Wednesday, November 23, 2016

Field Of Membership: An NCUA Priority? ....Why?

NCUA to propose new rule...?
Folks around the Country have until December 9, 2016 to comment on NCUA's proposed rule expanding the field of membership limitations for federally-chartered credit unions.  

The rule does not apply to state-chartered credit unions, which draw their FOM authority from their home state. Here's the link to the proposed FOM rule - BTW let's hope the NCUA is not also proposing to start regulating bathroom fans with more than one speed! (check out the link to see my concern!)
Britches getting a wee large?

Know of no objections to the proposed changes to the FOM limitations for federally-chartered credit unions (other than by the American "Braying" Association - 'da ABA!), did find the following statistics of interest from the 6/30/2016 NCUA Call Report data (select June/2016... it's on page 17 "Misc. Info" - here's the link):

# of Federally-Chartered CUs:                    3,679
# of Current FCU Members:                 55,433,285
# of Potential FCU Members:             978,012,080
         [under current rule]                            [978 million!]
% of Current Members to Potential             5.67%
                     FCU Members:

Which suggests 3 questions...


1) Doesn't that mean that FCUs aren't serving 94.33% of their existing, eligible members?

2)  Is this really the most important issue confronting the NCUA - ahead of an equitable appeals process, supplemental capital, fraud losses, IT/analytical deficiencies, advisory panels for unfiltered input...  a real strategic plan for the challenges of the future?


3) 978 million potential members? Aren't there only 325 million citizens in the entire Country?

... outstanding in our "field"?



Anonymous said...

Actually, it suggests more than 3 question.
How can credit unions have more potential members than US citizens?
If multiple credit unions are counting the same potential member multiple times than are they ALSO counting the same member multiple times if that member is a member at more than one CU?
Is it possible NCUA is relying on Hampel for analysis?
Where do the "extra" potential citizens live?
If credit unions have 978million potential members, and enjoy 55M actual members (a 18% of all US citizens), how come we only have 7% of US deposits?
why are we paying for marketing people when we have such a crappy market share for crying out loud?
Why are we paying CUNA dues?
If the veracity of our industry analysis is so weak, what does that say about us?
Maybe most of us have stopped listening to NCUA, CUNA and nafcu.

Anonymous said...


Anonymous said...

I am not a fan of hot air.

Anonymous said...

Perhaps more importantly is your question.
"Why is this a federal regulator priority"?

They're a safety and soundness regulator, not a trade association.
Oh, maybe because the trade associations have been so ineffective.
But wait, then why pay dues?

Further, if the agency has admitted shortcomings in cyber and other issues, why is it devoting time to changing the charter. That's congress job.

Lots of good questions, but no good answers.
In fact, no answers!