Monday, October 17, 2011

330 LUAs Went Unpublished in 2010

There is an interesting table in The 2010 Annual Report see below) that shows that NCUA only published 3 letters of understanding and agreement, while 330 letters of understanding and agreement went unpublished.

NCUA issued 28 cease and desist orders. However, only one cease and desist order was published in 2010.

The Federal Credit Union Act requires that the NCUA Board publish and make available to the public “any written agreement or other written statement for which a violation may be enforced by the Board unless the Board, in its discretion, determines that publication would be contrary to public interest.”

It appears that NCUA is abusing its regulatory discretion to suppress the publication of information about enforcement orders against credit unions.

I have a hard time believing that in 99 percent of these supervisory actions that it was contrary to the public interest to publish these actions.


  1. The condition of credit unions, overall, hasn't changed.

    The extensive new use of Documents of Resolution, Letters of Understanding and Enforcement Orders are just the bullet holes in the wall, as NCUA examiners shoot up institutions with an overly aggressive use of guns and clubs and "Enhanced interrogation techniques."

    The Agency can't follow-up and close issues that were not fundamentally wrong to start with; publishing needless and wrongly issued supervisory orders IS in conflict with the public interest.

    The same is true for FDIC's post-crisis actions and a majority of small banks. The evidence you cite exists only because there has been an excessive use of force.

  2. Who does the NCUA report to? You also need to list bank lobbyists, attorneys, etc. on your blog, who are fighting credit unions so that those who would like to report credit union malfeasance, can.

  3. You asked "who does NCUA report to?"

    NCUA is an independent agency, just like the Federal Reserve or the FDIC. NCUA does not receive any appropriations from Congress -- except for the Community Development Revolving Loan Fund and the Central Liquidity Facility.

    However, NCUA is subject to Congressional oversight and the NCUA Board is appointed by the President and must be confirmed by the Senate.

  4. Since the NCUA is not enforcing its own rules against credit unions, what are the alternatives, because Congressional oversight does not instill confidence?

  5. I'm not sure there are alternatives. My congressman was a complete waste of time, NCUA continues to pretend as though they know nothing about mortgage fraud despite the evidence, everyone else can see it. In our case it left us homeless, a veteran and family. I'm taking my case to Tim Geithner, the President and First Lady. Sounds silly but what choice is anyone left with? Maybe if they get enough complaints regarding NCUA's inability and failure to do their jobs...We'll see.



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