Chip Filson
Leadership changes are necessary to sustain every organization’s success. Sometimes changes at the top work well; other times they come with drama and uncertainty.
New CEO’s, especially if brought in from outside an organization, will have a healthy disrespect for the status quo.
But no one wants a job they disrespect.
So the critical performance standard is the leader’s vision of the future. Is the person equipped with the right motivation, not just relevant professional skill sets? Or, are they chosen just to break from the past?
Credit unions as cooperatives can teach and illuminate human possibility. But it can only do so to the extent that leaders are determined to use the design for those ends.
Otherwise, it becomes nothing more than an aggregation of financial accounts in a marketplace full of options.
Memory can be the key to understanding events. It provides vital perspective for the present and context for future plans.
Last Friday October 13th was an important event in NCUA and credit union history from 13 years ago.
It was the anniversary of the payoff of the most recent loan made by the CLF. It may in fact become the last loan the Facility ever extends. Reviewing this event illustrates why this public-private cooperative partnership has failed to play any meaningful role since in the credit union system.
Here are excerpts from NCUA’s Media Advisory of October 13, 2010 with the headline:
NCUA Repays $10 Billion in Corporate Loans
Using proceeds from selling performing assets of two formerly conserved corporate credit unions, the NCUA yesterday repaid $10 billion plus interest to the Department of the Treasury.
NCUA raised the $10 billion by selling select assets from US Central and WesCorp . . .(including) securities backed by performing residential and commercial mortgages, credit card receivables, student loans and auto loans.
The proceeds allowed NCUA to repay a $10 billion loan from the Treasury to NCUA’s Central Liquidity Facility which in 2009 transferred the $10 billion to the NCUSIF in order to lend $5 billion to each corporate. . . while they were in conservatorship.
Paying off the $10 billion in loans clears the balance sheets of both the CLF and the Share Insurance Fund,” said NCUA Charmain Debbie Matz.
Since that October 13the payoff, the CLF has made no loans. Or even offered a lending initiative.
When putting US Central and four other corporates into liquidation in September, NCUA eliminated the joint plan that gave all credit unions access to the Facility.
The Agency had no backup proposal. A brief history of this period and the Agency’s effort to mandate liquidity via regulation versus a shared cooperative option is described here.
In the first six months of 2023 credit unions increased total borrowings by $75.6 billion to a total of $120.4 billion at June 30. The two major sources for these funds were the FHLB system which increased loans by $46 billion and the Federal Reserve, a $29 billion lending expansion.
Even natural person credit unions increased deposits in other credit unions by $650 million via brokered non-member deposit programs.
The CLF with almost $900 million in capital and $20 billion in borrowing authority is missing in action.
This absence is not because no need exists or a shortage of resources. Rather it is an inability to work cooperatively with credit unions. The Federal Reserve announced its new Bank Term Funding Program on March 12 or in days following the Silicon Valley bank failure.
NCUA does not lack statuary authority as suggested by board members to serve credit unions. It lacks collaborative leadership.
But credit unions took an important lesson from this CLF loan payoff. The borrowing was designed by NCUA to provide for NCUSIF’s liquidity not the corporate credit union’s well being. Immediately after the two corporates were in liquidation, NCUA sold the best performing assets versus using their earnings to minimize losses to the fund.
The borrowings were to support NCUA’s regulatory priority, not to assist with a corporate’s liquidity management.
When put into liquidation, three of the corporates reported positive capital including US Central, Southwest and United. The CLF was paid off. The Agency funded the subsequent liquidations of all five corporates by going to Wall Street to issue NCUA guaranteed notes to fund the ongoing asset recoveries. These new borrowings were at rates many times higher than the cost of short term deposits and the rate on CLF borrowings.
Credit unions saw that the CLF was not a resource for their use. It was only a means for NCUA to manage the NCUSIF’s cash flows for its obligations to the insured corporates’ members. CLF’s borrowings were not for sustaining the corporates operations. In Matz’s characterization the loan payoffs: “clears the balance sheets of both the CLF and NCUSIF,” but at the expense of the corporate members.
In a recent interview before the NAFCU caucus Chair Harper reinforced this view that the CLF is only an NCUA tool, not a shared responsibility. He said staff had been requested to review lowering the current $250 million asset threshold for credit unions required to have a federally backed liquidity source (the Federal Reserve or the CLF). That is to force more credit unions by rule to join the CLF.
When given a choice, credit unions have overwhelming decided to belong to the Federal Reserve rather than the CLF, which has only 390 regular credit union members. The CLF is seen as simply an arm of the regulator, not a resource for credit unions.
As outlined in an earlier analysis, credit unions no longer view the CLF as a reliable partner in times of balance sheet stress
This 13th anniversary of the last loan payment is another milestone. It marks a year of no progress in making the CLF relevant for the credit union system. Rather, it has just become another funding source for growing a bureaucracy with no obvious role.
Editor’s note: Here is how one corporate recommended the CLF be changed in a 2011 comment on NCUA’s proposed liquidity regulation:
Alloya was among approximately 62 organizations commenting on the proposed regulation. The corporate’s comments centered around continuing the CLF, but making it closer in capital structure and operational nature to the Discount Window (immediate availability, little or no capital requirement), maintaining corporates as the agents for the CLF, allowing corporates to borrow from the CLF, CLF Board representation by credit unions and better investment returns on CLF stock through longer term investing.
The majority of credit union and corporate comments were similar and found value in continuing the CLF, but suggested that the structure (either capital or operational or both) be changed to preserve value. Another large portion of the comments were in reference to allowing the FHLB to act as a source of emergency liquidity.
None of these suggestions were adopted in the final rule or in CLF operations.
by Edgar Guest (1916)
It takes a heap o’ livin’ in a house t’ make it home,
A heap o’ sun an’ shadder, an’ ye sometimes have t’ roam
Afore ye really ’preciate the things ye lef’ behind,
An’ hunger fer ’em somehow, with ’em allus on yer mind.
It don’t make any differunce how rich ye get t’ be,
How much yer chairs an’ tables cost, how great yer luxury;
It ain’t home t’ ye, though it be the palace of a king,
Until somehow yer soul is sort o’ wrapped round everything.
Home ain’t a place that gold can buy or get up in a minute;
Afore it’s home there’s got t’ be a heap o’ livin’ in it;
Within the walls there’s got t’ be some babies born, and then
Right there ye’ve got t’ bring ‘em up t’ women good, an’ men;
And gradjerly, as time goes on, ye find ye wouldn’t part
With anything they ever used—they’ve grown into yer heart:
The old high chairs, the playthings, too, the little shoes they wore
Ye hoard; an’ if ye could ye’d keep the thumbmarks on the door.
Ye’ve got t’ weep t’ make it home, ye’ve got t’ sit an’ sigh
An’ watch beside a loved one’s bed, an’ know that Death is nigh;
An’ in the stillness o’ the night t’ see Death’s angel come,
An’ close the eyes o’ her that smiled, an’ leave her sweet voice dumb.
Fer these are scenes that grip the heart, an’ when yer tears are dried,
Ye find the home is dearer than it was, an’ sanctified;
An’ tuggin’ at ye always are the pleasant memories
O’ her that was an’ is no more—ye can’t escape from these.
Ye’ve got t’ sing an’ dance fer years, ye’ve got t’ romp an’ play,
An’ learn t’ love the things ye have by usin’ ’em each day;
Even the roses ’round the porch must blossom year by year
Afore they ’come a part o’ ye, suggestin’ someone dear
Who used t’ love ’em long ago, an’ trained ’em jes’ t’ run
The way they do, so’s they would get the early mornin’ sun;
Ye’ve got t’ love each brick an’ stone from cellar up t’ dome:
It takes a heap o’ livin’ in a house t’ make it home.
| Edgar Albert Guest, born on August 20, 1881, in Birmingham, England, but raised in Detroit, was a poet known for his popular verse. |
Everything in life comes around, full circle, even in credit unions.
“In 1908, Monsignor Pierre Hevey, Pastor of Sainte-Marie’s parish in Manchester, New Hampshire, organized what was soon to be known as the first credit union. The goal was to help the primarily Franco-American mill workers save and borrow money.
“On November 24, 1908 in Manchester, New Hampshire “La Caisse Populaire, Ste-Marie” (The People’s Bank) became the first credit union in the nation.” (from Our Story, St. Mary’s Bank)
Today the Bishops and priests of the Episcopal Diocese of New York are following in Monsignor Hevey’s footsteps. And for many of the same reasons, as demonstrated in these founders’ statements:
“As a diocese, we are committed to making a meaningful impact on the lives of those who have traditionally been marginalized and underserved. That’s why the establishment and launch of our diocesan credit union is such a pivotal moment for us.
“It’s not just about providing financial services, it’s about creating an inclusive space where everyone, irrespective of their financial standing, can feel valued and supported. . .
“These initiatives are more than just programs or ideas, they are a call to action, a call to embody the love and grace of God in the world.”
A second organizer:
“As a member of the inaugural board of trustees and co-chair of the Diocese’s credit union task force, I am thrilled to see the New York Episcopal Federal Credit Union open its headquarters and first branch here in the Bronx. It’s a testament to our commitment to the local community and our mission to serve everyone in our field of membership, regardless of their financial circumstances.
The existing banking system often neglects the needs of those who are underserved and overlooked, and that’s why we’re excited to offer a financial institution that prioritizes the well-being of all its members. We look forward to empowering our neighbors in Fordham and throughout the Bronx, as well as the entire Diocese of New York, with the tools and resources they need to achieve financial stability and thrive.”
The biblical calling to be “stewards of humanity” was featured in this short recording by the Diocese announcing the credit union’s formation.
In the June 30, 2023 call report, the credit union reported $477,000 in total assets, all in investments, and a net worth of the same amount.
Here are some details of the charter journey from an Episcopal News Service May 23rd story:
“The journey towards establishing the NYEFCU began in 1990 when the Diocese of New York committed 10% of donations to its endowment funds to economic justice efforts and created a task force to recommend projects. Despite initial discussions and resolutions in 2003 and 2004, the credit union’s development was slow.
“It wasn’t until 2014 when the diocesan convention voted to “authorize the establishment of a task force to prepare a charter and solicit initial grants and deposits to establish the Episcopal Diocese of New York Credit Union.”
The Diocese embraces a lively community of faith, fellowship, service and spiritual commitment across almost 200 congregations and 50,000 members.
“The task force submitted an application for a federal charter to the National Credit Union Administration in December 2020, and spent 2021 and 2022 addressing the federal agency’s requests for more information and revisions before finally receiving approval.
“The credit union was launched with an initial investment of $500,000, with $250,000 from the diocese and another $250,000 from Trinity Church Wall Street. An ongoing fundraising drive aims to secure an additional $300,000 to cover the first five years of operating expenses, including staffing, office supplies, and computer technology. After this period, NYEFCU aims to have enough members to sustain itself without further external funding.
“The first branch of the NYEFCU is located next to St. James, Fordham in a new mixed-use development (St. James Terrace) that will house 102 affordable apartments, half of which are allocated for formerly homeless individuals. In its inaugural year, the credit union aims to cater to the specific financial needs of its low- to moderate-income members by offering an array of services.”
No matter the size of America’s collective consumer wealth, many still have limited access to fair financial options. These are often the targets of for-profit financial offerings.
It’s no accident that people of faith have played a major role in the establishment of coops as a way to serve their congregations. They remind all of the values animating credit union pioneers. And the values that make cooperatives more than “nice banks.”
The fact that this charter application and processing will take from 2020 (when submitted) until the end of this year to raise sufficient capital, shows the perseverance required overcoming government bureaucracy.
These spiritual founders are responding to the call to serve by creating a financial cooperative.
The major difference is that the Diocese had one hurdle that Monsignor Hevey did not have to deal with, the NCUA. It just shows it helps to have God on one’s side.
Most commentary on rates focuses on when will the Fed stop raising, pause and then lower rates. And what will be the new normal? Will the markets ever see another ZIRP, zero interest rate policy? What ever happened to Modern Economic Theory that deficits don’t matter?
Here is a recent observation from Michael Higgins a consultant for banks and credit unions:
| Since the inception of Fed Funds Rate in 1954, the average is 4.60% and median is 4.16%. Today it’s 5.33% (Source: St Louis FRED). The recent decade was a statistical outlier. If you entered the industry after iPhone was introduced, this is how things used to be. As one expert noted to me, it’s going to be “normal” for longer. |
Following the formal board reports and the one hour Member Feedback Forum (comments limited to two minutes each), the Chair read the results of the contested election.
The three member-nominated candidates won all open seats by receiving the three highest vote totals of the six candidates. Overall 13,335 votes were cast, based on the highest total from each group. Incumbent directors received 47% and the candidates nominated via petition, 53% of all votes cast.
The new directors, left to right, are Michael Clements, Barbara Perkins, and Chuck Stone.
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Voting is the essence of democracy. All members had the chance to choose who they wanted to lead this iconic credit union. That is a choice that rarely occurs in credit unions today. But now the precedent has been set.
Another fascinating aspect of the meeting was the open Forum. I counted 32 members who spoke up. Here are several brief snippets of their remarks, addressed to the full board and CEO. There were no responses given to any of the concerns.
And many more. There was no dialogue and no responses from the stage even when members posed a question.
One speaker, a new member, stated that she wished she had known about these comments before she voted as she knew nothing about the candidates or issues except the information in the ballot.
The cumulative effect of these spontaneous, brief observations was overwhelming. Speakers cared strongly about the credit union and its change of direction.
A long time credit union advocate who watched the meeting sent me this reaction.
This is What Credit Union Democracy Looks Like
This afternoon, my daily routine was disrupted in a good way by the annual meeting of North Carolina’s State Employees Credit Union (SECU), the $50-billion, 2.7 million member, 85-year old credit union that is the nation’s second largest.
I became a cooperative idealist in the 1970s, first as a food co-op organizer until I was introduced to credit unions when I was charged with organizing one for the farmworker nonprofit I worked for.. . . I was enthralled with credit unions as democratic, egalitarian institutions, created to empower individuals excluded from the for-profit banking system.
I was fortunate enough to be hired by the National Federation of Community Development Credit Unions (rebranded as Inclusiv after I left), becoming CEO in 1983 and serving for nearly 30 years. . .
Over the years , , , I went to my share of annual meetings of our member credit unions, usually not very well attended (except if there were refreshments). It was great to meet members, and it was my job, but truth be told, it was not the liveliest way to spend an evening or weekend afternoon.
My Life’s Work
The 90-minutes I spent watching SECU’s annual meeting on YouTube reminded me why credit unions became my life work. One after another, SECU members debated recent changes instituted by the board, most controversially, the introduction of risk-based pricing—the nearly universal practice of U.S. credit unions which charge members different rates according to the credit score-informed tier they fell into.
Not SECU. For nearly its entire history, it offered the same price for the same loan product for all members. It was a simple, time-honored, financially successful practice, that fueled SECU’s steady growth. . .
But for some members and the credit union’s recent leadership, that was not good enough. Several speakers argued that the credit union’s savings rates were not competitive; one spoke of his children leaving SECU for better rates at a bank. How would the credit union grow and—well, compete—if it didn’t raise savings rates to retain members? . . .
Speaker after speaker—members of 30 years, 40 years, 50 years—spoke passionately about what SECU had meant to them and others, a place to get the best possible rate even when they were starting out in life, were struggling financially, or had marred credit.
True, risk-based pricing was everywhere in credit unions today—but for those with long memories, it had not always been so. They fully understood that better returns on savings were available elsewhere. But they were staying.
One-tier pricing is radically egalitarian—providing those with fewer financial means the same rates enjoyed by those with immaculate credit scores and ample resources. Except it is hardly radical, and hardly new.
One speaker denounced the strategy as “socialist”: This was North Carolina, he argued, not Russia, China, or Cuba. But I heard no “woke” or progressive rhetoric, only the testimony of people who cared deeply about their fellow North Carolinians and wanted to help them better their lives. “People helping people”—not simply a brand slogan, but an expression of human solidarity.
I spent my career working with small, community-based institutions. As the credit union “movement” became the credit union “industry,” with assets and membership disproportionately concentrated in a minority of institutions, I reluctantly concluded that my ideals and passion were nothing more than a relic.
Today, I thank the members of SECU for the inspiration and hope they gave me.
© Clifford N. Rosenthal
Yesterday the North Carolina Credit Union Commission met to discuss a member’s complaint that SECU’s recent bylaw change proscribed members’ rights. I noted three outcomes.
The Commission’s role in this oversight has not ended. The bylaw issue will continue on its agenda.
Today at 1:00pm SECU’s Annual meeting will be held. A link for the virtual broadcast will be published on its website. The voting outcome for directors will be announced.
This Annual Meeting will be a seminal event no matter the result. For once members have been brought into the process, it will be hard to shut them out in the future.
Once to every man and nation
Comes the moment to decide,
In the strife of truth with falsehood,
For the good or evil side;
Some great cause, God’s new Messiah,
Offering each the bloom or blight,
And the choice goes by forever
Twixt that darkness and that light.
Then to side with truth is noble,
When we share her wretched crust,
Ere her cause bring fame and profit,
And ’tis prosperous to be just;
Then it is the brave man chooses
While the coward stands aside,
Till the multitude make virtue
Of the faith they had denied. . .
Once empowered, the members’ voice is hard to still. In a democracy people will act when they see their self interest in jeopardy.
Member rights have not been a priority across the credit union system. Federal and state regulators have been absent and at times, negligent, when overseeing this aspect of their responsibility.
Democratic governance is a vital factor in the credit union model. Legal equality in governance was deemed to be a precursor for economic equality.
Democratic voting is more than an organizational design. The one-person-one-vote is a core value. For decades credit unions have struggled to tie their cooperative moral laces.
Today as recited in James Russell Lowell’s poem above, may be a reawakening of that effort for SECU and the cooperative system.
The credit union democratic cooperative model is simple. The legal equality of each member’s voting role is intended to facilitate economic equality.
The intent of the one-person-one-vote in governance is that when accessing common resources, each member is on the same footing. If one person is better or worse off than another, that should not affect their ability to access credit.
In almost all other for-profit organizations, control is exercised by who holds the most shares, or through classes with special voting rights.
A credit unions’s bylaws is the primary document implementing member rights. NCUA’s bylaw description runs 45 pages. “The FCU Bylaws address a broad range of matters concerning a credit union’s organization and governance, the relationship of the credit union to its members, and the procedures and rules a credit union follows.”
But who ensures that the bylaws are followed, both in letter and spirit? Here is NCUA’s description of their role:
“The NCUA has discretion to take administrative actions when a credit union is not in compliance with its bylaws. If a potential violation is identified, the NCUA will carefully consider all of the facts and circumstances in deciding whether to take enforcement action. The NCUA will not generally take action against minor or technical violations, but emphasizes that it retains discretion to enforce the FCU Bylaws in appropriate cases, such as safety and soundness concerns or threats to fundamental, material credit union member rights.” (emphasis added)
What happens when the bylaw procedures for nomination and election are administered so as to form without substance? Or interpreted to enable incumbent directors to protect their positions and prerogatives?
Today, October 9, an actual situation will be discussed. The North Carolina Credit Union Commission will hold a special public meeting at 1:00 p.m. (dial in # (877)-402-9753, access code – 6601929.)
The primary purpose as published in the Notice:
“Discussion about concerns raised by a member of the public regarding recently approved changes to the State Employees’ Credit Union by-laws.”
This is how Jim Blaine sees the issue to be discussed in a recent post.
This will be another way the Annual Meeting and election of directors at SECU could have an impact far beyond this credit union’s circumstances.
The Annual meeting occurs tomorrow October 10th and will be lived stream.
Yesterday Politico published an article on credit unions written by a Brookings-based economist.
The title and subhead give his message:
Credit Unions are Making Money off People Living Paycheck to Paycheck
The subhead: There’s a new predator making money off overdraft fees: Credit unions.
The article was prompted by a new report required of all California state chartered banks and credit unions beginning with 2022 data. The first report is 17 pages and lists in data tables the total overdraft and NSF fees collected by each firm the year. The final column shows these dollar amounts as a percentage of net income and total revenue.
The author’s academic and /Congressional staff credentials suggest an objective study of an important topic: the sources and importance of non interest income.
However as I read the article Mark Twain’s observation came to mind: “Figures don’t lie, but liers do figure.” But this shortcoming should not cause readers to overlook lessons from even a biased report.
In addition to the headline, the author’s target shows early on: And the first report of that data reveals that many California credit unions are taking millions from their most vulnerable customers and spending it on perks and bonuses for executives that resemble those of big banks more than nonprofits.
He uses one ratio from the study, total fees as a percentage of net income and then prepares a brief table listing the ratios for 12 credit unions (out of 114) with highest combined $ fees.
However this single ratio can fluctuate dramatically depending on net income, independent of the numerator being studied-combined OD/NSF fees.
To suggest a credit union like FrontWave is abusing members because its ratio is 140% ignores the study’s second ratio which is 12% of total income. This ranking would give a very different listing.
FrontWave’s net income in 2022 declined by 33% from $8.4 to $5.6 million (.44 ROA) thus making the fee/net income ratio appear much higher than a “normal ROA” might present.
Whereas Dow Great Western’s ratio was a negative -200% and only 1.32% of total income. Was the credit union giving back more fees than they collected? No, the credit union reported a negative net income. Perhaps it should charge more fees?
But the author has made up his mind, and now wants to condemn a practice without examining other relevant details, such as the actual fee charged per transaction. He downplays the other ratio of fees as a percentage of total revenue, which would show each firm’s dependence on this one area of income. These ratios range from 0% to 15%.
He makes no attempt to understand the data by calculating mean or the average fee-to-income ratio. His conclusions were formed before he knows what the data might mean:
Let’s be clear: Overdraft fees can be predatory. Every overdraft by definition turns money from someone who has run out of it into nearly pure profit for the bank or credit union that charged it because they get paid back immediately when the next deposit hits. Eighty percent of overdraft fees come from just 9 percent of account holders, highlighting that this product is targeted at people living paycheck to paycheck who run out of money from time to time.
Even given his limited analysis, the situation is dire:
The full picture among California’s 114 state-chartered credit unions is alarming. And not just in California. One suspects similar trends across the country. Several of Michigan’s largest credit unions have been sued for abusive overdraft practices and research from the Consumer Financial Protection Bureau shows credit unions averaging similar overdraft fees as banks.
Near the end the author’s political bias comes out as he talks about democratic congressional members’ rhetoric against junk fees, and then this sentence: Todd Harper, chair of the National Credit Union Administration (NCUA) has spoken out against abusive overdraft practices, but the NCUA Board has a Trump-appointed, Republican majority that is continuing to deregulate.
All three board members are Trump-appointed. I’m not aware of any reg, rule or guidance letter that Harper has issued on this topic or that the other two board members opposed. The singling out of Harper’s alleged views (no links) raises the question whether this is just a comrade in arms fronting for someone.
The author is a sceptic of credit union business practices:
California’s data shows that some credit unions are making a lot of money from overdraft fees. California’s largest state-chartered credit union, Golden 1, took $24 million in overdraft from their members, while spending $6 million a year for naming rights for an NBA stadium in Sacramento. North Island Credit Union bought naming rights for a famed music venue in Chula Vista and created an exclusive entrance, ticket discounts and other perks for some of its members while taking over $10 million last year in overdraft and non-sufficient funds charges from its members.
Do these business practices sound like those of nonprofits designed to provide basic banking services to people who share what the law calls a “common bond,” such as a workplace or other connection required for membership? Or are they what would expect from for-profit banks?
The author asserts this not a single state issue: California’s data is a wake-up call for the nation as a whole.
Even though he critiques mutiple credit union activities through his very limited NSF/OD lens, the article is a wake up call for those who believe credit unions are not banks in sheep’s clothing.
The article has all the indicators of a planned “hit piece” on credit unions. But to try to kill the messenger or discount all the data is to miss the point.
Even when a public critic may be wrong, the better approach is to engage on the issue with facts and logic that show a grasp of the issue. More rhetoric just makes the issue burn hotter but with no more light.
The need for fee transparency at the individual and macro levels is valid. Credit unions, consumers and analysts/regulators can all better understand the role these fees have in a firm’s business model.
Comparisons between credit unions can be valuable, if all the data is known. How do some have very low fees and others relatively higher?
Members can more easily learn as they seek information on fees as they do now about loan and savings rates.
The author believes the only solution to his alarming “problem” is more regulation.
But what kind of regulation would be relevant and consistent with one’s views on government’s role for coops and in markets? Should government regulate the fees somehow, mandate more disclosures, or control business practices as he hints by limiting fees to a percentage of net income.
More regulation will not stop credit unions tempted to put institutional priorities ahead of member-owner interests.
Regulators should ensure members have the tools to hold their repesentatives to account-with the information and the ability to openly raise these topics in the traditional annual meeting and director election format.
What is missing is not regulation but the ability of members to play an effective governance role as owners in their credit union. Enabling members to be more aware and active is critical to any credit union’s long term success.
No regulation, no matter how well intended, can replace members exercising their rights as owners. That’s how markets are supposed to work.