Wednesday, September 07, 2016

Brief Intermezzo ... A Pause For The Cause!

'Can't we talk about
something else?"

We're getting ready to try "to argue out" a proposal which will describe and define how the NCUA can, in the future, become the premier financial regulator in the U.S.

Before we proceed to "the dialogue", let's check on a couple of questions to make sure we are all in agreement on some "basics".

1) Is NCUA currently the premier financial regulator in the Country? ☐Yes  ☐ No

2) Should NCUA strive to be the premier financial regulator in the Country? ☐Yes  ☐No

3) Is it possible for the NCUA to become the premier financial regulator in the Country? ☐Yes  ☐No

If you answered "No" to any of the questions:

Why not?
(Are we happy with a "second tier" regulator?)

"Brilliant idea!"
The second series of questions are "Who will bell the cat?'' questions. 

If that doesn't ring a bell (so to speak!) with you, the fable goes that a group of church mice had grown weary of seeing their numbers decimated by the ferocious cat which prowled the church grounds.  At a meeting called to seek a solution, the brave, angry mice discussed various action plans and decided that the best course was to have a volunteer mouse sneak up on the cat and tie a bell around its neck; then in the future, the sound of the bell would always give early warning to the mice of the presence of the lurking cat. Great plan! ....which all the mice vigorously supported!

"It'll be a piece of cake..."

The only problem was no mouse was willing to volunteer for the duty of installing the bell on the cat!

So, which of our brave credit union advocates will take up the task of leading our soon to be created action plan to help make NCUA the premier financial regulator in the Country?
Who will bell the Cat?

             1) CUNA?         ☐Yes  ☐No

             2) NAFCU?       ☐Yes  ☐No

             3) NASCUS?     ☐Yes  ☐No

If you answered "No" to any of the choices:

Why not?
(Then why waste our time on the Plan?) 


Anonymous said...

You already answered the most important question. None of the above will install the bell. They may moan and groan but that is all you will get. They don't know where to start, have any ideas and are to busy holding conferences where they kiss the asses of those in Congress who are not going to do anything for them but introduce bills that either do little or get no traction.

Michael Waylett said...

As a long-time NCUA basher & former NCUA chattel/employee myself, I must say my first exam with NCUA since moving to Mississippi was refreshingly methodical, predictable, fair, level-headed, and entirely devoid of the desultory peeing contest of which I had become accustomed with NCUA examiners in NC. Perhaps there is hope yet for the ole NCUA! IMO, the primary difference between NC and MS,-that produces such a vast incongruity between examiner conduct and behavior in the states-, is that the examiners in MS are being led by a level-headed and fair SE, that contrary to other states, does not believe NCUA's job is to remain inflexible and rule with an iron-fist. They listen and discuss issues in MS and actually hold you to actual NCUA rules and regulations, rather than holding you hostage to their views on best practices. Just think had you moved to MS 20 years' ago, you could have saved yourself from all that balding and greying of your hair.
Sidebar: when's the retirement shindig and can I Facetime in?!

Jim Blaine said...


Certainly the NCUA - like any other large, accountable business - must have well-established, internal monitoring and quality control procedures in place to identify and eliminate the type of supervisory mismanagement you have pointed out - right?

And assuredly, the NCUA has in place a well-defined and functioning appeals process for credit unions to raise concerns about supervisory mismanagement if it occurs - right?

If not, then wouldn't those two issues be very worthy of action by CUs, the NCUA Board, and our trade associations with a goal of making the NCUA the premier financial regulator in the Country?

What am I missing?

Michael Waylett said...

Aside from hair, you're not missing anything. I agree. Ideally, we can get to this place of monitoring and quality control in NCUA, and it sure seems a realistic goal to me. Like any other problem though, NCUA won't work towards solutions until they acknowledge there's a problem. Frankly, I don't think NCUA is in the business of acknowledging their deficiencies and collaboratively trying to improve them. There business is in fixing US, not them.
Also when CUs do raise issues about supervisory mismanagement, it's too quickly dismissed as a CU just being disgruntled about a DOR or CAMEL rating and the nature of the complaint is never fully investigated. NCUA's QC also naturally investigates from a vantage point of supporting their examiners, rather than getting to the bottom of potential mismanagement. QC must be an unbiased 3rd party for it ever to have any meaningful impact.

Jim Blaine said...

How do we find an unbiased 3rd party that everyone - CUs, examiners, and the NCUA Board - would accept and trust?

Having that in place would certainly be a big step toward setting NCUA apart, as a standard setter heading toward being the premier financial regulator in the Country.

Why wouldn't the NCUA Board want to run "the model" regulatory agency - who does that hurt?