Thursday, July 30, 2009
Shouldn't Credit Unions Be Subject to Branch Deposit Reporting?
A reader recently pointed out a competitive advantage that credit unions have over banks that rarely gets discussed -- credit unions are exempt from the disclosure of midyear branch deposit data which banks and thrifts file each year.
As Kenneth Thomas in a July 14, 2006 American Banker Viewpoint article wrote: "This was an insignificant issue when credit unions were employer-based and had no retail branches. Today, however, this disclosure exemption translates into a valuable advantage.
Credit unions know exactly how much every bank branch and thrift office has on deposit every June 30 from the FDIC's Summary of Deposits. Credit unions can use this market information to make better decisions on branch location and other matters."
Moreover, this deposit data is used for anti-trust calculations to determine the impact of mergers on local markets and other regulatory decisions. By excluding credit union's from such disclosures, this could result in sub-optimal regulatory decisions.
As a matter of good public policy, credit unions should be required to disclose their deposits by branch locations, just like all other depository institutions.
As Kenneth Thomas in a July 14, 2006 American Banker Viewpoint article wrote: "This was an insignificant issue when credit unions were employer-based and had no retail branches. Today, however, this disclosure exemption translates into a valuable advantage.
Credit unions know exactly how much every bank branch and thrift office has on deposit every June 30 from the FDIC's Summary of Deposits. Credit unions can use this market information to make better decisions on branch location and other matters."
Moreover, this deposit data is used for anti-trust calculations to determine the impact of mergers on local markets and other regulatory decisions. By excluding credit union's from such disclosures, this could result in sub-optimal regulatory decisions.
As a matter of good public policy, credit unions should be required to disclose their deposits by branch locations, just like all other depository institutions.
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