CU Committee on Declaration of Grievances Told Congress of NCUA’s Misdeeds

Submitted by gwyche on March 14, 2011

On March 4th a newly emerged ad hoc group of officials from credit unions located in multiple states calling itself the Credit Union Committee on Declaration of Grievances sent a letter to certain federal lawmakers airing their concerns about…“the sufficiency of the National Credit Union Administration’s actions in regulating the industry and the many federal agencies that are undermining our member citizens.” Sent to federal lawmakers on the House Financial Services Committee and the Senate Banking, Housing and Urban Affairs Committee the letter was signed by thirty-two credit union CEOs, senior executives, and elected volunteers. This correspondent was advised by one of the signers that there would have been more names had many not feared retribution for publicly expressing their concern about NCUA’s regulatory overkill. The signer also said, “Our position is this is our credit union members’ money that is being bled off by this regulatory treatment and we have a fiduciary obligation to speak up for them.” Reportedly, the CU Committee on Declaration of Grievances also delivered copies of the grievance letter to the CEOs and elected officials at CUNA and NAFCU.

The list of seven grievances included:
1. The members of federally-insured credit unions, 91 million taxpayers who are your constituents, are being drained by the recent actions of the National Credit Union Administration (NCUA) and the plethora of regulations passed by federal agencies with the delegated authority Congress has given to them (unregulated regulators). Recent actions of NCUA imposed on credit unions along with other unregulated regulators are harming each of the credit union depositors and borrowers in this country.
2. NCUA’s clear failure to provide adequate supervision of the ‘wholesale’ corporate credit unions has placed a considerable long-term financial burden on the nation’s 7,400 credit unions, which hold $748 billion in deposits of 91 million member/taxpayers. In 2010, NCUA began charging credit unions for these losses with assessments equaling approximately 27 percent of the credit unions’ net income. NCUA has told the credit unions it insures to expect the aggregate assessments in 2011 to range from $1.5 to $1.9 billion. NCUA expects similar charges to the nation’s credit unions and their member/taxpayers to continue through 2021 – another ten years. Though these charges are applied directly to credit unions and not the American taxpayers as a whole, credit unions are cooperatives owned by our members and these charges will be borne by our member/taxpayers through reduced ownership capital, reduced savings rates, increased loan rates, increased fees, and decreased service quality.
3. While charging the nation’s credit unions and their 91 million members as much as $1.9 billion in 2011, NCUA has increased its own 2011 budget by more than $24 million, passing on the expenses to each credit union during a time of recession and sacrifice for all Americans. In reality it is not the credit unions funding this 12 percent budget increase, it is the individual member/taxpayers who use credit unions to finance their daily lives. This budgetary increase by NCUA follows a similar 13 percent, $23 million budget increase in 2010.
4. The NCUA has budgeted for 78 new staff in 2011 while federally insured credit unions are downsizing and reducing expenses. This equates to a seven percent staffing increase. In addition, the NCUA Board has approved pay increases of up to eight percent for 2011 when the credit unions’ member/taxpayers are experiencing little or no raises and true unemployment remains near 10 percent. Congress should require NCUA to revise its 2011 budget to 2008 levels.
5. There appears to be little or no oversight of the NCUA or any separation of powers to give balance to their actions. NCUA has closed door meetings on many occasions that are not open to the public or the scrutiny of the press. This lack of oversight has permitted NCUA to repeat past mistakes at the expense of the credit unions it regulates.
6. The Durbin Interchange Amendment as implemented by the agency will further drain monies of credit union member/taxpayers in the name of consumer protection. Implementation may be as soon as July 2011. The United States has the best financial payment system in the world that is being undermined by this new law. The financial services industry will lose an estimated $3.6 to $9.2 billion per year. To continue to provide efficient electronic debit and credit cards these costs will be passed on to the member/taxpayer through increased cost of services. The Durbin Amendment should be repealed.
7. Excessive regulations that have unintended consequences are smothering member/taxpayers with redundant notices on privacy, consumer rights notices and loan notice compliance. The current stable of Federal regulations such as the FACT Act, the SAFE Act, BSA, OFAC (to name just a few) is an incubator for costly, redundant, and often questionable notification and reporting requirements. The costs of complying with the myriad federal, state and locals laws, rules and regulations are passed on to the consumer by financial institutions through increased fees, reduced interest, and increased borrowing rates. Congress and the various regulatory agencies should perform a full review of all current laws and regulations with the intent of amending or repealing those which are barriers to the free enterprise system on which this country was established and prospered. It is incumbent upon governments comprised of the people to make certain that the laws and regulations enacted and enforced upon the public are absolutely necessary and do not result in unintended harm in excess of intended good.

The CU Committee on Declaration of Grievances expanded on several of these topics in the remaining three pages of its letter. This correspondent had not learned whether or not the CU Committee on Declaration of Grievances heard back from any of the lawmakers or from CUNA and NAFCU. It would also appear that the credit union industry trade press had not yet gotten wind of this newsworthy event. Additionally, it was unclear as to whether the lawmaker letter was to be a one-shot effort or whether the group planned to engage in a longer-term independent direct advocacy effort. Regardless, the CU Committee on Declaration of Grievances was yet one more illustration of the growing discontent within the credit union industry about the traditionally centrally-controlled and spin-doctored “speak with one voice” advocacy by the trade associations. This correspondent has great sympathy with the CU Committee on Declaration of Grievances’ concerns http://www.cutimes.com/2011/03/02/ncuas-rulemaking-pendulum-has-swung-to....

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