Queen Elizabeth’s Wisdom on How Credit Unions Succeed

The world is now in the middle of a ten-day state funeral planned long ago with the name London Bridge.  The British government’s royal pageantry is in full bloom honoring Queen Elizabeth’s life and reign.

In her Christmas Day broadcast years ago, there is wisdom that describes I believe,  the motivation for the cooperative model.  Credit unions were not the example for her commonwealth listening audience; rather she singles out the human capital that every coop needs to succeed.

These are a two excerpts from this annual holiday address (with English spellings).

I often draw strength from meeting ordinary people doing extraordinary things: volunteers, carers, community organisers and good neighbours; unsung heroes whose quiet dedication makes them special. They are an inspiration to those who know them, and their lives frequently embody a truth expressed by Mother Teresa, from this year, Saint Teresa of Calcutta. She once said: “Not all of us can do great things. But we can do small things with great love.”

The following observation is key for the cooperative mission.

But even with the inspiration of others, it’s understandable that we sometimes think the world’s problems are so big that we can do little to help. On our own, we cannot end wars or wipe out injustice, but the cumulative impact of thousands of small acts of goodness can be bigger than we imagine.

Change Starts Small

 These words echo the idea of subsidiarity —the belief that individuals, families, local communities, non-profits and churches (faiths) can change society for the better and that large organizations tend to make big problems even bigger.

Her words suggest that when change is needed, it can start locally, at the grassroots level, by individuals passionate about improving  their communities.

Sounds like a credit union idea to me.


Credit Union’s Status at June 30, 2022

Last week a reader responded to my analysis of credit unions investments at June 2022. His comment was so insightful and comprehensive, I asked Mike Higgins to convert his response to a post, which follows.

Musings On the State of Credit Unions June  2022

Another quarter has passed, and the economy is behaving like a moody teenager – one day up, the next day down.  Wall Street has a slightly optimistic outlook, but the Federal Reserve has different plans.  A lot of mixed messages. This leads me to a handful of musings and situations to consider based upon second quarter credit union call report data.

  • Net interest margin finally improved this quarter (up 16 bps to 2.73%). It was driven by two items:
    1. Rising loan to asset ratio (more assets earning higher loan yield vs. lower surplus funds yield).
    2. Higher surplus funds yield (up 34 bps).

I count cash as surplus funds because I am ruthless about sloppy funds management, so if you see a slightly different number somewhere else, you will understand why.

  • Those credit unions with short weighted average maturities (WAM) in surplus funds will see immediate benefit from continued (signaled) rate hikes.
  • Loan yield barely budged this quarter.  It increased 1 bp to 4.29%.  Why?  Let’s look at where the massive amount of loan growth came from this quarter:
    1. 40% from real estate lending (1st mortgage held and commercial real estate).
    2. 35% from vehicle lending.

Those tend to be fixed rate.  So huge loan growth, mostly fixed rate, adds little movement in loan yield.  When rates go up, the incentive to pre-pay is reduced, so duration will extend here.

  • On the funding side, we normally see price inelasticity as rates on core checking and savings are “sticky” tending to lag markets. However:
    1. The Federal Reserve is starting quantitative tightening.  Bank deposits declined this quarter, which rarely happens — the supply of funds is shrinking.
    2. Credit union deposits were basically flat this quarter.
    3. Credit union borrowings and non-member deposits increased by 36% this quarter.
    4. Deposits are becoming valuable again!  The spread between cost of funds and the yield on surplus funds is producing a high rate of return after being low for so long.

Banking Like It Used to Be

So, the tendency is greater demand for funds going forward.  Banking like it used to be  with deposit and loan spreads near equilibrium (deposit spread = surplus funds yield minus deposit cost; loan spread = loan yield minus surplus funds yield).

  • Unrealized losses on available for sale (AFS) securities now represent 12.6% of credit union net worth.  This will only grow larger with each rate hike.  I realize there is no loss on any security held to maturity, so it’s just a paper loss, but it reflects the following:
    1. Credit unions will be reluctant (or unable) to stomach losses, so they will hold the securities until maturity.
    2. This effectively converts the securities to fixed rate loans for interest rate risk purposes.
    3. Fixed rate loans held to maturity reduce liquidity, thus increasing demand for funds to support continued loan growth.  Fortunately, there is still room left in the loan to asset ratio. However AFS securities should really be viewed as a loan for ALM analysis, because they are going to model the same behavior.

Navigating to a New Normal Interest Rate Curve

How would you characterize your balance sheet today?  What concerns do you have and how do you plan to address them?

Every credit union will be in a different position, but here are four general situations I am seeing right now:

  • Nothing Changes.  Credit unions that are good at lending don’t have to worry about surplus funds management — because they don’t have lots of surplus funds to begin with.  Assuming they are following sound ALM practices, they should be just fine. Suggestion:  Stay the course.
  • Happy Days Are Here Again.  For credit unions who are not so good at lending, and as a result, have excess amounts of surplus funds, but did not chase yield in the investment portfolio, their ROA is in for a big boost from rapidly rising rates. A reasonable deposit spread has finally returned after a long drought. Suggestion: Closely monitor any outflows of deposits and increase rates on shares to avoid runoff–which should also make members happy.
  • Can You Say Liability Sensitive? For credit unions good at lending but chasing growth using price/terms as a differentiator (low yield, fixed rate), you will experience increasing liability sensitivity.  The funding side of the balance sheet will see faster increases in costs than the asset side can absorb. Decreasing net margin may cause ROA to wane.  If you have a large enough net interest margin, you should be able to ride things out; however, run some net income simulations to get a better read on P&L exposure.
  • A Forecast That May Incur Pain. Those credit unions not so good at lending, and with excess amounts of surplus funds which chased yield hard, are facing a net margin squeeze. Rapid rate increases are not a friend.  Increased unrealized losses will come with each rate hike.  Suggestion: Re-evaluate your liquidity. Your securities are like fixed-rate loans in ALM analysis.  To grow, you may need new funds since much of your liquidity is “underwater.”

Asset liability management is changing quickly now after a two plus years of historically low rates and a flat yield curve.  The current market consensus forecasts an overnight rate in the 3.50-4.00% range before the Fed pauses to let things get sorted out.

Those of you who remember banking before the Great Recession can draw upon your experience.  Those who were not in the industry at that time may want to do a little research of the interest rate cycle post 9/11 and the return to “normal.”




Mike Higgins is a consultant helping credit unions and community banks improve their competitive position through performance-based compensation.  He sees financial statements for just over 100 financial institutions every month.  He was also a founding investor in a 2006 community bank startup.


Credit Union Investments at June 2022 and the “Wisdom of the Crowd”

Wisdom of the crowd is a theory that assumes large crowds are collectively smarter than individual experts. It believes that the collective knowledge and opinions of a group are better at decision-making, problem-solving, and innovating than an individual or single organization.

The collective judgment of a diverse group  compensates for the bias of a small group.

On September 2, Credit Union Times published an analysis by Callahan’s Jay Johnson of credit union investment trends at June 2022.  How did the industry respond to 2022’s rise in market rates?

Investments 30.5% of Total Assets

Total investments held by credit unions, including cash balances, fell 9.5%, or $68.6 billion.  But the June total $655.5 billion was still 30.5% of the balance sheet.

As reported in the article, credit union investments boomed in the past two years, growing from $389.3 billion in December 2019 to a high of $724.0 billion in March 2022, mostly by  Covid relief payments held as cash. Even after this quarter’s decline, total investments are well above where they stood at the start of the pandemic.

 Credit Unions Favor the Front of the Curve

Johnson’s analysis reported the  trends in market rates at quarter end as follows:

“The yield curve flattened after the Fed raised rates 75 bps in both June and July. Short-term Treasuries, which are most sensitive to Fed action, priced in expectations for additional rate hikes. The two-year yield increased 40 basis points in June after some dramatic intra-month swings. It settled at 2.95% at month end after reaching as high as 3.45%.

“The market struggled to price in both recession risk and more Fed rate increases at the same time, as the two forces counteract each other. The 2-year/10-year spread finished the month at 6 basis points, threatening inversion.

“Portfolio allocators took advantage of the increase in shorter-term yields and reinvested funds into securities of more near-term maturity. The one-to-three-year maturity category took in $4.2 billion from credit union investors since March, good for a 3.6% increase and enough to become the largest non-cash category.

“Investments in securities are spread relatively evenly across each of the maturity categories within the one-to-10-year range, understandable given recent changes to the yield curve. Cash comprises 28.3% of total investments.”

Portfolio Yield up 21 Basis Points

“The average yield on investments increased 21 basis points quarter-over-quarter, up to 1.12% through June. While this marked the fifth straight quarterly increase, it was the most significant change in yield since the first quarter of 2019.

“Of course, with rising yields come unrealized losses on available-for-sale securities, and these, perhaps temporary, losses now total $28.3 billion throughout the industry.”

A Crowd Sourced Benchmark for WAM and Investment’s NEV Risk

As shown below 42.6% of credit union investments are cash or under one year maturity.  Obviously it is difficult to reposition longer maturities as rates rise, without incurring a loss.   This short-term liquidity build up allows credit unions to “ride the yield curve up” as rates are taken to a new normal by the Fed in its inflation fight.

The overall weighted average investment maturity for all credit unions is 2.83 years.  Every institution’s balance sheet, cash flow and business priorities are different.

The 2.83 years is the risk profile of the total credit union portfolio.  It is based on 4,900 independent decisions about managing risk as measured by WAM at the end of June.

Individual credit union investments may have a longer or shorter WAM.  But this is the “collective wisdom” at this point in the upward rate cycle as the Fed tries to rein in the highest inflation in four decades.

Total Balance Sheet Analysis

Investments are one component of overall balance sheet risk management.  In addition to NEV calculations, credit unions use net interest income (NII) simulations to project possible outcomes for net income in changing rate scenarios.

NII is a comprehensive look at the repricing of assets and cost of funds.   The June data showed that the industry’s net interest margin  improved in the latest quarter.

Rising market rates will lead to increased cost of funds. The ALM challenge is to manage this adjustment in tandem with the repricing of both investments and loan assets.  So far, so good.

While market “narratives” about future rate hikes can vary daily, the overwhelming consensus  about future  Fed moves is “higher for longer.”

Investments are just one aspect of interest rate risk management. For this component, how would your portfolio’s risk profile and  recent decisions compare with the industry’s collective wisdom?




Notes from the Field

The notes below are from  three CEO’s monthly staff updates to all employees.  All report excellent financial results with above plan loan growth and strong earnings. The  comments illustrate these credit union leader’s efforts to reinforce their distinctive cultures.

Taking Care of Employees: Stimulus Checks and Health Care at WPCU

Thank you to all the people who expressed their gratitude with an email, a handwritten note or a thank you in the hallway. The management team was thrilled to do this for all our Partner-employees and the myCU experts. Though I want to make sure I remind you that every dollar we paid out in the stimulus check (and every other dollar WPCU spends) comes from the members – and that is why it’s so essential to take better care of members than anyone else does.

CREDIT UNION RECOGNITION: I am excited to share that WPCU has once again been named one of the healthiest employers in Ohio by Healthiest Employers®. Since 2009, Healthiest Employers has been the leading recognition program for employer wellness. Healthiest Employers has over 10,000 employers from all 50 states, including 72% of the Fortune 100.


A Credit Union Member Story from WEOKIE

Ms. Member came into the credit union to speak with a mortgage loan officer about how she could consolidate her debt to make ends meet each month. Ms. Member stated that she is 79 years old and still has 23 years left on her mortgage. Due to the economy, she is unable to make ends meet each month. She got very emotional and told me there are times when she eats very little to make sure all bills are paid. I told her I would take good care of her and look at all her options.

She told me she wanted to consolidate all debts, if possible, into one monthly payment. We added up all debt payments totaling $1879. She only receives $3000 total a month between social Security and retirement. After reviewing all the products Ms. Member settled on the low-cost 15yr fixed. I was able to shave eight years off her mortgage and put $970 back into her pocket each month. Not to mention we closed her loan the last day of the month therefore, she was able to skip September. So that’s an additional $909 (the new mortgage) in her pocket. I told her to go enjoy a steak dinner with her grandson, who she talked about every time we met.

Partnering with local nonprofits.

The WEOKIE Foundation is proud to be partnering with two new local nonprofit organizations. One organization called NorthCare works with the community to recover from mental illness, substance use, and trauma. They have 400 awesome employees in multiple facilities and have asked our team to assist their employees with their finances by providing education, tools, and 1:1 counseling. We kicked off the program the last week of August with a presentation to their staff and have many other future events planned.

Another group that we are working with is ReMerge, a local nonprofit offering a second chance to women battling trauma, poverty, and incarceration. We’ll be working to assist these women as they rebuild their lives in regards to their finances.

We have many exciting things planned for both nonprofit groups and look forward to helping our community with some practical tools to improve their financial lives. Both of these nonprofits are doing amazing work in our community. The Foundation is honored to be assisting with more than just monetary donations.

Connecting with a 90Year Old Former NCUA Mentor.

Kim and I were able to travel to Palm Springs last week to celebrate the 90th Birthday of a long-time mentor and friend Hap Blaisdell. Hap was an early mentor to me and is recognized as the “father” of the Student Credit Union movement while serving as Executive Assistant to then NCUA Vice Chair Elizabeth Burkhart. Hap eventually became my “first hire” as the Executive Director of the Campus Credit Union Council (CCUC) when I served as its chair. Hap has been “uncle Hap” to thousands of young credit union leaders over the years. The occasion also facilitated a new friendship for Kim and I with Georgetown Student Credit Union Alumni Peter and his wife Agnes.

See Harry Blaisdell’s role 1986 in this blog on student-run credit unions in a New York Times story.


Employee Appreciation Event

It was a little hot Sunday but there were clear skies as about half the Day Air team and their families came out to Day Air Ballpark for the Associate Appreciation event.  The Credit Union is once again having a “best year ever” so there’s a lot to recognize and appreciate.  A good time was had by all, especially by the little ones.  Thank you to everyone on the team for living the mission and making a difference in the lives of our members each and every day.

Member Feedback on the Net Promoter scores of 1 through 10.

  1. Ten is for everything I have ever needed help with was taken care of. Things were taken care of quickly and done right. Also day air saved my family; my car didn’t work anymore. I was in a bad time in life and needed a new car like an emergency. I went in to get a loan with not very good credit. Day air helped and gave me a loan and changed my life forever. I will forever be greatful.
  2. Many times you have helped me during a financial crisis

A Member note.

“When i came in to open my personal and business accounts I had a problem with my tax# and Palisha Boyd was great she was patient with me and she navigated me through the process to get my tax# straight. I was so grateful that’s what I would tell anyone who I refer to dayair. Something else I love about dayair is that you have a relationship with re-entry people trying to get their lives back after incarceration.”

Keeping in touch with state legislators.

I met with State Rep Andrea White last week. She left very impressed with all that Day Air is doing in the areas of home ownership affordability, financial literacy, and supporting the local economy.  She was receptive to and will likely support several bills endorsed by credit unions, including county recorder modernization and residential PACE loans.  She was interested in the history behind the public funds issue (credit unions are prohibited from accepting public funds in Ohio) and requested information that led other states to move in favor, which will be provided to her.

Supply Chain Issues.

The HVAC system in the suite level of Day Air Ballpark is operating at 50% capacity and replacement units aren’t available for 30 weeks due to supply chain issues.


A Valuable Case Study of a Ransomware Attack on a Credit Union

This morning’s news started with the report of a ransomware attack on the country’s second largest school system in Los Angeles.

The warnings or reports of cyber security threats occur daily.   However, until reading the article below I had not seen an actual account of responding when this happens in a credit union.

The case study appeared  in CUSO Magazine.  It was written by Matt Sawtell, VP of Managed Technology Sales at CU*Answers who had first-hand experience with the event.

Facts are given and lessons learned.  I would urge anyone in this area of responsibility to read this account.

The Anatomy of a Ransomware Incident (And What We Learned)

Following a trend that has been developing over the last ten years, cybersecurity is a topic that is no longer reserved for the dimly lit, garden-level, IT-dwelling teams to consider. It is a topic that is on the minds of those in the boardroom.

As events have garnered ever more concerning headlines, from the Colonial Pipeline incident, which was settled for around $5M in Bitcoin, to the various Microsoft incidents, to the cypto.com hack which saw thieves lift approximately $33M from over 500 user wallets back in January, it’s hard to imagine that no credit union has been affected by an incident in the last few years.

The target that financial institutions have on them is especially large. The attackers believe FIs have the dollars to pay and they possess sensitive member information, which has its own value and adds leverage to a potential payout.

In the last year, we have had the experience of participating in the response to one of these attacks on a credit union. The experience reaffirmed the importance of solid cybersecurity plans and operations as essential, and we gathered some takeaways for others as we worked through the event.

The event unfolds

Friday afternoon, nearly the close of business, our support team received a call from a credit union asking some questions about why their access to data on the network wasn’t working. We followed our normal troubleshooting and escalation protocols. Shortly after digging into this troubleshooting, the bad actor reached out to the credit union to say they had exfiltrated member information out of the credit union and communicated the ransom. Our team escalated this to management, who then advised the credit union to shut down systems and to contact their cybersecurity insurer to begin assisting with the incident.

Cybersecurity insurance is crucial

You have cybersecurity insurance, right? Believe it or not, we have run into organizations recently that do not. We view this as very important coverage, not just because of the financial aspects but also the incident response and forensic and legal resources these insurers can bring to bear in order to minimize the impact of an incident like this.

In this instance the response was swift—a forensic team and case manager were assigned from a firm that specializes in that work. They would quarterback the incident from here through the end. The lead had extensive experience working for a federal agency responding to just these kinds of incidents.

Be diligent, there is a pattern of timing with these events. If you look at the recent rash of events, it seems like the news often breaks on a Friday afternoon, weekend overnight, or before a major holiday. The bad guys know they may have a better go of it when we may have relaxed our guard a bit.

The mitigation work begins

From the initial contact Friday, the case manager was working with multiple parties and coordinating that work on daily (sometimes multiple) calls with all involved. The groups included the forensic team, legal team, negotiator, cybersecurity firm, our CUSO, and the credit union.

We were tasked with a few things at the start, such as determining if we had good backup copies offsite and getting the credit union an alternative way to do some of the daily processing and member work that was needed while the network was shut down. Thankfully, the online and mobile banking systems and audio response were unaffected by this outage so members could still do many of the transactions they needed.

The forensic team was digging in and looking for indicators of compromise (IOCs) as well as any information that might point to a known group of bad actors that pulled off the attack. They used tools, requested hard drives be pulled out of equipment and sent for inspection, and on a daily basis made progress in unraveling the who, when, and how details.

The negotiator was busy interacting with the bad actor and working to negotiate down the initial $5M ransom request. This if nothing else would buy time to decide what the options were over the coming days. The updates from this individual made the whole event seem like a spy movie as much as a cyber incident.

The cybersecurity company utilized tools to start monitoring behavior on the network, process and traffic analysis, and ingress and egress.

The credit union had closed itself to the membership for over a week following the start that Friday. They were present for every call and update, and ultimately made decisions on how all parties would proceed with the work they were doing. In the meantime, they also needed to figure out how to communicate with their members, regulators, law enforcement, and other stakeholders.

Do not overlook a communication strategy

Communication is key. When you have an incident, it is a stressful time. We have all witnessed companies that do a good job of communication and manage the incident well and we have also seen those who… leave room for improvement.

Take for instance the Colonial Pipeline incident. If you lived in the DC/Maryland/Virginia area during this incident, you witnessed panic fuel buying almost overnight. Communication between the pipeline company and the government was not forthcoming where it could have been to calm and inform the public.

On the other side of that are incidents like the Kaseya zero-day from 2021, where the CEO was out in front with regular updates, clients were informed and given IOCs before they were in the news, and the credit union provided transparency and clarity about what to do next.

As a financial institution, one thing to consider is having your incident response strategy and even sample messaging ready to go in advance. Have it cleared through your legal team, management team, and board; keep them in the know on the details and approach. Most importantly, understand that in some cases sharing too little, too much, or speculating publicly can do more harm than good.

You can take this a step further even by conducting tabletop exercises where your team will role-play out various scenarios in order to prepare. Finding someone with experience is a great way to guide the conversation and get the most out of one of these exercises.

Backups and the ensuing recovery

The forensic team started to make headway with their analysis. IOCs were found and pointed back to a foreign group that specialized in gaining access to business networks in the west. They could not tell when that original compromise had happened, but the method they used was sophisticated and had been found at other companies that had similar intrusions.

One of the most interesting things they found was that the state-sponsored group had likely sold access to the credit union network to another, likely an organized crime group that specialized in ransomware. This approach we are told is more common these days as the groups then specialize in their respective areas.

In the meantime, we had validated that offsite backups were not contaminated and could be used to help rebuild the credit union network. The cybersecurity firm had a standard process to create a new, separate, air-gapped network and slowly move machines from the dirty network to the clean one after they had been sanitized. This was painstaking work and took many days to complete. We worked very closely with them and at their direction to ensure the details were followed for each system.

While this was happening, the negotiator continued to haggle with the bad actors over the dollar amount requested. The bad actors had also given proof that they were able to exfiltrate member information, including an AIRES file, from the credit union and were prepared to sell that information on the dark web if their demands were not met. This is a newer tactic to add leverage in the hope of getting a payout.

The credit union was closed for this week while all tech was sanitized. Given they had good backups, and there was no guarantee the bad actors would return the exfiltrated member data, they decided not to pay the ransom, which at this point had been negotiated down to approximately $2.5M. The members who wanted to do in-branch transactions were starting to get frustrated, so re-opening as soon as was safely possible was the highest priority.

A more common and costly occurrence 

Ransomware events of several years ago were not nearly as sophisticated or as costly as they had become. Ransomware events were often slow to propagate the network, easy to detect if they had already been in the wild by traditional endpoint security software and the ransoms were in the tens of thousands, not millions of dollars.

The involvement of both states sponsored and organized criminal groups point to how effective a revenue generator this has become for groups that are sheltered in countries that either directly support or turn a blind eye to their activities. Think about the number of companies you have read about that publicly disclose this because they must…then think about the many multiples more that do not.

The end of an incident

Thankfully, this incident had as good an outcome as could be expected. The following week the credit union reopened its doors to members. The credit union retained most of their members, for whom they were providing credit monitoring for the next year. They opted to retain the cybersecurity firm to supplement their efforts after the incident concluded. The remediation and recovery was an effort that required over 1,000 hours of work from multiple teams. Our Network Security team had over 400 hours in the recovery alone.

What are the key takeaways for your institution?

  • Have a solid plan. It is best to prepare in advance and avoid trying to come up with a response in the stress of the moment. Prepare communications, understand and have contact information for the key players on your incident response team, and make sure everyone knows their roles and responsibilities.
  • Understand the technology and security you have. It is difficult to assess cybersecurity risks and gaps if you do not understand both what your team is doing, what your third parties and partners are doing, and what they are not doing. Make sure you have gone through a detailed assessment of this and that you are comfortable with the residual risk based on your approach.
  • Align with the right partners. Consider seeking out specialized partners for things like 24×7 monitoring through a security operations center or a managed detection and response service. Make sure your insurance coverage is appropriate for your organization.
  • Test, prepare, and practice. People are key in cybersecurity effectiveness and incident response. Make sure you’re training your team on the threats out there, how to use tech safely within the organization and to report suspected incidents as soon as possible. Conduct tabletop incident response scenarios to practice what an event might look like with your team.



“The Public Purpose” of the Credit Union Cooperative System

In every new administration and most assuredly  following economic or other national crisis (Covid, natural disasters), the need to review governmental and agency responsiveness is raised.  Are changes needed?

Whether prompted by political priorities or  performance shortcomings, this is how existing policies are reassessed.

Another motivator is when market competition carries over to the political arena . Firms call out their rival’s more favorable regulatory  or tax status in their lobbying messaging.

In last week’s posts listed below, I noted the current absence of a policy framework at NCUA for the cooperative system.  I believe this leaves the system vulnerable to priorities set by others or to purely personal agendas.

The Reviews Begin

Last week the Director of the Federal Housing Finance Agency (FHFA) announced a review of the FHLB system.  FHFA, created in 2008, is the successor to the five person FHLB board.  This single administrator oversees the eleven FHLB’s and the conserved Fannie Mae and Freddie Mac.

The assessment of the 90-year old FHLB’s $ 1 trillion assets is to determine if  its modern day activities fully match its original mission of supporting mortgage lending.

FHFA Director Thompson’s purpose is to ensure the banks “remain positioned to meet the needs of today and tomorrow.”  One outside observer noted: “The home-loan banks lack a well-articulated contemporary purpose.”

Similar to credit unions, the FHLB cooperatives are exempt from corporate federal, state, and local taxation, except for local real estate tax.  For individuals, all FHLB bonds are also exempt from state and local taxes.

Credit Union’s Tax Exemption On the Agenda

A month earlier on July 27, columnist David Bauman wrote how the GAO was urging the OMB to study tax expenditures,  a budget category that includes the credit union tax exemption.  Are numerous tax exempt organizations still fulfilling their mission?

Bauman points out  the Treasury Department estimated the credit union tax immunity will cost the federal government $25.3 billion between 2022 and 2031.  This issue he wrote is “part of an ongoing battle between the banking and credit union industries.”

Scrutiny Not a New Process

From 1981 through 1985, the credit union system was part of four national studies directed by the Regan administration.  These were in  response to record high inflation, unprecedented interest rates,  disintermediation, financial innovation and growing concerns with institutional solvency.  For example, the Penn Square Bank’s 1982 failure was the largest FDIC liquidation post WW II.

In addition to the normal inter-agency or industry councils such as the FFIEC, NASCUS and multiple studies such as CUNA’s CapitalizationCommission, NCUA’s Chair was directly assigned to these four government-wide  assessments.

  1. The Depository Institutions Deregulation Committee (DIDC) was a six-member committee established in 1980 by Depository Institutions Deregulation and Monetary Control Act passed on March 31, 1980. DIDC’s primary purpose was phasing out interest rate ceilings on deposit accounts by 1986.

NCUA Chairman Callahan was one of five federal depository regulators. Chaired by Treasury Secretary Regan, all banks and S&L’s were given until June 1987 to end all federal controls on deposits.

NCUA chose not to follow the banking group’s timetable, eliminating all regulations in one new rule in May 1982. The decision effectively gave credit unions a five-year head start in the new market-facing era for financial intermediaries.

  1. The Garn-St Germain Depository Institutions Act of 1982, known as the “Deposit Insurance Flexibility Act” mandated that the three regulatory agencies study their insurance funds and make any recommendations for future changes.

On April 15, 1983, NCUA forwarded its 71-page, five-chapter study containing four policy recommendations.  This study became the foundation for the NCUSIF’s financial redesign approved by Congress in The Deficit Reduction Act  signed by the President  on July 18, 1984,

In Chairman Callahan’s forwarding letter to the study he noted:  “For credit unions there are very clear answers to the issues raised by Congress.  This is because credit unions . . .have actual experience with the options and alternatives suggested. . .Our responses are based on historical facts and current operational realities rather than academic theories or untried options. The credit union experience with insurance has been substantially different from the other agencies and our recommendations accordingly reflect this unique heritage.”

  1. The Private Sector Survey on Cost Control(PSSCC), commonly referred to as The Grace Commission, was an investigation requested by President Ronald Reagan, authorized in Executive Order 12369 on June 30, 1982.

The focus was waste and inefficiency in the US Federal government. Its head, businessman J. Peter Grace, asked the members of that commission to “Be bold and work like tireless bloodhounds, don’t leave any stone unturned in your search to root out inefficiency.”

The Grace Commission Report was presented to Congress in January 1984.  The Report included this observation:   “NCUA Chairman Callahan is a role model for government agency executives.  In one year NCUA reduced Agency staff 15% and its budget, 2.5%, while maintaining their commitment to preserving the safety and soundness of the credit union industry.” (NCUA 1983 Annual Report, page 3).

  1. The Vice President’s Task Group on the Regulation of Financial Services was formed in late 1982. Treasury Secretary Regan, the five financial regulators, the Attorney General, Directors of OMB, chairs of the SEC and FTC and state regulators raised the total principals to thirteen. The Group was given one-year to make recommendations to address the challenges of the emerging financial markets after deregulation and the potential repeal the Glass Steagall Act.

A final report was issued in November 1984. The Group’s recommendations were summarized by John Shad, Chairman of the SEC, in a later speech. He closed saying:

The lines of demarcation between the financial service industries have eroded. These activities should be regulated, and permitted to compete, according to their functions, rather than outmoded industry classifications.  

NCUA and the independent cooperative system were not mentioned in the Group’s regulatory recommendations.

NCUA and credit unions thrived in this transformative period of rapid financial change and increased scrutiny by completing the institutional, regulatory and policy foundations for a separate, unique and sound cooperative system.

Why a Cooperative Policy Framework is Essential

Without a clearly stated understanding of credit union’s role, every government study above could have drawn credit unions into their macro policy recommendations.

Instead NCUA demonstrated its ability to develop, document  and implement  how the deregulated cooperative system was successfully meeting its public purpose role serving members.

The cooperative system’s soundness was based of the values of self-help, self funding, and democratic volunteer leadership.  The “moral hazard” concern from FDIC/FSLIC insurance of private financial ownership  was absent in  cooperative’s creation of “common wealth.”

Today the ability to articulate this purpose is missing.  Regulations, especially the recently imposed RBC/CCULR were defended as being virtually identical to bank capital requirements.  New charters are rarely issued raising the question of credit union relevance today.  Whole bank purchases are routinely approved by NCUA even though  this use of member savings would seem contrary to why a cooperative system was created.

Absent an awareness of cooperative history and precedents, policy pronouncements or priorities of board members may just seem  like comfortable generalities.

In Harper’ July 2022 investiture address, he reflected on his year and half tenure as Chairman:

In achieving each of these things (regulatory activities), we have followed a philosophy that should guide all financial services regulators. Specifically, we were fair and forward looking; innovative, inclusive, and independent; risk focused and ready to act when needed; and engaged appropriately with stakeholders to develop effective regulation and efficient supervision. This philosophy will continue to drive our actions in the years ahead.

Is this the regulatory understanding that credit union cooperatives are seeking?

Sooner or later credit union’s special identity will be challenged by some governmental or political process.

The cooperative system navigated the multiple reviews from 1981-1985  because NCUA and credit unions earned a reputation for trust, expertise, mutual respect, shared purpose and performance.  This achievement was recognized by the industry and throughout the executive and legislative branches of both state and federal government.

NCUA Chairman Callahan in the Agency’s 1984 Annual Report observed:  The only threat to credit unions is the bureaucratic tendency to treat them, for convenience sake, the same as banks and savings and loans.  This is a mistake, for they are made of a different fabric.  It  is a fabric  woven tightly by thousands of volunteers, sponsoring companies, credit union organizations and NCUA-all working together. (page 3) 

Should  the movement aspire for anything less in this time?



A Rare New Species Sighted This Labor Day

Rare bird sightings are often front-page local news.  Such was the lead story on July 5, 2022  in Rockland, MI: Rare Eurasian bird spotted in Michigan, first sighting in US:

A Michigan birdwatcher made a once-in-a-lifetime discovery this weekend when he spotted a bird known as a common redshank in a marsh near Detroit, a few thousand miles from the bird’s usual home.

Equally rare among the financial species is discovering a new credit union charter.  The local news headline says it all:   Somebody Actually Started a New Credit Union. Here’s How They Did it.

This was the second sighting of a new credit union charter this year.  NCUA’s press announcement described the event as an example of credit union’s purpose: Supporting underserved communities and providing capital for community development is at the core of the credit union mission. 

Few in the credit union movement are actively trying to spot new charters.   CU*Answers and its CUSO challenge is one multi-year institutional effort.  Two individuals have been public in their pursuit of this rare activity:  Denise Wymore and NCUA Vice Chair Kyle Hauptman.

Because this event is so unusual, the joy, passion and hope embodied in a new credit union today are often overlooked.

Many persons’ deep desire to create something new to serve one’s community is a defining characteristic of American enterprise.

Entrepreneurs are central for a market economy, especially for new credit union charters that begin with limited financial capital.

On this Labor Day eve, I am reprinting this August 30 story as I believe it describes the dynamic human spirit new charters bring to the movement.  Enjoy this description of Community First Fund FCU’s creation by OSCAR PERRY ABELLO:

A Credit Union in the Neighborhood:  It Just Makes Sense

Leo Rodriguez knew all he needed was $10,000 in startup capital to open his own hair salon, something he’d dreamt about doing since he was four years old and saw a poster of legendary hair stylist Vidal Sassoon. Twenty-nine years and countless clients later, he is more excited than ever to invest back into the only institution that believed enough in him to make that loan.

The year was 1993. Rodriguez had already spent the previous several years studying cosmetology and hair styling in New York City and London. He returned to his home city of Lancaster, Pennsylvania, where he landed a job working at a new downtown hair salon founded by local legend Paula Severino Standish. After a wildly successful year, gaining his own influential clientele, he knew it was finally time for him to go out on his own.

He just needed that $10,000. But none of the banks he went to around town were interested in loaning him the money.

“I wasn’t looking to, like, renovate a building, I just needed a couple chairs, just to get started,” Rodriguez says. “There were a lot of banks that just didn’t want to give you any money. It was very hard to start a business. Also being a minority, that was difficult.”

A Personal Connection

But as fate would have it, one day Rodriguez was catching up with his childhood friend, Daniel Betancourt, who had recently left his job in commercial banking to join a new loan fund created by another local legend, a Black civic leader named James Hyson. Now called Community First Fund, it invests in Black, Hispanic, immigrant and other entrepreneurs whom traditional financial institutions weren’t interested in serving.

Not only did Community First Fund give Rodriguez his first $10,000 loan, it also taught him the ins and outs of running a business, creating a business plan, proper accounting, and profit and loss statements. He soon repaid that $10,000 and borrowed another $35,000, then $50,000. Every time he needed to expand or renovate or move his salon to a different location, he went back to Community First Fund. During his prime — he’s 63 now and expects to semi-retire in a few years — Rodriguez had 10 stylists working in his downtown Lancaster hair salon.

“I probably borrowed over three or four hundred thousand dollars from them in total over 30 years,” Rodriguez says. “They’ve never turned me down. They were always, always there for me.”

Loyalty and a Credit Union

Earlier this year, Community First Fund opened a traditional financial institution, a credit union. Why? Because after serving entrepreneurs like Rodriguez for 30 years, the fund found that the families and communities around those entrepreneurs either weren’t getting access to banking and affordable credit elsewhere or would prefer access to banking and affordable credit from a name and face they’ve come to trust.

Rodriguez was one of the first members of the new Community First Fund Credit Union. He’s moving all his personal and business accounts over.

“I’m into loyalty, man. I’m into taking care of people. it’s what I do,” Rodriguez says. “When Dan was telling me they were gonna open up this credit union, I’m like, ‘Oh, Jesus, thank God.’”

New Credit Unions Much Rarer

Starting up a new credit union is much rarer than it used to be. Prior to 1970, it was typical for federal regulators to charter 600-700 new credit unions every year. But since then, for multiple reasons, the number of new credit unions chartered every year began a long, slow decline. The new Community First Fund Credit Union was one of only four chartered in 2021. That’s as many new credit unions chartered over the previous five years combined. With so few new credit unions starting up, and scores closing or merging with others every year, the total number of active credit unions has declined from a high of 12,977 in 1970 to just 4,872 today.

The new Community First Fund Credit Union is also an even rarer example of something else. It’s modeled partly after Hope Credit Union, based in Jackson, Mississippi — which itself is really a replication of a model for banking that was birthed either on the South Side of Chicago or Manhattan’s Lower East Side, depending on who you ask. The model explicitly combines deposits from inside the community with deposits brought in from outside the community that might otherwise be deposited in bigger banks like those on Wall Street.

CDFI Plus a Credit Union

“The very fact that a new credit union is chartering is something noteworthy,” says Clifford Rosenthal, who helped establish Lower East side People’s Federal Credit Union in 1986. “And it’s especially significant in the CDFI world that this loan fund has used its resources to establish a credit union, which in the optimal scenario will operate side by side with the loan fund and hopefully achieve some real synergies.”

CDFI stands for “community development financial institution,” a U.S. Treasury designation for loan funds, credit unions, banks and venture capital funds that have a primary mission of serving low-to-moderate income, historically marginalized communities. Rosenthal helped craft the legislation passed in 1994 that created the CDFI designation as well as the CDFI Fund, an arm of the U.S. Treasury that provides grants, tax credits and other forms of support for CDFIs across the country. Community First Fund is a CDFI loan fund, and after it gets up and running, the new credit union can also seek its own separate CDFI certification.

Based on his own experience helping to start a credit union to serve a neighborhood other financial institutions were leaving behind at the time, Rosenthal expected that the new CDFI Fund would provide assistance to other groups starting either new credit unions or banks — regulated, depository institutions. But that isn’t how things turned out. Most of the CDFI Fund’s support has gone to loan funds like Community First Fund. And, with assistance from the CDFI Fund, some of those loan funds have grown very large, with assets in the billion dollar range.

“Some of the loan funds clearly have the capacity to launch a depository institution if they choose, but none of them have until now,” Rosenthal says.

Five Years Planning

Betancourt, now the CEO of Community First Fund and its credit union, says he started mulling over the idea maybe around five years ago. Clients of Community First Fund would occasionally ask if the loan fund could maybe help them or their families out with a home mortgage, or a used car loan, or alternatives to payday loans. Maybe they had tried getting those loans elsewhere and couldn’t, maybe they just wanted to deal with an institution they already knew and came to trust. At the time, Community First Fund had no way to help with those situations directly, it could only refer those requests to others.

Betancourt says he also started reading books like Lisa Servon’s “The Unbanking of America,” which gave him even more food for thought. Community First Fund also partnered with Lancaster’s Franklin & Marshall College to do a study of underbanked populations in Lancaster County.

More recent findings affirm what Betancourt was starting to grapple with. A study released last week from the Joint Economic Committee Democrats in Congress found Black and Hispanic Americans are more than twice as likely as white Americans to be unbanked or underbanked. Similarly, families at the bottom of the income distribution are more than six times as likely as families at the top of the distribution to be among the unbanked or underbanked. In 2021, 46% of Black Americans and 37% of Hispanic Americans reported that they had been denied credit or were approved for less credit than requested, compared to less than 25% of white Americans. Evidence shows that while new financial technologies show less bias than face-to-face lenders, they fail to eliminate discrimination.

Social Change with Transformational Deposits

The year 2020 ended up becoming the moment that provided the fuel for Betancourt’s credit union fire. Between the racial disparities laid bare by the COVID-19 pandemic, and the racial reckoning sparked by George Floyd, Breonna Taylor and other Black people killed at the hands of police, individuals and corporations were looking for something to do in response. One of the options that emerged was moving money into Black banks and credit unions.

Hope Credit Union received a $10 million deposit from Netflix and another $10 million deposit from PayPal, on the way to raising $100 million in deposits from corporations and philanthropy. CEO Bill Bynum started telling corporations his credit union actually didn’t need any more, but he could refer them to others like Betancourt who were looking to secure such big dollar corporate deposits — which Bynum started calling “transformational deposits.” They aren’t donations. These are part of the large pots of money that all corporations keep around on their balance sheets as part of managing their finances, but historically they’ve left those deposits in big banks or short-term Wall Street investments.

Finding Capital

But Betancourt needed more than just transformational deposits to charter a new credit union. Federal regulators require depository institutions to set aside a small portion of cash as a cushion against potential losses. For banks the minimum is $1 set aside for every $11 in assets, for credit unions it’s $1 set aside for every $16 in assets. New banks typically raise that initial small portion of cash from their shareholders. New credit unions can’t do that. So Community First Fund instead launched a capital campaign, in the traditional sense of a nonprofit or church group capital campaign in which donors are asked to make multi-year pledges.

For every corporation that called about making a transformational deposit, Betancourt also approached them about making a multi-year pledge as part of Community First Fund Credit Union’s capital campaign. And of course Community First Fund went around to its long list of previous donors to see who else might be interested in contributing to the capital campaign. A pledge of $500,000 could be spread out over five years, as $100,000 a year in retained earnings for the credit union to set aside as part of its regulatory requirements.

A Wealthy Donor

Community First Fund might have needed more time were it not for MacKenzie Scott’s surprise $10 million donation to the nonprofit, $2 million of which it plowed into the capital campaign for the new credit union. Thanks to the capital campaign pledges, stretched out over as many as five years, the new credit union projects it will have positive net income starting from year one. That’s unusual for any new depository institution, most of which anticipate negative net income during the first few years of getting up and running.

With its target customer base, letters of intent for transformational deposits and capital campaign pledge letters, not to mention its decades of experience making 5,592 small business loans and counting, Community First Fund submitted all of that as part of its charter application to the National Credit Union Administration in December 2020. The agency approved the application in just six months — lightning speed by normal chartering standards.

Since then, Community First Fund converted its headquarters into its first credit union branch, serving the Lancaster metropolitan area’s 550,000 residents. The credit union eventually plans to open six total branches and also leverage online and mobile banking to serve Community First Fund’s entire footprint, which now includes Philadelphia and crosses state lines into Delaware and parts of New Jersey.

The loan fund will continue to do what it has been doing, providing loans to underserved business owners, 71% of whom so far have been people of color. But now it has an affiliated credit union as a way to meet those requests for home mortgages, auto loans, emergency loans and other personal loan requests from its existing borrowers and their networks.

A Credit Union in the Neighborhood: “It Just Makes Sense”

“I’m so happy that they got the new credit union,” Rodriguez says. “It’s almost like the old way, you know, where you had a bank in the neighborhood and it knew everybody in the neighborhood and you knew the bank was there to help you. I believe every client that they ever had will open up an account there. It just makes sense.”



The Credit Union-Regulator Relationship

The basis for a shared cooperative regulatory policy framework:

“The relationship between credit unions and the regulatory agency is one founded on mutual self-respect, and on the realization that both sides share equally in the responsibility for the survival and future development of credit unions.”

(NCUA 1984 Annual Report, Page 14)

The Harm from an Absence of a Cooperative Policy Framework (Part II of II)

Yesterday (August 29) a press release from the North Dakota Credit Union League described NCUA’s turning a deaf ear to their request for their credit union members’ $10 million pro rata share of US Central’s AME surplus.

The final total may actually exceed $12.7 million based on NCUA’s March 2022 AME projected US Central distributions.

The NCUA’s Claim receipt states:  Upon final liquidation of the USC liquidation estate, this claim receipt will enable you to share  in the net proceeds, if any, to the extent of your PIC and MCA balances as of the record date.  No further action is required on your part to file or activate a liquidation claim.

The Dakota League’s title says it all: Time for NCUA to Do the Right Thing.  Its release points out Iowa credit unions are in the same situation. One might also ask how are all the corporate member shares of credit unions who were merged before AME payouts began being distributed? (example, Constitution Corporate)

Moreover, all credit unions  are still waiting for an update on the remaining $451 million of the reported $846 AME surpluses as of March 31, 2022.

These are just the most recent examples in which NCUA seems indifferent to its responsibilities to put credit unions and their members’ interests first.  This “me-first” approach is not lost on credit unions’ own activities.

Members’ Best Interests No Longer?

Lacking a cooperative policy framework, NCUA claims it is powerless when obvious conflicts of interest and direct subordination of fiduciary responsibilities by boards occur.   The members’ best interests becomes a forgotten standard.

For example, consultants overtly market “change of control” clauses for CEO’ contracts, a perverse interpretation of its real intent since coop CEO’s are the ones who initiate their own mergers.  The most recent example is a $750,000 payment in the merger of Global Credit Union. CEO contracts are a board responsibility.

A CEO and chair transferred $10 million of member equity to a private foundation they alone created upon merging.  The foundation is to be financed by another $2.5 million from the ongoing credit union-a clear conflict of interest. NCUA routinely approved this diversion of members’ equity to private party’s control.

Without a cooperative policy framework, the NCUA’s only test of a credit union’s sustainability is financial.  This is the “safety and soundness” mantra.

That standard is similar to saying that a person’s character and contribution is measured solely by their wealth. That is the value-agnostic success criteria that animates much of the capitalist system.

This policy vacuum undermines the unique advantages of the cooperative model and its long term safety and soundness.  Members become customers with profitability profiles.   A credit union’s resilience is nothing more than a quarterly tracking of net worth trends.

Soundness requires continual investments in members’ best interest, not merely fulfilling management’s personal ambitions.  A regulatory framework for cooperatives should be a collaborative effort.  It is not an NCUA internal task responsibility alone, like a budget, to be put out for comment.

Policy  would address current operational  issues that threaten the system’s character and integrity.  It will entail provocative conservations about current topics such as:

  • mergers of sound credit unions
  • the regulatory hurdles and lack of new charters
  • the suppression of members’ ability to vote for directors
  • the absence of member transparency on consequential decisions such as buying banks or adding ten-year debt/capital notes
  • reducing real regulatory burdens and enhancing NCUA transparency
  • the roles of CLF and NCUSIF-distinctly cooperative institutions reliant on credit union funding.
  • Increasing required disclosures for all credit unions including salaries for all federal credit union’s senior executives as is now required for state charters.

One outcome might even be a cooperative scorecard which would assess each credit union’s use of their charter’s unique abilities.

Not Perfection, but Setting Directions

A policy framework does not mean all the resulting regulatory judgments or approvals will be  uniform.   A regulatory framework should encourage better decisions  supported by objective data as well as the cooperative and legal documented processes of fiduciary oversight and care.  Conflicts of interest should be called out.

Experience suggests policy outcomes may be like the biblical parable of “weeds and wheat” grown together. That’s a risk but less so than the “anything goes” practices today.

Credit unions are and always will be a combination of good intentions and variable performance. They are run by human beings. Not all choices will be perfect. This mixed bag is the reality of freedom.

Both credit union leaders and regulators make mistakes. It is acknowledging when that happens.  Then  learning from the event, not defending the errors.

This mixed reality doesn’t mean regulators and credit unions can avoid the diligence and accountability that should characterize credit union decisions.  It’s not okay for self-interest to be the dominant standard for an action.

All are free to make mistakes and sometimes fail, but that does not mean there are no standards to be followed.

Cooperative assessments are important for another reason.  Credit unions, unlike their competitors, are not subject to the market’s daily judgments of management’s actions.   Coops lack bank’s  external check and balance on institutional performance whether through daily stock price fluctuations or the oversight of private ownership interests.

If cooperative standards are not part of the movement’s culture, then credit unions will tend to become just another financial option increasingly indistinct in a crowded marketplace. This will lead Congress to ask why this system should retain the tax exemption that would appear to be their only defining advantage.

The cooperative framework should enhance the never-ending task of credit unions becoming better cooperatives.  Nobody is perfect.  But reducing regulatory oversight to a standard that says  7% versus 14% net worth is better at meeting members’ needs is shallow and unhelpful.

Developing a Cooperative Policy Framework

In 1984 the credit union system redesigned its share insurance fund following 18 months of study, comment, and public dialogue about future options.  The recommended changes then required congressional approval.

This success was the product of extensive collaboration and interaction at every  level of the credit union system.  This effort was described in this brief introduction of NCUA’s implementation video by then chairman, Ed Callahan:


A cooperative policy process should be collaborative, transparent and yes, controversial.  It should be democratic, public  and seek consensus on shared interests. Policy must encourage credit unions as communities of possibilities, not conformity.

An Alternative Path?

Without this policy framework, continuing examples of a “race to the bottom” business practices may put all credit unions on a path similar to the S&L industry with no turning back.

That does not mean credit unions (taxed or not) will disappear.   But it does suggest their separate regulatory apparatus will be absorbed by the FDIC, OCC and the FED. This is where the 602 institutions and $1.5 trillion savings industry is now regulated.

Why have a separate NCUA cooperative regulatory system if all it does is mimic the banking model?




The Missing Framework for NCUA Success (part I of II)

It is an accepted truism for NCUA board members presenting their credentials  for Senate confirmation, or whenever the agency is justifying a new rule, reg or policy, to state their ultimate goal is “to protect the insurance fund.”

Current board members have even called that objective their goal or North Star.  Their primary job.

This assertion turns upside down the logic of means and ends.

What is NCUA’s End Purpose?

NCUA’s primary responsibility, its purpose,  is encouraging and sustaining the resilience and integrity of a cooperative financial system for American consumers.  The FCU Act states:

The term Federal credit union means a cooperative association organized in accordance with the provisions of this chapter for the purpose of promoting thrift among its members and creating a source of credit for provident and productive purposes

To achieve this end, NCUA was given multiple means in the law:  chartering, examinations, supervision, administration of charter changes, issuing regulations and providing expert guidance.   The tool least used, as it is rarely needed, is calling upon NCUSIF.

Most importantly, the FCU act specifically states the NCUSIF’s financial solvency is protected by the full faith and credit of the credit union system.   All members must deposit and maintain 1 cent of each share dollar in a credit union with the NCUSIF.  Every member is part of this collective guarantee ensuring all other member shares are indeed safe. This is a cooperative movement commitment, unique to the NCUSIF.  It is the law.

If all of NCUA’s every day tools ( the other “means”) are effectively managed, then the members should never be called upon to provide additional resources.  That is how NCUA protects the Fund.

The first four-decades of regulatory responsibility to maintain cooperative system integrity from 1934-1971 did not require the share insurance tool.

One aspect of “integrity” was certainly promoting credit union solvency as there has always been reserving and net worth requirements in the law.

But just as important, system “integrity” (as a source of credit) also included vital cooperative components to provide a distinct financial alternative for members.  These  include democratic governance, values such as education and collaboration, volunteer leadership (unpaid directors and committee members), access for all Americans regardless of financial circumstance (capital), focus on community (common bond), and contrary to the capitalist model, building common wealth versus private equity, to be used by future generations .

Over time additional characteristics have been developed including interdependence (corporates and CUSO’s) and system support augmenting the critical initial role of sponsors.

A Reward for Performance

When Congress approved the NCUSIF for credit unions in 1971, it was a reward for their performance.  As stated at that time, insurance was not due to financial problems with credit unions or the cooperative system.  Rather it recognized their growing contribution to the American economy and that they might not perceived by the public as the equal of their FSLIC/FDIC alternatives.

A Cooperative Policy Framework Is Lacking

For NCUA to faithfully fulfill its mission to protect the integrity of this cooperative financial alternative, an appropriate regulatory policy framework is necessary. Such a framework should be nonpartisan and multi-administration.  Past examples are the deregulation of shares by NCUA or the redesign of the NCUSIF.

Without a thoughtful and evolving framework, NCUA becomes a mishmash of regulatory justifications or each Chairman’s personal priorities.  What do the banking regulators do?  Or let the “free market” work its will.  Or elevating suboptimal tasks and agency operations  to define priorities.

Absent a policy framework, the unique role of cooperatives becomes increasingly confused with all the other financial activity in the marketplace.   No longer are the well-being and rights of member-owners front and center.  Bright shiny objects such as innovation and new technologies take center stage.

The ambitions of managers and boards seeking to outgrow their for-profit competitors become the industry’s defining priority.  Some credit union leaders chart success not by developing a better alternative to attract members, but rather using their decades of member reserves for buying out bank owners at a premium.

That activity would certainly seem contrary to the spirit of the Act.  And therefore worthy of public debate.

Credit union CEO’s, nearing retirement, game the system for personal enrichment  “selling their credit union” via merger.  They capitalize on the transfer of members’ accumulated wealth and loyalty for additional bonuses and extended payments beyond those merited as CEO.

In these transactions, the financial and relationship legacy, its goodwill, is turned over to boards and CEO’s with no prior connection.  And justified only with vague future promises that bigger is better.  The unique character of the charter and its local legacy and traditional focus are eliminated.

Tomorrow Part II, developing a policy framework.