From The Field: A Slam Dunk Choice...

Play Ball!

"We have retained PeatMaravich to perform the audit."

Seeing Things Differently...

Eye see!

People who have all the right answers in life, who lack the gene for uncertainty really worry me - particularly when they are employed in an official capacity. 

Experience has shown most of us that - like it or not -"there is usually more than one way to skin a cat".  Differences in opinion should be respected, even when the reason one would attempt to skin a cat is not entirely clear ??!

A bit strange at times...

Decidedly differing views are a fact of life; something which should be expected and accepted. Admittedly that can be difficult at times, as some folks' thinking can be a little strange. That's why we have prisons, mental hospitals, and economic conferences.

Here's the best example I've ever seen to illustrate how truly different some folks see the world:

I have sexdaily.

Telling A Larry... Part II

"The truth, the whole truth,
and nothing but the truth..."

Let's turn once again to the testimony before Congress this week of Mr. Larry Fazio, a very important, senior muckedty-muck over at the NCUA.  

Let's do a little quiz - OK?  Here are 5 direct quotes which Mr. Fazio delivered earnestly, forthrightly, and with a completely straight face. From your actual personal experience with the NCUA, please rate each statement below in terms of truthfulness. Got it?

1)  "NCUA is ever mindful of the impact of regulations on credit unions, especially smaller ones."  a) True, b) False, c) THATS A LARRY!

NCUA's long-standing rolling, regulatory review process helps ensure NCUA's regulations:

2) "Impose only the minimum required burdens on credit unions, their members, and the public."  a) True, b) False, c) THAT'S A LARRY!

3)  "Are appropriate for the size of the credit unions regulated by NCUA." a) True, b) False, c) THAT'S A LARRY!

4)  "Are issued only after full public participation in the rule making process." a) True, b) False, c) THAT'S A LARRY!

And, everyone's #1 favorite...

National NCUA Standards.....Flights of Fantasy.

Among citizens, there appears to be a growing belief that a centralized, prescriptive government is no longer efficient nor effective.  The strongest critics are harsher, and claim "the system is broken".

Personally, not ready just yet to "take up tea", to "occupy" anything, or to "move up into the mountains with an AK-47".  Think we have a very resilient "system" that has proved adaptable to change over the centuries - but there clearly is a need for reform.

Despots and...?

It's counter-intuitive perhaps, but the larger and more complex a project, an idea, a government, a society - or a credit union - becomes; the greater the necessity for decentralized management, control, and decision making.  Better and fairer decisions are made; responses are both quicker and more timely; and the risks of mistakes, corruption, and failure are significantly reduced.  Despots and entrenched bureaucrats of course do not agree with this view. 

NCUA's past humiliation with the largest corporate credit unions is an excellent example.  NCUA centralized regulation, monitoring, and control of corporates in Alexandria.  NCUA had full control and responsibility with direct "C-suite" NCUA leadership involvement, and with NCUA anointed "specialists" in-house, on-site, endorsing and second-guessing corporate management decisions and corporate Board governance.

With the corporates, NCUA's leadership failed.  They failed dramatically; they failed catastrophically; they failed financially; they failed "regulatorily"; they failed publicly; they failed abjectly; they failed.... thoroughly.

Same old, same old...

Yet NCUA seems to believe, as Larry Fazio's testimony before Congress yesterday indicated, that they can make their very public, very costly failures - including the recent, rank, "dead skunk" RBC proposal -  "go away". How?   By increasing centralized regulation, control, and monitoring over the surviving elements of the credit union movement - and now even "third party vendors" where NCUA clearly has less than no expertise.

Natural person CUs are being "bullied and

I am smiling and I am listening...

thrashed" to standardize, to centralize, and to adopt NCUA's national guidance - the very same "failed plan" which NCUA used to embarrass itself - and all credit unions - with its corporate self-destruction.  

NCUA seems to believe that if credit unions can be made to repent for NCUA's sins, all will be forgotten and forgiven.  NCUA should think again....

Credit unions might just take off if we could get some failed folks and failed ideas out of the way....  

Telling A Larry....

"I Wanna Testify...!"
The Parliaments (1967)
(...almost as good as
The Castaways!)

Really hate to be interrupted while reading the 450-page RBC rule draft (By the way, how you doing with your reading? You are reading it, aren't you?); but Larry Fazio from the NCUA was up before Congress today telling the truth - at least as NCUA sees it, which is often through a very narrow lens, backed up by some tightly closed minds.

But when NCUA testifies before Congress about how it is working hard to relieve the regulatory burden for credit unions; well, what can one say... which can be printed on a civil blog, in a polite manner?  Here's a link to the text: Larry Fazio Before Congress - 2/10/2015.

Mr. Larry Fazio
Burial complex?

NCUA has developed a strong reputation for having "a burial complex" in its proclamations, which simply means that you must start at the end or dig through the footnotes to find out what the Agency is really up to... they save the worst for last!

"Male cow stuff..."

So, true to form, after you have waded through a lot of "male cow stuff" in the testimony; on the next to last page (pg. 14) down at the bottom and in footnote #29, Mr. Fazio finally reveals what NCUA really wants (wags call this..."Telling a larry"!):

Dress Code Violation....Pants On Fire ???.

IS NCUA SPORTING A SET OF
 LEGAL OPINION "HOT PANTS" ??

Something Doesn't Add Up....

"A little going away present..."

The buzz claims that the recent  CUTimes (2/6/2015) 

"DutyStation/Travelgate" exposé was an "inside job" - an attempted set up by "the usual suspects" hoping to discredit the "R-wing" of the NCUA Board - particularly past Chair Mike Fryzel.

Yet another Soap Opera
on Duke Street...?

After reading the blurb and sifting through "the dirt", think most folks would say "much ado about nothing", pretty petty, and doesn't the Agency have a few other issues of more import?  Like rebuilding its credibility and  reestablishing public confidence?

Lastly, much like the initial risk-weights in NCUA's RBC fiasco, somehow "the numbers just don't add up" - at least not to scandal.  Unless you look at them this way...

Rating The Agency: RBC A World-Class Farce - But Nobody's Laughing...

"IGNORANCE IS BLISS, REALITY IS NOT."

NEWS FLASH: First Public Comment Filed On RBC Rule!

WELL SAID!!!
NEED WE SAY MORE???

Further Adventures In Wonderland: The Cheshire Cat... Out On A Limb?....

ACCOMPLISHED LAWYERS 

CAN 

ALWAYS

READ