Why the CLF Has No Interest

For over 15 years, the public-private credit union designed liquidity lender, the CLF, has had no activity.  The last major loans were to the NCUSIF for $10 million to pass through to US Central and WesCorp as part of the stabilization efforts when they were conserved by NCUA in 2009.

Liquidity Options

In April 2024 an $800 million credit union reported to the board their return on its two primary liquidity lender relationships as follows:

The FHLB declared and paid a 9.0% quarterly dividend last month.  Our capital stock value there is $1,884,000.

Corporate One FCU declared and paid a 5.75% dividend on all Perpetual Contributed Capital last month.  Our PCC there is $1,283,000. 

In contrast, the CLF reported its first quarter dividend as 4.54% which was down from 4.62% from the prior quarter.  That return is approximately 1% below the overnight rate credit unions are earning on risk free investments.

The CLF’s First Quarter Financials

At March 31, 2024 the CLF’s $895 million balance sheet was composed of $859 million in member shares and deposits and $41 million of retained earnings.  There were no loans.

The CLF’s primary assets are investments in Treasury notes ($819 million) and cash ($95 million).  At yearend the portfolio was $9.0 million underwater.  Why would a liquidity facility  ever invest longer than one year, let alone the $45 million extended beyond five years?

Moreover, the CLF has investment authority similar to FCU’s.  Why is it limiting its portfolio to just Treasury securities-generally the lowest return option in the market?  Does NCUA lack the investment expertise from staff who routinely evaluate the soundness of credit union portfolios?

The below market quarterly dividend means every credit union member is subsidizing the CLF.   The dividend decline is even more puzzling when the CLF reports adding $869,000 to retained earnings which now total over $41.1 million.

The CLF has no risk and no loans so why shouldn’t all net income be paid to its shareholders?  In the same quarter of 2023, for example, the CLF added only $3,000 electing to send all net income to shareholders.

A Vestigial Organ

The numbers show that the CLF has played no role in a year which saw record credit union borrowings and liquidity pressures from rising rates and banking failures.  CLF investments report below market returns. The dividends paid are not competitive.  That fact alone shows how detached CLF and NCUA leaders are from managing a facility that would actually serve the members who loyally fund it.

Contrary to NCUA board members’ entreaties for new Congressional legislation, the lack of credit union support for the CLF is not a statutory shortcoming. It is a management one.

Over decades the CLF has evolved to become a regulatory vestigial organ serving no purpose. As shown above, credit unions have liquidity options which they also own and which provide real value.

Isn’t it time the CLF decided to do the same?  Or at a minimum pay a competitive dividend before shareholders decide there is no reason to continue “bankrolling” a moribund facility.

Standing on the Shoulders of Others

Recently a CEO reported on a new event for his credit union:

Earlier this month the Executive Leadership Team and the Chairman hosted the First Annual Credit Union  Alumni Breakfast with 17 retired employees and volunteers. Special thanks to key staff for their work in putting on this special event.

Today we stand on the shoulders of these employees who have come before us as they laid the solid financial, operational, and philosophical foundation upon which we are building today.

We asked each attendee to share their favorite credit union memory.  They  can be summarized simply – the PEOPLE. To a person they shared that it was the members and/or colleagues that made this the best place they have ever worked.

They shared story after story about the changes in members’ and employees’ lives, and in many cases, how these interactions changed their own lives. We know that for so many of these retirees this was not just a job, but part of who you are.  So we will continue to cultivate that community, even after you have retired. These Alumni are some of the best Ambassadors in our community.

Celebrations Create and Honor a Shared Past

Yesterday was May Day, an informal, country-wide celebratory event in England.  My daughter sent several pictures of how the Day begins with the ringing of the bells and singing by the boy’s choir from the tower of Magdalen College. Oxford.

The event commemorates not only the beginning of spring, but the common destiny we all share with nature.

Merry Makers on the way to the Tower:

Bells ringing and boy’s choir singing to bring in Spring-with 14,000 early risers.

A Visit by Louise Herring to NCUA

In Ed Callahan, Bucky Sebastian and my first year at NCUA, Sam Rizzo who was the CEO of ASI (then NDGC) made a special  effort to bring to D.C. the last living attendee from CUNA’s founding at Estes Park, Colorado in 1934.  Louise Herring spent her entire life promoting, leading and founding numerous credit unions and supporting firms (such as ASI).  She had to travel attached to an  oxygen breathing cylinder.

Her mind and commitment were as sharp as ever.  Field of membership for FCU’s was a hot button issue. Her belief was that all Americans should have credit union access.  In her memorable phrase, “Poverty is not a common bond.”

The incredible chartering and organizational efforts of her era and the passion for the movement were apparent to everyone.

Louise is just one example of the pioneers who devoted their lives to lay the foundation for credit unions today.  Her commitment was a memorable experience for everyone she saw.

Recognizing past credit union regulatory leaders was an integral aspect of Chairman Callahan’s role.  Just one example. He honored his predecessors at NCUA and in the HEW’s  Credit Union Bureau by asking them to come to D.C. to celebrate the 50th anniversary of the Federal Credit Union Act in 1984.

Earlier that year Ed presented the Agency’s highest honor, a gold medal, to recognize many whose tenures were only recorded in official reports. (see Dean Gannon’s medal award)

Current and prior federal credit union regulators, General Counsels, and Executive Directors reunite  at NCUA’s headquarters, 1776 “G” Street, Washington D. C. on the 50th anniversary of the Federal Credit union Act.

The Past Makes the Present Possible

It is always tempting to believe when one achieves a position of great responsibility, that the future begins with their arrival.  The past is gone.  Those are the achievements of others.  Now it is our turn to pivot with new beginnings.  After all who wants to just carry forward the success of others when every impulse is to put one’s own imprimatur on events?

However, without a knowledge of the past it is difficult to sustain a sense of common purpose or community with others.  Each leaders turn at the wheel becomes a unique episode.  The lessons of prior efforts are overlooked.  The successes are taken for granted, because they seem just to endure naturally.

But that is not how lives or even organizations are remembered.  When individuals are at their best, their work and example transform the moment.   There is a moral component that recognizes the worth of each person, and a commitment to common good, not merely individual or organizational momentary success.

Every society has its May Day celebrations.  They create a shared heritage that goes back generations in England.

Current leaders and CEO’s of organizations may not know or even be interested in their predecessor’s  success or viewpoints.  The past leadership is gone and I am now in charge.  Some CEO’s are uncomfortable even talking with their forebears.

Knowing the history of any organization is vital to continued relevance. That is why I believe this credit union’s inaugural Alumni breakfast matters.  Honoring leaders from different eras and circumstances, gives meaning and context to current events and decisions. How a leader remembers their predecessors is a good indicator of how one’s own tenure is likely to be recalled.

 

 

 

“Climbing Ladders to Nowhere”

A reader sent the following after reading Ed Callahan’s last interview as Chairman of NCUA. In that conversation he focused on the relationships between the agency and credit unions.

Hey Chip – I am just reading this.  My husband and I were camping in the wilds of Utah with very sketchy service.  In the “old days” it truly was a partnership with the Agency. 

Being a CEO my entire career, I was always highly engaged with the Examiners when they were in my credit union.  It was always a very positive relationship where we learned from each other.  Unfortunately, it devolved over the years into an “I GOTCHA” encounter. . .

Losing Our Heart and Soul

Greetings Chip!  I continue to read your blog . . .  After the latest news about more Illinois credit unions merging, I finally felt compelled to write down my thoughts on this issue.

I will publish his thoughts in the future.  These are his opening paragraphs:

Credit union mergers have been happening for decades.  Some are forced by the regulators, some are voluntary, and there are a multitude of legitimate reasons.  But as I celebrate 32 years in this industry, it is still sad to see the number of credit unions that disappear every single year, and to see the pace of mergers pick up every year.  When we lose our small credit unions, we are losing the heart and soul of our movement that makes credit unions special.  

I know that no matter the size, credit unions are still member-owned, not-for-profit financial institutions.  But it is difficult to argue with the fact that as we grow larger, whether organically or through mergers, that members have less of a voice. . .  And I fear that we are becoming just another industry, instead of a movement.

No Longer a Movement?

There is no doubt credit unions are becoming more and more “mainstream.”  They tout their promotions with professional sports franchises, stadium naming rights and multiple business partnerships.

Growth is the dominant success indicator.  Credit union lobbyists argue in tandem with banks against the consumer protection initiatives of the CFP.  NCUA’s Chair cites the FDIC as a financial model for the NCUSIF and positions his supervisory initiatives  because that is how banking regulators act.

In becoming an important component in America’s financial sector, have credit unions also embraced the status quo?  Are they more concerned with protecting their achievements than addressing the economic inequities members face in the economy?

An observer might give examples on both sides of the “movement” issue.  However, I believe credit unions are not alone in their constant temptation to be seen as fully engaged participants in the so-called “free market.”

“The Only Game in Town”

Franciscan scholar Richard Rohr describes the ever-present allure of America’s economic system this way:

Most of us have grown up with a capitalist worldview which makes a virtue and goal out of accumulation, consumption, and collecting. It has taught us to assume, quite falsely, that more is better.

It’s hard for us to recognize this unsustainable and unhappy trap because it’s the only game in town. When parents perform multiple duties all day and into the night, that’s the story line their children surely absorb. “I produce therefore I am” and “I consume therefore I am” might be today’s answers to Descartes’ “I think therefore I am.” . . .

The course we are on assures us of a predictable future of strained individualism, environmental destruction, severe competition as resources dwindle for a growing population, and perpetual war. Our culture ingrains in us the belief that there isn’t enough to go around, which determines most of our politics and spending. . .

F. Schumacher said years ago, “Small is beautiful,” and many other wise people have come to know that less stuff invariably leaves room for more soul. In fact, possessions and soul seem to operate in inverse proportion to one another. Only through simplicity can we find deep contentment instead of perpetually striving and living unsatisfied. . .

St. Francis knew that climbing ladders to nowhere would never make us happy nor create peace and justice on this earth. Too many have to stay at the bottom of the ladder so some can be at the top. . .

 

Chairman Callahan’s Last Interview at NCUA

“It’s a partnership and it works”

Knowing our shared past helps us to understand the present and envision the future.  History provides our sense of community.

From the May 1985 NCUA News, Vol 2, No. 4:

From the recent interview on NCUA’s Video Network, Chairman Callahan praised the NCUA staff, saying, “It’s all working, the team is in place.   There is a sense of confidence in the Agency, and it has infected the credit union movement with confidence as well.”

The Chairman is quick to credit examiners and other Agency personnel for the successes during his term: “Most people at NCUA have a good sense of where the Agency is going and how they fit into the picture.  People at NCUA get the credit for what we’ve been able to accomplish because they brought us to the point we are now.” 

He believes three years of unprecedented growth in shares, loans, capital and membership attest to the positive effects of deregulation and to the success of credit union managers and directors when given the opportunity to make their own business decisions.

As important as deregulation is to Mr. Callahan, increasing the examiner ranks and getting Agency staff out in the field, closer to credit unions is just as important.  “Deregulation actually increased our supervisory responsibilities,” he said.  “We told credit union officials ‘You run our institutions, and we’ll be there to help.’  It’s a partnership, and it works.”

P.S.  See the reference above to NCUA’s Video Network.  This interview was the final edition, number XXI.  If anyone has this recording in their credit union collection, I would appreciate making a copy.

 

State Regulators and Credit Union Oversight

Who do members turn to when they believe their credit union is not responsive to requests for greater transparency or accountability?  These situations can arise around bylaw interpretation, board oversight, and election conduct.

Following are two examples of members’ interacting with their state regulator when they believe accountability is lacking in credit union conduct.

A Live Hearing-NOW

The first is a hearing of the North Carolina Credit Union Commission at 10:00 AM EDT today.  Several members have sought clarification of the regulator’s approval for bylaw changes, especially those that affect the board election process.  The toll free call in number is 1 (984)-204-1487.  The access code757767261#.

There are thirteen items on the agenda, but the primary one is an update by the state administrator, Kristina Ray, on all areas of her responsibility.   The ability to listen to a live state update is an important opportunity not just for North Carolina charters, but for all credit unions who are interested in the state and federal oversight process.

A Member Complains- the Regulator Responds

A reader sent me a March 18, 2024 article form the Lost Coast Outpost titled:

Coast Central Credit Union Releases Vote Counts From Recent Board Elections Following Complaint to State Regulators

The story is a press release from one of the candidates for Coast Central’s board.  She filed a complaint with the California Department of Financial protection over the credit union’s failure to release vote tallies for the 2024 board elections.

As a result the credit union posted the vote totals for all candidates for the most recen two years with the Chairman’s reply:

In response to members requests at the annual meeting and in the spirit of enhanced transparency and goodwill, we have taken the additional step of posting the vote totals from the previous year on our website. We hope this action demonstrates our commitment to transparency and our dedication to addressing the concerns of our members.”

Prior requests to the CEO for details of the vote had been turned down.

The complaint was filed by Carrie Peyton-Dahlberg who wrote the press release for the local paper.   The posted results showed she had come in fifth place just 172 votes behind the fourth place elected candidate in the 2024 election:

  • Matt Wakefield: 1,641 votes (73.1%), elected to a 3-year term
  • Terry Anne Meierding: 1,600 votes (71.3%), elected to a 3-year term
  • Ron Rudebock: 1,520 votes (67.7%), elected to a 3-year term
  • Dane Valadao: 1,346 votes (60.0%), elected to a 1-year term for the remainder of a 2023 retiree’s term
  • Carrie Peyton-Dahlberg: 1,174 votes (52.3%), not elected

In her commentary “she urged Coast Central member-owners to use their comment cards to ask for further progress, such as publicly announcing board vacancies, revising board election rules so they don’t hinder election outreach, and changing the board appointment process so that future vacancies can be filled in a way that is more representative of community demographics.”

“Coast Central is moving in a good direction, including releasing these numbers, putting 2024 election reminders in each branch and making sure that its ballots were sent in clearly labeled envelopes. All of these are big improvements over the January 2023 election, and I hope this is starting a new trend.”

 “Bit by bit, if member-owners stay involved, we can encourage Coast Central to move further down this path of listening to the people who own it.” 

Democracy Takes Work

Releasing the actual votes in a member election would seem to be a fundamental requirement, a no-brainer.   The California regulator seems to agree that members are entitled to know the actual votes cast in an election.  That may seem like a small step,  but is still not followed in all credit union merger and board elections-whether for state or federal charters.

This California precedent matters.   Democracy can be a contagious activity.   It is also a participant activity, not a spectator sport.  Carrie Peyton-Dahlberg has done every member-owner a service by raising this issue of election transparency in her credit union.  Hopefully, all regulators will soon see this fundamental accountability for a democratic process the same way.

NCUSIF Investments: Repeating the Practice that Caused the Current Underperformance

I’m afraid I must rant again about NCUA’s management of the NCUSIF investment portfolio.

From the most recent posted financials as of February 2024, the Investment Committee appears to have learned nothing from the past two years of Fed Reserve short term rate increases.

The Committee bought a $650 million Treasury bond yielding 4.26% with a final maturity of 6 years and three months on February 15.

The investment extended the NCUSIF’s duration, increased the portfolio’s interest rate (IRR) risk, and reduced short term  liquidity. The term portfolio (75% of the $22.5 billion total) is underwater by $1.3 billion and yields just 1.44%.  the Fund’s overnight position in contrast earned an average yield of 5.41% in February.

This new term investment reduces income versus rates available at the short end of the curve by at least 1% or $6.5 million per year until the Fed decides to change course.  Here are the Treasury rates as of Wednesday April 3, 2024 from CNBC  Pro, Stocks at Night:

Bond Yields Above 5%

  • The U.S. 1-month Treasury bill is now yielding 5.36%.
  • The U.S. 2-month T-bill is also now at 5.36%.
  • The U.S. 3-month T-bill is at 5.35%.
  • The U.S. 6-month T-bill is at 5.31%.
  • The U.S. 1-year T-bill yield is now back above 5%, hitting 5.044%.
  • The U.S. 2-year Treasury note is yielding 4.67%.

Ignoring Investment Fundamentals

This decision ignores the IRR lessons from the more than two years of Fed rate increases. The negative consequences of this investment pattern on the earnings and liquidity of the portfolio during this time have been enormous.  Moreover, in recent Board updates, staff said they made no change in their investment policy.

Those policy assumptions fail to adjust to not only  events of the past two and one half years creating this ongoing underperformance; it is oblivious to the history of the Federal Funds rate.

Here is  an analyst’s review of this rate experience in a recent update by a longtime observer and consultant to financial service firms:

Since the inception of the Fed Funds Overnight rate in 1954, the average and median have been in the 4-4.5% range. (https://fred.stlouisfed.org/series/fedfunds)

If you entered the industry after 2009 then you probably didn’t know this.  Your “normal” was a Fed Funds rate in the 0-2% range and you probably think the sky is falling with the current rate at 5.33%.   

The implication of a low Fed Funds rate since 2009 was that you could only survive by making loans because there was very little spread to be had between deposit cost and investment yields.

The Need for Leadership

As NCUA staff repeats its past misjudgments, one would hope the board had the abiity to ask relevant questions and more importantly, documented policy plans and goals.   This is what any examiner would require of a credit union with this continuing record of a $17 billion investment portfolio yielding 1.44%.

The current practice/policy increases the portfolio’s interest rate risk,  provides  no weighted duration goal based on the earnings requirements of the fund, and shortchanges the credit unions who should be receiving dividends from their performance during these last five years of minimal insurance losses.

Reviewing the NCUSIF history since 2009 shows that a portfolio yield of 2.5-3.00% would provide a stable NOL after all costs and growth assumptions.  Returns above that would give credit unions a return on their collective investment—a public commitment when the NCUSIF was redesigned with industry support.

Here for example, is the published forecast from the August 1985 NCUA News (page 3) the year following the Fund redesign:

An estimated 6.8% dividend has been projected for the federally insured credit union deposits  in the NCUSIF based on the Fund’s performance as of June.

The estimated dividend is part of an overall program of reporting to the NCUA Board and to credit unions on the Fund’s activities.  The dividend forecast is updated each month.  Office of Program Director D. Michael Riley noted that he expects the fiscal year dividend to be in the 6.5% to 7% range.

No Muscle or Memory

The core problem is that the board and staff have lost all the “muscle-memory” demonstrated by prior Agency leadership when projecting dividends.   The dividend was and is the key success factor that separates the NCUSIF from all other federally managed deposit funds.

A 5%  portfolio yield would result in total NCUSIF revenue of over $1.0 billion and a substantial return for credit unions.   Current NCUSIF investment policy and practice shortchanges credit unions and mismanages the most important asset under NCUA’s administration.

The only advantage of this six year and three month investment is for the three board members, Their terms will all have expired.  So they won’t have to explain how making the same oversight error increased NCUSIF’s portfolio risk while reducing its earnings for credit unions.   In short, this NCUA board has no memory let alone muscle when it comes to overseeing the NCUSIF.  Perhaps that’s why there was no Board meeting in March.

 

 

 

An Observervation on the Difficulty of  Gaining a Credit Union Charter

Oscar Abello is the senior economic writer for Next City.  His focus is community initiatives that bring opportunities to those left behind by existing financial options.  New credit union charters are an area of special interest.

His latest story is A Long-Awaited Black-Led Credit Union Finally Gets the Green Light.  The subtitle is “after eight years of work, Arise Community Credit Union just secured Minnesota’s first state charter in over two decades.”

The announcement of this new charter’s background has been reported by the credit union press.  Abello’s story focuses on the difficulties of the process.   Here are some of his observations:

Chartering a new credit union today is like traversing a long-lost trail through the woods, one that used to be well-traveled but is now overgrown, littered with fallen trees and other obstacles no one has had to navigate in many years. Prior to 1970, there were 500 to 600 new credit unions chartered across the country every year. After a steep decline to near zero, the numbers have never recovered. Over the past 10 years, fewer than 30 new credit unions have been chartered across the country.

New Credit Union Charters

The annual number of new credit union charters issued nationwide by the federal government, as published in the annual reports from the NCUA.

According to Inclusiv, a network of credit unions that focus on community development, minority credit unions across the country are closing at the rate of one per week, making the new Arise Community Credit Union’s chartering even more urgent if that trend is to ever be reversed.  (Editor’s note: all credit unions close at a rate of more than three per week). . .

Arise hopes to fill in the gap left behind by other more conventional banks and even other credit unions. Predatory lenders have jumped into the gap left behind by the retreat of the mainstream banking system from certain communities. African Americans are twice as likely to live within 2.5 miles of a payday lending storefront, compared with all Minnesotans. . .

Chartering a new credit union is a huge lift. It’s been nearly eight years of organizing for Arise, but it’s not uncommon for aspiring credit union organizers to take multiple years between initial conversations to raising startup capital to finally getting a new charter. The Association for Black Economic Power also had to deal with a leadership transition along the way — it’s now led by Debra Hurston. The new credit union has its own CEO, Daniel Johnson, who has deep family ties and professional ties to the Northside of Minneapolis.

It would have been easier — and quicker — for Hurston if her group just brought in an existing bank or credit union as a partner organization to provide access to credit and basic financial services to the Northside.

But Hurston says in surveys, town halls and just informal conversations over the years, the Northside’s desire for its own institution has only gotten stronger.

“The mistrust in the banking community, it’s not a small thing, and it can’t be fixed overnight,” Hurston told me last year. “We’re starting from the wrong spot…if I have to protest in front of you to make you treat me right. Something’s not right about that. So no one from our communities has ever asked me if we should just partner with a larger bank.”

Insight for Those Who Care

Abello’s reporting should be a boon to the credit union community.  For as Robert Burns wrote of this ability to see what others may not:

O wad some Power the giftie gie us To see oursels as ithers see us! It wad frae mony a blunder free us, An’ foolish notion: What airs in dress an’ gait wad lea’e us, An’ ev’n devotion!

Music For Holy Week

Christ on the Mount of Olives, by Ludwig van Beethoven (1803)

(https://www.youtube.com/watch?v=5ZKWcn7bqsQ&t=41s)

What Credit Union’s Can Learn from the FHLB System

This month the Congressional Budget Office (CBO) released a 27-page report analyzing the Federal Home Loan Bank System.

The significant chapters include an Overview, Financial Condition, Subsidies and Risks.

The FHLB system is the largest lender to credit unions. Hundreds of credit unions have capital invested in individual banks and rely on them as critical partners for liquidity and ALM management.  At 2023 credit union borrowings reached a peak in the system’s history:

The Central Liquidity Facility

How can the cooperatively owned, tax exempt FHLB, created to serve the savings and loan system, thrive with credit unions while their own funded CLF plays no role at all? Certainly, the borrowing demand is there.

At February 2024, the CLF reported $913 million in total assets, equity of $862 million and one loan for $1.0 million.

A 5% return on the fund’s retained earnings of $42 million would pay all CLF’s operating expenses.  It’s 4th quarter 2023 dividend of 4.62% trailed the overnight market by .75%. Why aren’t members even receiving a market return on their shares?

More importantly, what can credit unions learn from the CBO’s analysis and the system’s response?

The CBO and FHLB Summary

Ryan Donovan, CEO of the Council of the Federal Home Loan Banks posted a reply #FHLBank to the CBO report: “it does a fair job of acknowledging the many things we have been saying.” He singled out a number of key success factors:

Private investors — not the government or taxpayers — bear the cost of any “subsidy” associated with the FHLBank system.

The FHLBank system plays a valuable role in providing liquidity to its members, particularly during times of market stress.

The benefits the system provides accrue not only to the members but to borrowers and the public. In fact, it says,

“Lower financing costs on FHLBs’ debt are passed along through lower rates on advances than members would receive when borrowing in private debt markets. In turn, competition leads members to offer lower rates to borrowers.”

“Because members are both owners and customers of FHLBs, almost all of the subsidy (after afford-able housing payments are deducted) probably passes through to them, either in the form of low-cost advances or, to a lesser extent, through dividends.”

The existence of the FHLBank system “reduces mortgage rates and provides liquidity to the housing market, particularly during period of financial stress.”

The FHLBank system poses very little risk to taxpayers. If one accepts the CBO’s figure of $600 million in federal tax exemption, the roughly $1 billion that the FHLBanks will distribute in affordable housing and community development grants this year seems like a very good investment for taxpayers.   

Donovan concludes: The report stymies critics . . .because CBO makes clear FHLBanks pose little risk, they provide significant public benefit, the implicit guarantee is perceived by bond investors and the benefits of the system flow through to borrowers and communities.

The FHLBank system is poised to deliver $1 billion toward affordable housing and community development . . .We’re engaged every day with our members and other stakeholders on how those resources can be used most effectively.  (end)

All these housing and community benefits should be possible with the CLF.  Why isn’t this happening?  What might a CBO report on the CLF say? Would anyone care?

Music for Holy Week

With each daily post I will be adding excerpts from some of the great classical music inspired by this Holy Week. Today’s is the “Resurrexit” from Berlioz Messe Solennelle.

(https://www.youtube.com/watch?v=K-RX0XtBBnw&t=29s)

 

 

 

A Valuable Library Resource from NCUA

In following up an article by David Bauman in which he referenced his FOIA request to NCUA, I was directed to  NCUA’s FOIA Library.

Under the Frequently Requested Information section was what I had asked for:  NCUA’s response to Congressman French Hill on December 14, 2023.   Other items in this section included previous multiple requests that can be accessed by just clicking on the link.

Another section of the Library was the FOIA Request Logs  which include 474 requests going back to 2019.  I scanned the requests that were open and closed for 2023 to see what information had been asked for.

The log table has the date of the request, sometimes the organization, a description of the information sought and final disposition: granted-partial or full, denied, or “no records” responsive to the request.

I have reached out to NCUA to ask if anyone can use the FOIA log number to review previous responses without having to submit a whole new request—just to learn about the agency’s response.  When the reply is received, I will add to this blog.

In the meantime here are some of the more intriguing request descriptions, all of which were filled in whole or in part.

Selected Titles In the FOIA Library from 2023

Copies of all FOIA appeal logs by year from 2010

Records sufficient to identify all employees who entered into a position at the agency as a Political Appointee since January 20, 2021, to the date this records request is processed, to include a list of enumerated parameters to include resumes and waivers.

Documents and data sufficient to account for the monthly occupancy or vacancy rates for the agency’s five largest buildings (measured by square footage) from January 1, 2020, to December 31, 2022. 

A list of federally insured credit unions with agricultural loan portfolios greater than $100 million.

The application, approval, and any attached materials from the most recent field of membership change by Thrivent Federal Credit Union, headquartered in Appleton, WI.

A copy of the charter for NBC (N.Y.) Employees Federal Credit Union, charter 22351, prior to its merger into XCEL Federal Credit Union, charter 16218. 

A list of nationally insured credit unions that have failed and/or been acquired since January 2001 to include credit union name, charter number, opening date, failure date, and acquiring institution. 

The most recent NCUA salary data.

1)The number of federal credit union mergers completed each year between 1980 to 2020; and 2) The number of active federal credit union charters each year from 1980 to 2020 (as of 12/31 or other uniform date for each year). Note: If information is not available going back to 1980, please provide information going back as far as NCUA records allow. 

A list of all credit union CEOs and volunteers as of March 31, 2023.

NCUA salary data specifically under the category of political appointee.

Quarterly lists of all credit union board members for each quarter from Q42012 through Q42022.

1)Field of membership (“FOM”) criteria and approval documentation for FirefightersFirst Federal Credit Union (“Firefighters”); 2) Firefighters’ application and documents related to add “employees of non-profit foundations authorized by their organizing documents to be for the benefit and support of firefighters” (“Foundation”) to its FOM; 3) OGC’s legal opinion and analysis that supports the addition of the Foundation to Firefighters’ FOM; 4) CURE’s office summary that supports the addition of the Foundation to Firefighters’ FOM; 5) CURE’s approval letter and GENISIS worksheets reflecting approval of the Foundation to Firefighters’ FOM. 

Entire consumer complaint file from 2013.

An Important Resource

This is a partial 2023 listing.  In addition to some interesting reading, it also shows the agency as a resource for names of CEO’s and volunteers (including even CUNA and NAFCU) and for credit union data or other files going back years.

There might even be some valuable credit union press stories in following up some of these past requests.