OIG Report on The FDIC’s Readiness for Crisis

Completed in 2019, the FDIC’s Office of Inspector General (OIG) reissued this report yesterday to assist in responding to the current crisis.

There are two takeaways that could help the credit union system.

The first describes how the FDIC performs self-evaluations of its performance in past crises. This process is summarized in the following paragraph for the Great Recession. To my knowledge, NCUA has never conducted any study of its actions in this event.

Two current board members were directly involved, at different times, in the implementation of the Corporate Resolution plan begun in 2009. The current surplus of over $6 billion from the five corporate liquidations, versus NCUA’s projected costs of $13-$16 billion, suggest the urgency of understanding how such a catastrophic supervisory misjudgment could have occurred.

Below is how the FDIC’s evaluated its role:

“Since its inception in 1933, the FDIC has responded to several financial crises in the banking system. In 2012 and 2017, the FDIC completed two Agency-wide studies of its response to the financial crisis of 2008-2013. These studies identified challenges that the FDIC experienced and addressed during the prior financial crisis, such as those related to staffing, contracting, and information technology. The studies also identified lessons learned and recommendations, some of which the FDIC has incorporated or planned to incorporate into its operations and crisis readiness planning. Such operational improvements have helped the FDIC continue to enhance its readiness for crises impacting insured depository institutions.”

A second benefit of the OIG report is the identification of best practices in crisis management. It evaluated the FDIC’s capability on each of these. These seven practices are listed as follows:

“The OIG identified that guidance established by the Department of Homeland Security and Federal Emergency Management Agency on planning for crisis events could be used as best practices by the FDIC. Additionally, best practices from non-Federal sources reinforce the concepts articulated in Federal best practices.

Our review of these best practices identified seven important elements of a crisis readiness framework that are relevant to the FDIC – (i) Policy and Procedures; (ii) Plans; (iii) Training; (iv) Exercises; (v) Lessons Learned; (vi) Maintenance; and (vii) Assessment and Reporting.”

The 73-page, reissued OIG report is available on the FDIC OIG website.

A CEO’s View of the Current Moment

Every good CEO knows that what we are learning now is the foundation for new ways to EARN in the future. The key is to make sure we don’t waste the learning and the lessons thinking this is just a freak interruption to a template we wish to get back to.

From the Field: What is a Credit Union?

“A Credit Union is a place to do your banking – we do loans, have checking and savings accounts, credit cards, mortgages, and other banking items. We are a not-for-profit cooperative financial institution, and operate like a bank except we don’t issue stock on Wall St. Since we don’t have to pay stockholders, we can use our income to provide lower loan rates, higher deposit rates, and do other things like reinvest in our community, give to charities, and keep our fees low for services. At NET Credit Union, we don’t have customers, we have members. Members have voting rights as to how the credit union operates. Our board of directors are volunteers – they don’t’ get paid to sit on the board. When you bank with NET, your money stays right here, local. There’s so much more you get when you bank on NET.”

 

A Sunday Meditation for Our Time

With thanks to Mark Willey, organist choirmaster at Georgetown Presbyterian Church, Washington D.C.:


Martin Rinckart walked quickly down the filthy side street that led to his house, distracted only briefly by a hungry mob fighting over the body of a scrawny and very dead cat. He knew them all, had ministered to them, buried their children, and fed them what he could spare from his own meager rations.

Today though, he carried nothing but an idea, a poem that had come to him while he was conducting one of ten funerals he had conducted that day.a He needed to write it down before it was forgotten.

Opening his front door, he rushed to his small desk and picked up a goose quill pen. Dipping it into the well, his mind wandering over the events of the past year, as the tip slowly filled with iron gall ink.

He could see their faces and hear their cries of anguish. The weeping parents burying their only child, the grieving young widow, sick herself with only days to live. They were almost too numerous to count, but as the town’s only living minister and one of just three surviving members of the town council, it was his job to count. In that year alone, he’d buried over four thousand souls, their lives cut down by the Black Plague, but this was just the latest pestilence.

Ever since his appointment in 1617 as Archdeacon of Eilenburg in Saxony, he’d never known peace, or plenty. The skirmishes between the various Protestant and Catholic states had metastasized into an all-out war in 1618; a war that killed millions. Poverty, sickness, hunger, and death were ever present for Martin, and his life was devoted in service to those who suffered.

Lifting the pen from the well, he set its tip on the paper. The familiar scratching sound of its strokes quickened as the letters formed words, flowing into lines of poetry:

Nun danket alle Gott                               Now thank we all our God,
mit Herzen, Mund und Händen,         with heart and hands and voices,
der große Dinge tut                                 Who wondrous things has done,
an uns und allen Enden,                         in Whom this world rejoices;
der uns von Mutterleib                          Who from our mothers’ arms
und Kindesbeinen an                             has blessed us on our way
unzählig viel zu gut                                 With countless gifts of love,
bis hierher hat getan.                            and still is ours today.

 https://www.youtube.com/watch?v=skdWLWF6Ttw

It’s hard to imagine this hymn emerging from such a dark time: a plague, and famine in the middle of a thirty-year long war. Somehow, between all the burials, feeding the hungry, caring for the sick, and ministering to as many people as he could, Martin Rinckart found time, and a spirit of thankfulness to write these words.

Writing them didn’t put an end to the plague, or bring peace to Europe, but Martin seems to have discovered what a spate of recent studies are confirming: Gratitude is good for our minds and bodies.

Could we, would we write words like these today? The words of this hymn of thankfulness flow from Martin’s time to ours, to inspire us to live with a spirit of gratitude in the face of sickness, even the threat of death, and how to focus our energy on service, rather than fear. The world needs more Martins. I want to be one. Don’t you?

In Case You Missed Spring: Nature Did Not

With all the world’s attention focused elsewhere, it is easy to overlook the calming rhythm of nature. A poem by Wendell Berry, “The Peace of Wild Things”, captures the life affirming repose of nature. Berry (born August 5, 1934) is an American novelist, poet, essayist, environmental activist, cultural critic, and organic farmer living in Kentucky.

When despair for the world grows in me
and I wake in the night at the least sound
in fear of what my life and my children’s lives may be,
I go and lie down where the wood drake
rests in his beauty on the water, and the great heron feeds.
I come into the peace of wild things
who do not tax their lives with forethought
of grief. I come into the presence of still water.
And I feel above me the day-blind stars
waiting with their light. For a time
I rest in the grace of the world, and am free.

Some of the life affirming beauty from our garden energized by a warmer than normal season.

Primrose:

Crocus:

Hyacinth cluster:

Schools and Credit Unions Serving Communities Together

Under the US Constitution the primary responsibility for public education rests with the states, not the federal government.

The result is that K through 12 education is overseen by a fragmented system including local school boards, county level agencies and state departments of education.

Financially, approximately 90% of funding is from state and local taxes. The federal government’s share of education fluctuates between 12-15%.

Effective public education encounters all of the major issues of society: race, income disparity, immigration, technology access, financial resources and even political ideology.

The local school systems are a daily example of the major demographic, political and economic issues each community must deal with.

An Indicator of Economic Needs

Some credit unions such as NET Credit Union actively partner with school districts in their educational and outreach strategies.

Most credit unions today have community charters. One of the most useful indicators of the need for credit union services may be from the economic data provided about K-12 students.

Public information on each community’s K-12 student population is abundant.

Here are three examples of data points about the economic circumstances of students in the greater Washington DC area:

  1. In Montgomery County, Maryland, with 144,064 students, the percentage that have received free and reduced price meals (FARMS) is 42.4%.
  2. In Fairfax County, Virginia, with 187,000 students, the number considered economically disadvantaged is 34%.
  3. In the District of Columbia’s public school system of 94,503 students, 77% are considered economically disadvantaged.

These three school systems have some of the most affluent housing areas in the country and, due to government employment, some of the steadiest levels of employment.

Yet significant percentages of students are from families living in circumstances where the school system provides free meals.

Investing in the Next Generation of Members

School statistics can inform credit unions about the economic circumstances of local families especially those that are just be getting by. Financial education and access to reasonable credit is critical for lower income families achieving financial stability, if not independence.

Partnering with schools and students is a way to introduce the cooperative option to the next generation of members. Every community has a school system and most are under local control. A first step could be to ask the school board for the public statistics on their student’s economic and demographic trends. Then open a dialogue for how to reach those families who would benefit most from credit union service.

Forming a collaborative relationship with the single most important institution families’ consider when moving into an area, could give credit unions a long term partnership that enhance opportunities for those most in need.

Should Credit Union Members Have “Jury Duty”?

A friend recently commented on his initial wait for possible jury duty:

As I write this, I am sitting at the D.C. Courthouse waiting to find out if I’ll be selected for jury duty. Many of you have been where I am, and likewise many of you remember the video that is played to prepare potential jurists for voir dire and a case: Jury Duty: Call to Serve!

It’s dramatic (over-dramatic?), and a bit of a strange juxtaposition. While we’re being told that the fate of democracy rests in our hands (!)—I’m really just sitting in a large room with people scattered around doing their work or reading, but mostly just waiting around. And it’s easy to dismiss the video—getting called up for jury duty feels like a distraction and not all that important, if waiting around seems to be our main job. . .

So, for the next few hours at least, I will try to bring a different perspective to jury duty. I will attempt to wait patiently and attentively, hoping for my time to serve, all while knowing that the work is critical, and much bigger than one person. Perhaps as I wait, I’ll learn something about duty as well.

The Duty of a Credit Union Member

Is there an analogy for the member-owner of a credit union? Could it be to “serve” by attending and voting for their leaders at the Annual Meeting? If we only ask and expect our members to use products, have we really helped members understand the cooperative principle that the “fate of democracy rests in our hands”? Is your Notice of the Members’ Annual Meeting a call to duty?

Ending Autopilot Decision Making in Credit Union Mergers

No credit union merger proposal has ever been turned down by a vote of the members. In over 5,000 voluntary mergers over the last two decades, most were by credit unions that were financially sound.

So why has the voting process been so perfunctory, to the point of meaninglessness?

Why has this fundamental member-owner responsibility become so routine?

This is especially critical when much evidence exists in for-profit sector and financial services, that many mergers destroy value.

One reason why this exercise in cooperative democracy appears pointless is that the voting decisions is presented in such a way that members believe there is no real choice in the matter.

Members are given no economic facts or alternatives, and often given a nudge in the form of a special dividend to follow the course recommend by the Board and management to give up their charter.

In an article exploring why consumers may act contrary to their economic self-interest,  the authors provide the following observation from behavioral economics:

“While it may not sound like a lot of fun to think about the opportunity costs of every financial decision, we need to be careful and not get too caught up in an “autopilot” mode of decision making. Thinking about everything we could do with our money is hard. At the time you make a purchase, remember that you can spend the money only once. More costs exist, so you may miss future opportunities such as a more significant purchase, interest earned on savings, bill payments, or other possibilities. The difficulty of considering several options leads us to revert to mental shortcuts during our decision making.”

Surrendering control over an organization and legacy assets produced by the efforts of generations is hardly a routine decision. Might it be time to ask whether the so called voting process be re-evaluated based on cooperative values and fiduciary responsivity?

People Helping People: The Closing of the Restaurant Industry

One of the most threatened industries from the stay-in-place requirements will be the restaurant business. Every eatery, from the oldest locally-owned café to the largest national franchises, is financially at risk. These local businesses’ futures are in doubt; more importantly millions of full and part time workers may be laid off-indefinitely.

Almost ten years ago, Chef Jose Andres and his wife Patricia started the World Central Kitchen. They envisioned a non-profit organization that would create innovative approaches to combating hunger and poverty. Initially this was through providing clean cook stoves and culinary training programs along with social enterprise ventures that empowered local communities and economies. The focus was on country’s suffering from natural disasters or chronic hunger in the population.

Now this decade long world-wide charitable effort is focusing on the US: “We have shown that there is no place too far or disaster too great for our chefs to be there with a hot plate of food when it’s needed most.”

A week ago Chef Andres announced the closing of all his DC area restaurants. He explains why in this 4 minute video. He is paying all his staff for the next two weeks and converting several restaurants to Community Kitchens. Below is the conversion of his Bethesda restaurant’s location. While undoubtedly concerned about the future of his own enterprise, Chef Andres is putting community outreach as his first priority.

  1. Chef Andres’ Bethesda location
  2. The conversion to a Community Kitchen
  3. Get in Line
  4. Stand here signs in walk to pick up food:

  5. Serving those most in need

So You Want Government Crisis Money

The subject line of a CEO’s email to staff: “Ensuring that our business records reflect due diligence, policy follow up, and the right balance of CYA”. Excerpts follow:

Team, think backwards – after this is all over, we may be AUDITED to see how we did during the crisis by official third parties. Not just our internal operations but those organizations we rely on to serve members. I want the board record and business documentation to show our attention to our processes related to these times and normal times. Assume a future proctology exam is coming and be ready.

For example: We are assuming the process to get GOV’T funds for extended PTO and employee benefits will be a FIGHT or a HASSLE at the very least. We are starting a process to make sure we keep the records to make our case very specifically as we learn the rules. Our management team must keep a CENSUS – have the numbers, know where people were, what they were doing , what work we accomplished in strained times, etc.

We want to never lose on process – so we have to anticipate process reviews and be ready. Make our business records tight and shining – especially through the upcoming months.