By Tom Pinnow
It is great to see our industry finally seeking real regulatory relief in the form of exemptions for credit unions from all of the onerous regulations imposed on us the past six years. I applaud these efforts, but can’t help but wonder why it took so long. Credit unions below $50-million in assets have been especially besieged by these regulations and our numbers have dwindled as a result.
It is frustrating to note that the examples in an article in CUToday.info that compare a $250-million institution to a $10-billion institution, and a $200-million institution to a $1-billion institution. What about institutions below $50-mllion? Let me repeat: What about credit unions below $50 million?
Credit unions under $50-million represent 65% of all credit unions, yet we are left out of this discussion. This concerns me. What can we do to change the culture so that future discussions cite and actually deal with credit unions under $50 million?
Another case in point is an article in CUToday.info on April 13, 2015 titled, “House Passes 5 Regulatory Relief Bills.” Two of the items listed as “regulatory relief” aren’t even regulatory relief for credit unions: H.R.1480 regarding the Safe Act applies to regulators; H.R. 1265 makes information public. H.R.299 corrects a drafting oversight regarding a small number of privately insured credit unions. H.R.1259 has the “potential” to provide relief, but we have to apply to the CFPB to have a “rural” county re-designated. They manage institutions over $10 BILLION, so how much priority will a mere $24-million credit union get? H. R.601 regarding privacy notices is helpful, but not significant. What is often cited as regulatory relief isn’t real regulatory relief for small credit unions.
The regulations that have really hurt us are: higher priced mortgage loans, because if forces us to deal with complex and burdensome escrowing; Credit Card Act, because it eliminated Multi Featured Open End Lending; Private Education Loan disclosures, because they are complex; and the endless array of mortgage changes. This is where we need for regulatory relief.
Congress appears not to care and I question our trade associations’ emphasis on MBL, field of membership, risk-based capital, etc. Yes, these are important to larger credit unions and I want them to be represented, but not at the expense of ignoring issues that are, literally, killing small credit unions now.
Where is the evidence those credit unions under $50-million matter? We are excluded from many discussions and it appears the issues that are threatening us are not being addressed. We are out of time, because we are dropping every day. This disappoints me because I feel truly small credit unions ARE the credit union movement. How can we make the survival of credit unions under $50-million a top priority?
Tom Pinnow is president of County-City Credit Union in Jefferson, Wis.