Wednesday, February 24, 2016
FOM Policies, Just Not Reg Burden, Threaten Small CU Survival
In an opinion piece in The Hill, former Representative Jim Nussle, president and CEO of the Credit Union National Association (CUNA), wrote that regulatory burden is threatening the survival of small credit unions.
It is true that small credit unions, as well as small community banks, lack the economies of scale to spread out the cost of complying with all the new regulations and may cause these institutions not to be viable.
But regulatory burden is only part of the story.
Changes in field of membership (FOM) policies and practices that have fueled expansive community charters and permit anyone to join a credit union through an association have allowed large credit unions to poach smaller credit union members.
But this has not always been the case. Historically smaller credit unions received overlap protection with regard to their fields of membership. Overlap protection was designed to protect smaller credit unions operating in the same market as larger credit unions.
However, overlap protection has largely disappeared.
This is leading to increase competition between smaller and larger credit unions hastening the demise of small credit unions.
As Paul Harvey used to say, "And now you know the rest of the story."
It is true that small credit unions, as well as small community banks, lack the economies of scale to spread out the cost of complying with all the new regulations and may cause these institutions not to be viable.
But regulatory burden is only part of the story.
Changes in field of membership (FOM) policies and practices that have fueled expansive community charters and permit anyone to join a credit union through an association have allowed large credit unions to poach smaller credit union members.
But this has not always been the case. Historically smaller credit unions received overlap protection with regard to their fields of membership. Overlap protection was designed to protect smaller credit unions operating in the same market as larger credit unions.
However, overlap protection has largely disappeared.
This is leading to increase competition between smaller and larger credit unions hastening the demise of small credit unions.
As Paul Harvey used to say, "And now you know the rest of the story."
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That's been the case for over 20 years and went into overdrive with HR1151 in 1998.
ReplyDeleteWhat is noteworthy about your post is that you publicly point out what CUNA and Nafcu will never admit. The entire "movement" works against itself.
The most disingenuous industry on the map.
Dr. Leggett.
ReplyDeleteYou sell yourself short.
Sometimes you aren't just the rest of the story, you're the only way we hear the story.
Examples:
My board and I discussed that the only good info we have gotten on medallion loan crisis is from your blog. And the numbers are scary. What does that total problem look like for potential losses and assessments and what does it say about NCUA 's supervisory skill that they let those credit unions concentrate over 70% of ASSETS in medallion loans?
Also, if it wasn't for you, we would never know that NCUA tried to sneak to fdic calculation for insurance fund and that they want to raise the amount we pay in!
Dr. Leggett, has our back!
CUNA and Nafcu? Have their own backs.