After appointing republican member Hauptman as the new chair of the three person board, have there been other changes?

Following are a series of Q&A’s sent to NCUA last Friday to learn about  further impacts.  Responses were received today from an NCUA spokesperson.

Q. Have NCUA policies on working in the DC office been changed?  If so in what way?  If not changed, what is he current in-office policy for the head office?

Pursuant to President Trump’s Return-to In-Person Work Presidential Memorandum, NCUA non-bargaining unit employees are required to return to office, full time, beginning Monday, Feb. 24. NCUA employees in field positions (mobile workforce), including but not limited to examiners, problem case officers, supervisory examiners, and regional specialists, are not within the scope of the Presidential Memorandum.

Q. Has the NCUA withdrawn job offers since the change of administration?   Is there a hiring freeze?

The NCUA rescinded 12 offers in compliance with the Executive Order instituting a hiring freeze for all federal positions.

Q. Have there been any changes in senior staff responsibilities under the new chair?

No.

Q. Did NCUA employees receive the resignation emails DOGE sent to all federal employees?  Is NCUA staff eligible to apply for this option?

NCUA employees received the same communication sent by OPM about the deferred resignation program. NCUA staff are eligible to participate in this program.

Q. Has NCUA stopped payments under any contracts or programs it administers?

Four DEI contracts have been terminated.

Q. Have members of DOGE or its representatives contacted NCUA or been in NCUA’s offices?

None yet.

Has Chairman Hauptman filled any of his vacant Schedule C  positions?  If yes, their titles and names?

Not yet. When these positions are filled they will be publicly announced.

Currently, Chairman Hauptman’s immediate staff includes Chief of Staff Sarah Bang and Confidential Assistant Natalie More. Three positions allocated to the Chairman are currently vacant.

Q. Who is the best person to contact during this transition period to learn about events?  Should I reach out directly to individual board members? Or, can you set these up?

Please contact NCUA’s Office of External Affairs and Communications.

Q. When is the next NCUA board meeting and when will an agenda be released?

The next NCUA Board meeting will take place on Feb. 27. The agenda will be posted to the NCUA’s website on the afternoon of Feb.20.

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The Source of Credit Union Power: Members Rally to Rebut Banker’s “Hit” Article

“You will pry my credit union from my cold middle class dead hands.”   Words of defiance from a credit union believer. One of hundreds of comments posted last week.(source below)

A leader’s ultimate success much depends on how the person manages the instruments of power.  For some in authority, the point of power is to use it to expand one’s dominion.  Using requires building up an institution’s size, scope of activity and resources to control or dominate.

However, there is another leadership model.These individuals believe that the role of authority is empowering others.  Credit unions at their most effective are subversive of status quo structures. They organize from the bottom up.  By the grass roots, not by investors hoping to make money.  No capital, just personal sweat equity, time and collaborative effort to accomplish common purpose.

This counter-cultural, not-for-profit cooperative design is also the key to  credit unions’ latent political power.  Here is a case study from last week of what this looks like in practice.

Responding to a Newspaper Opinion

Last week the Washington Post published an Opinion article by the former chair of the FDIC, Sheila Bair, titled:   Tax-free credit unions are thriving at public expense.  Her bank in Chesterton, MD, The Peoples Bank, accepted a purchase offer from a Massachusetts credit union “using some of their untaxed income.”

Her article referenced other examples of credit union branding and expansion.  Her recommendation was to level the playing field with community banks by taxing credit unions.  Otherwise, she warned, ““Give them an inch and they’ll take a mile.”

I had used the credit union’s purchase of “her” bank as an example in a blog Time to Ask WHY.  My p;oint was to illustrate the bigger public stage on which credit union actions are now viewed.

I did not foresee the  Post’s readers’ reaction to her article.   When the postings were stopped 253 comments had been submitted, almost all from credit union members.

The members universally defended their credit unions, called the article a “hit” piece, and provided hundreds of firsthand examples of how credit unions provide special member value.

Following are a few examples of the readers’ responses unleashed by this former banking regulator’s critique of credit union’s tax status.

From a bank customer and credit union member:

I have business both with a major bank and a credit union-right now the rate on my major bank credit card is 27.99% (they cut my rate a whopping 2% from 29.99% a few months ago!)

Right now, the rate on my credit union credit card is 8.99%

 You can probably surmise from the above anecdote who gets most of my business… 

From a 30 year member::

I have been a credit union member for 30 years. No hidden fees, low interest credit card, interest on my checking and savings, no service charges, talking to real people, great service, the list goes on and on. I would prefer to never have to deal with a bank again. I’m sure big banks would love to crush credit unions.(Reader comment ratings:  Provocative/Thoughtful 61)

From a member with mortgage loans for 37 years;

I’ve had a mortgage since 1988 on my successive residences, usually with an escrow account to pay property tax and homeowners insurance. Refinancing in 2012 with a credit union was the first time I managed to persuade my lender to include California Earthquake Authority premiums in the escrow account associated with my mortgage.

I’ve been much more satisfied with the service I’ve received from a credit union than from any of the big banks I’ve patronized over the years…. 

A Question posed: The difference, who cares more about you?

Ask yourself a simple question. WHO cares more about YOU as an individual? A big bank or the credit union where you are a member?

Notice that YOU are a member of the credit union – not just a customer. With banks – YOU are just another income source.

A question: Why the article?

Of all the non-profits that exist (and ALL credit unions are non-profit) – why attack the one group that actually takes care of their members instead of pushing propaganda as part of a political agenda?

 Attacking the for-profit Washington Post:

Wow, taking a shot at non-profit banking!?!? Proof once again that the Post is in the bag for corporate interests. Where is the guest opinion on the mis-deeds of for profit banks? Instead of recommending that credit unions return to stricter membership rules, or limit their ability to purchase commercial banks, you go right for their non-profit status. I have not used a for profit bank in 25 years. Thankfully almost everyone on Capitol Hill banks with the Congressional Federal Credit Union (as do I) so they understand the value of a credit union. 

A comment on the Opinion author:

As others have pointed out, Shelia Bair was chair of FDIC during the 2008 financial meltdown. She was a major architect of the TARP bailout of Chase, Bank of America, Wells Fargo, and the other big banks. 

This is an unadulterated hit piece against Navy Federal Credit Union, which is competing with the big banks directly in their consumer banking business. 

How and When Is Member Power Mobilized?

The comments extend for another 240+ reader reactions.   These words are not lobbying jargon, irrelevant numbers or cliches.   They are from lived experience motivated by personal feelings.

Implicit in these words is a readiness for action.  This potential  is the real source of credit union power, not the amount of PAC dollars donated.  It is the member-owner-voter’s relationship with their credit union.

This foundation of the movement is a latent,  “sleeping giant”-a phrase used by Ed Callahan during the 50th anniversary of the FCU Act in 1984 and afterwards.  Deregulation had placed  the responsibility for the future of credit unions back where it started, in the hands of boards and members, not the federal government.

The Immediate Challenge

America is in an era of political disruption. The issue of taxation will undoubtedly arise in several contexts.  But the real challenge of crafting a new beginning, a rethinking of who we want to be, is much greater.  And it may be beyond the grasp of those who seek only to defend the existing co-op status quo.

What is necessary are new models to tackle critical opportunities for clarity about credit unions’ future role in the American economy and members’ lives.

The country is hungry to reset foundations, recommit to fundamental values and for new generations of leaders who can innovate with cooperative design.

We should avoid marketing our fear of change to garner internal support, but rather take this fluid moment to rally our members for a renewed vision of what we can be.

And like the initial founders, or the change makers who led deregulation, this new era can be both frightening and enlightening.  This redesign may involve both government/regulatory relationships and new realities for industry participants taking  responsibility for our future.  It may entail new organizational relationships and partnerships.

If one looks closely the seeds for a new future are already there.  Some have been planted by those seemingly old school; others are in the enthusiasm of a generation that seeks to change the world.  Our skill will be to identify those whose directions empower others with their vision, versus those intent on enhancing their existing legacy returns.

Let the conversations begin.   If you have any doubts about what members value, just go the article and read some of the several hundred more comments.   The members’ voice is there if we really listen.

 

 

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The Art of a Leadership Transition in Government

The country is going through the political throes and formal processes of a complete changeover  of executive and political leadership in DC.  This includes NCUA.

In late 1981 Ed Callahan had been confirmed as the next NCUA Chair. Before he had been formally sworn into the job, I asked what would be his toughest challenge would be.

Ed had been leading the Illinois Department of Financial Institutions for almost six years.  In the Department, the credit union division oversaw  1,200 state charters.  During this time the Illinois system had navigated multiple market and legislative changes implementing deregulation.

I assumed his response to my question would be about greater scale of responsibility, from one to 50 states and from 1,200 credit unions to 16,000; or, the increased size of the agency budget and staff; or, the more complex institutional and political environment in DC.  This involved Senate and House hearings and NCUA membership of interagency committees such as the FFIEC or DIDC.

Ed’s Number One Challenge

His answer mentioned  none of the above areas.   His biggest challenge he said would be  communication.   That is to explain the direction he believed the NCUA and credit unions should undertake and why.

Callahan’s track record and leadership of Illinois cooperatives  was described as deregulation.  At a dinner celebrating his appointment before  going to Wasington, the Illinois Credit Union League presented Ed with a framed sign  he then hung in the Chairman’s NCUA office.  It read:

 Leadership of a Transition

However, what would deregulation look like on a national scale and all at once?

The first effort communicating this approach was a videotaped panel discussion arranged by the Illinois Credit Union League on January 8th, 1982.  The title:  Deregulation, What Does it Mean?

 

(https://www.youtube.com/watch?v=S09QkeNYgBU&t=4s)

The video is 24 minutes. This  conversation was the beginning of a dialogue to change the entire direction of the prior 50 years of federal credit union regulatory practice.

Several factors in this video are noteworthy.  It was a joint NCUA-movement project. The Illinois League sponsored and produced the video.  The panel included Jim Barr, the head of CUNA’s Washington office as moderator, three credit union CEO’s, and Chairman Callahan and NCUA Executive Director Bucky Sebastian.

The format is Q&A.  Hard questions are asked. The dialogue is authentic due to the openness of the conversion.

The most important moment may be at  minute 16.  A CEO responds to Callahan’s deregulation approach  by asking how much influence will credit unions really have in deciding this policy?   Ed’s reply from the February 1982 NCUA Review, which printed a transcript of the video:

“Even though I think credit unions want deregulation, I am more committed to the fact that we have to respond to their needs. If they don’t want deregulation, we will see that it doesn’t happen.”

A second question by Jim Barr is simply.  Why now?  Go to minute 18 for the response.

This video was the first of 20 NCUA created during  Callahan’s three and one half year tenure. It was  one of many efforts to inform credit unions and the public about NCUA actions.  To succeed, this approach required a leader who was accessible, informed  and willing to listen to the industry.

The result was a tenure characterized by joint NCUA-industry efforts that repositioned the system for an entirely new era of market competition.

This video is one example of how the regulator and the industry collaborated so that the movement could thrive well into the future.

Communication went to all constituencies.  These included the public and credit union press, the members, credit union leaders and other agencies of federal and state government,  The outcome included some of the most consequential  cooperative system innovations since the first credit union charter in 1909.

Leadership is never easy, especially in public positions.  Developing and seeing through a successful  tenure begins with the very first communication.  In this transition. that began with a video that still provides meaningful lessons decades later.

 

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Getting After It-The Art of Leadership in Transition

Authority attracts followers.   The power of a position is a reality whether that role is CEO of a credit union, a company, a regulatory agency or an elected official including the President of the United States.

People and the public have an instinctive respect for those in authority.  But the process of validating one’s leadership is different for those in elected versus appointed positions.  For appointed roles, there is a presumption of industry expertise or other skill that warrants the responsibility.   The first steps matter.

Getting After It

Whichever path to leadership most will  act quickly to affirm their new authority, sometimes dramatically. It both enhances the role and the perception of being in charge.

President Trump claims an electoral mandate “landslide.” In just one week he has issued dozens of executive orders, traveled widely across country, spoken to an international conference all in a very deliberate campaign to show there is new Sheriff in town.  Getting after his agenda in a very public and energetic way, enhances Trump’s claims and intent to exercise his vision for the country.

NCUA Board Leadership

This impulse to demonstrate  newly awarded executive power is also practiced by incoming NCUA board chairmen. This is especially the case when board appointees have little or no previous relationships with credit unions.

In February 2021 shortly after appointed chair by President Biden, Todd Harper announced his promotion in a Commander’s Call address to the Defense Credit Union Council.

As the COVID-19 pandemic rages on, we must smartly, pragmatically, and expeditiously address the economic fallout within the credit union system. To that end, when I first became Chairman, I issued my Commander’s Call to the agency.” 

Time and again Harper used the imminent  threat of “economic fallout” during his leadership independent of the industry’s performance and or critical mission issues.

In this same tradition, several days after being appointed Chairman Kyle Hauptman published his eight priorities in a press release.  Many read like summaries from prior board meeting statements.  Like Harper, he wanted to put his views out immediately.

These initial pronouncements were an assumed first step in asserting the authority of an appointed versus elected position in government.  NCUA chair’s will routinely reference a  restatement of safety and soundness oversight.  Or in some cases an adaptation of the Administration’s governing priorities.

In Hauptman’s new role an important question will be how Trump’s priorities for the federal bureaucracy shape his administration.  This is especially true for personnel policies and appointments, agency spending and regulatory and rules review. Will he assert NCUA’s independent agency status or try to implement Trump’s efforts to reform what the president calls the deep state?

The Most Critical Agenda Issue

While these opening statements are part of the ritual when appointed to NCUA leadership, the most important question that all chairs must answer is, In whose interest will they serve?

Will it be incoming administrations?  The agency staff? Or the needs of credit union member-owners and their communities?   Each constituency wlll have its special claims and interests.

When NCUA leaders arrive without a track record of working within the credit union system, the assertion of agency priorities can easily overlook the most important issues the industry faces.  It is easy to repeat the regulatory mantra of safety and soundness without having to explain what that means.  For example, from 2007-2024 the losses to the NCUSIF have averaged less than 1 basis point per year.  So what are the underlying performance issues?

The Credit Union Way for Developing a Relevant Agenda

I believe the most important priority for NCUA leadership should focus on the credit union member-owners.   “It’s the member, stupid” is how one prior leader explained the challenge.  But how does one put members first?

The answer lies at the heart of the cooperative model.  Leaders within the credit union system must talk with and listen to credit unions.  For a relevant regulatory agenda, NCUA and credit unions should be co-creators for  setting the priorities to enhance the mission of the cooperative system.  And the well-being of its owners.

Not all credit union decisions involve a regulatory issue.  But credit unions need to recognize individual actions can have system wide consequences on the reputation and public support for their special status in financial markets.

Just as Hauptman has drawn up his initial talking points, so too are credit unions, or their lobbyists, asserting their priorities: protecting interchange fees, the tax exemption and reducing over-regulation.

But are these the primary issues that should form a collaborative agenda for the next four years?   How do credit unions balance their increasing financial stature with the absence of any effective member owner governance?

Is the growing mergers of sound credit unions and removal of local roots in the long term interests of the members?   What is credit unions unique responsibility, if any, in addressing the needs of individuals left behind or the macro issues such as the national shortage of affordable housing?

Ultimately an effective leadership agenda is a collaborative process.  No institution has all the answers. Listening to competing agendas and reaching a consensus is the art of political compromise.

Some “leaders” will want to avoid this task preferring to assert the power of their appointed or earned positions.  Getting after it  may work in the short run.  Americans respect authority implied by the rule of law.   But it is not a formula for lasting change as we see the current approach of a new administration just overturning the priorities of the former.

Credit unions and the regulator are at their most effective when each uses their special skills and experiences to work cooperatively furthering the best interests of members, not a partisan agenda.

Here is an example of how an NCUA board and credit unions responded to the issue of the movement’s federal tax exemption in a prior administration transition.

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A Lesson from the Past: Could NCUA Be Reorganized Away?

While credit unions focus on the threat of federal taxation, there is another event that could end the independent cooperative system.  To understand how governmental agencies are reorganized, it is useful to review what happened to the separate S&L industry after a decade long series of industry and regulatory failings.

From an Inspector General Report dated March 2012: Title III of the Dodd-Frank Act sets forth provisions to address problems and concerns in the multiple agency financial regulatory system by abolishing OTS and transferring its powers and authorities to the FRB, FDIC, and OCC as of July 21, 2011 .

All OTS functions relating to federal savings associations, all OTS rulemaking authority for federal and state savings associations, and the majority of OTS employees transferred to OCC; OTS’s supervisory responsibility for state-chartered savings associations and OTS employees to support these responsibilities transferred to FDIC; and OTS’s authority for consolidated supervision of savings and loan holding companies and their non-depository subsidiaries transferred to FRB.

Prior to this 2011 transfer of supervision, chartering and examination, the separate FSLIC insurance fund had been merged into the FDIC in two steps.  The FSLIC was abolished in August 1989 and replaced by the Resolution Trust Corporation (RTC). On December 31, 1995, the RTC was merged into the FDIC which became the sole deposit insurer for all thrift institutions.

The Presidential Transition Center describes one surviving regulator’s situation today: “The OCC is one of eight Treasury bureaus and has approximately 3,850 total employees. Headquartered in Washington, D.C. It has four district offices and a London office that supervises international activities of national banks. Operations are funded primarily by assessments on national banks and federal savings associations.”

Current numbers under OCC responsibility are  approximately 1.500  national banks and federal savings associations and 50 federal branches and agencies of foreign banks.

The administrative head, the Comptroller, is nominated  by the President to a five year term and confirmed by the Senate.

As of mid-2024 there were 556 surviving savings institutions.  There was no single regulator however. Supervisory oversight of their $1.2 trillion total assets was divided among the OCC-242, the FDIC- 278 and the Federal Reserve-36.

An  independent consolidated thrift industry does not exist today.  Depending on each institution’s charter history and scope of operations, regulatory oversight is divided among the three federal banking agencies.

The Relevance of History

A goal of the Trump administration is greater governmental efficiency. Combining regulatory agencies is not a new idea. Merging the cooperatively designed NCUSIF into the FDIC, closing the unused  CLF and transferring  chartering and supervision to a new Treasury bureau would seem a reasonable proposal-for some.

A New North Star: Faster Alone, Farther Together

How might a single OCC administrator view this possibility?  The following is from an exit interview with the acting OCC head during the Biden administration:

Michael Hsu, a longtime bank supervisor and former top Fed staffer, threw himself into what he describes as a dream job: running an agency full of examiners. The OCC chief was at the table as officials managed through a regional banking crisis and a crypto crash.

MH: I made safeguarding trust the North Star for all that we were doing…I feel good about what we’ve done.

I’m most interested in long-term, durable wins. I’ve been in government for 20 years, over 20 years doing this stuff. There’s nothing more frustrating than this kind of fleeting, pendulum-swing of announcements. . .

There’s a saying: Faster alone, farther together. I say it to my staff all the time, which is frustrating, because sometimes we have to slow down…But if you just do it alone, you can get the quick win, but then the next guy is just going to undo the quick win.

Responding to a Reorganization Review

To counter the inevitable suggestions for more coordinated financial regulation, the so-called level playing field, requires rethinking what is being communicated at every level about credit unions today.

Some areas for messaging might include:

  • An NCUA led by informed and articulate leaders presenting the contributions and role of credit unions and cooperative design to the pubic and Congress;
  • An industry performing with stable and successful financials capable of responding to ever-changing markets;
  • Meeting public and individual interest in and demand for cooperative charters to lift up local groups and communities;
  • Daily examples of member-owner benefit that rises above traditional service and product options from for-profit providers;
  • Leadership at all levels communicating the advantages of cooperative design. A former NCUA executive director once summarized credit union’s purpose with the phrase:  “it’s the member, stupid.”

Much of today’s credit union commentary reads and sounds like all the other lobbying and jockeying with a new administration.  Protect the status quo.  Align one’s vision and “asks” with the incoming administration’s priorities.

That apprach may be smart politics.  But credit unions did not succeed by preserving the status quo.   What will their role be in responding to the numerous areas of unmet member needs and expectations?  That response will position NCUA and credit unions as leaders for greater contribtions or, if not, as a part of  governmental policy that needs rethinking.

 

 

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How Will Trump Administration Policies Affect NCUA?

In a full first day of pomp, circumstance and executive orders, a new regime took over the leadership of the U.S. government.  Among the new President’s many actions was appointing Kyle Hauptman as Chairman of NCUA.  What will this mean for the agency and credit unions?

Among the blizzard of Trump’s first day executive orders were a number directed at the administration of federal agency management.   These orders included:

  • The requirement for all employees to return to office five days per week;
  • A freeze on hiring;
  • The removal of civil service protection on senior positions.
  • Ending all DEI training and policy implementation.

There were also multiple references to eliminating regulations and sending the people’s money back to them via reduced spending, and maybe lower taxes.

Chairman Hauptman’s term expires in August of this year.  Will he follow these priorities of the new administration or assert independent agency status, and therefore not bound by these initiatives?

Hauptman has a number of initial decisions that will indicate what his governing practice will be including:

  • Who does he add to his team as appointees and what is their professional experience–credit unions or government employment? Or, purely political patronage?
  • What is his governing philosophy? Is the job a full-time leadership responsibility for the agency, or merely a policy setting role delegating to staff all interpretation and implementation?
  • What is his view of the role of the cooperative credit union system? Is the coop design unique, or just another form of financial choice in the marketplace?  How does he assess the major trends in the industry including merger-acquisitions, the buying of profitable banks and the suggestion that credit unions be taxed?

Preparing for the Role

Hauptman announced his intent to become chair posting “openings” on LinkedIn several weeks ago.   His view of credit unions and a governing agenda have never been spelled out.  His statements on policy have been in response to Harper proposals, which he has largely supported including the longest, most intrusive rule NCUA ever added to the books, Risk Based Capital.

What will be his leadership style as Chair?   How accessible will he be to the public, the press and to the credit union community?   Will he listen in conversations or deliver scripted positions?  Will he present objective and fact-based priorities or rely on general cliches about government’s role?

Can he articulate common purpose with the cooperative system founded on collaboration, or will he assert NCUA’s independence from credit union’s destiny or fate?

When problem events occur, will he respond with factual answers, send out staff to reply, or worse, just stay silent and avoid any comment as the press reports on credit union shortcomings?

People, especially those working in credit unions serving members, want to hear from their regulators.   The coop democratic structure is intended to give responsibility to the members and their chosen leaders.  Openness builds trust and confidence.  Distance undermines the collaborative advantage which is the foundation of two vital NCUA facilities: the CLF and the NCUSIF.

The Learning Challenge

For both individuals and organizations to succeed they must become learning entities.  Responding to change is more than just adding new technology or professional expertise.  It means sharing  a vision while responding to the constant changes which we all face.

The Shakespearean actor Patrick Page stated that it takes at least 30 years to become an effective performer.  Acting first requires knowing thyself, the motivations and awareness that comes from life’s experiences, relationships and multiple roles.  But just as important is understanding the same characteristics in others-especially if you intend to present their character to the public in plays.

Leaders are formed in the same way.   Leadership is not conferred by appointment to a role—no matter how deserving the individual interprets his or her selection.  It is formed in the challenges of life—the wins, the disappointments and the strivings.

Now Hauptman has the chance to show how he will learn and lead.   The fate of an industry may depend on how successful his growth can be.

 

 

 

 

 

 

 

 

 

 

 

 

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Honoring our Cooperative Heritage

A June 26, 1984 gathering of “Old Timers:” current NCUA board members, prior Administrators, past General Counsels and senior staff celebrate the 50th anniversary of the passage of the Federal Credit Union Act.

Seated  left to right: Deane Gannon, Joe Blomgren, Richard Walch and Bernard Snelick.

Standing left to right: Joe Bellenghi, Austin Montgomery, Fred Hayden, P.A. Mack, Ed Callahan, Elizabeth Burkhart, General Herman Nickerson and John Otsby.

A statement of cooperative enterprise from a church’s bulletin board

LEGACY

All of us are indebted to the past,

to those who precede us.

We drink from wells we have not dug.

We enjoy liberties that we have not won.

We share faith whose foundations we have not laid.

 

At the same time,

We are seeds of the future,

for those who succeed us.

 

We dream and envision

and set things in motion.

The fruition of our decisions

will be known only to others,

whom we wll not meet.

 

We are called to partner in faith

with those who have gone before us

and to offer the best

that we have to give

to those who will follow.