What would you do if you discovered that the administration and teachers in your public school system were not qualified or not appropriately trained to teach your kids the skills they will need in the 21st Century - endangering the future of your children?
Or that the doctors in your local hospital were not keeping up with advances in medical technology, or the break-throughs in bio-pharma therapies - resulting in the untimely death of many
patients? Or that your local government was still using a 1970's "legacy", Tandy-TRS 80 computer, with a dial-up modem to compute your water & sewer rates and to create your tax bills - creating uncertainty as to the reliability and fairness of the assessments? Or that the rulings of your local district court seemed to favor "personal peeve & politics" over the rule of law - resulting in severe losses of public support & credibility, and with no clear, fair source available for appeal & redress?
And most importantly, what if there were no credible, internal control standards, nor effective external, "market-based" benchmarks in-place to monitor, measure, and report on the performance of these important services...
What would you do?
As you've noted from the title of this post, this isnot a hypothetical exercise. We want to take a specific look at the NCUA, as to whether or not the Agency is "at the crossroads" in terms of a need for dramatic, critical change to assure its future - Why do this now?
1. Credit unions need a strong, independent federal regulator & insurer - and should fight to create one.
2. NCUA now has the strongest and most capable Board it has had in the last decade - operating with an open mind.
3. NCUA will not be permitted to continue its backward-looking, "shoot-from-the-hip" regulatory missteps - by either credit unions, Congress, nor the real world marketplace.
4. This won't wait. NCUA has a very short "shelf-life" as it now operates - hopefully not already beyond its "sell by" date.
So, before we look at "What would you do?", it seems reasonable to establish "WHY" something needs to be done. Too often it is easy to assume that grousing about the NCUA is simply whining or anti-regulatory rhetoric. Can it be clearly demonstrated that there is a serious deficit in the existing training, expertise, systems and senior leadership at NCUA required to help take credit unions into the future?
I think so and the best place to start is with the recent risk-based capital (RBC) rule - the incapability of NCUA on display before the entire world...
But before we start , do you agree with the "Four Reasons"?