Tell Me Why I'm Wrong

Feat. Randy Karnes

An off ramp for credit union charters

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In the preamble to Randy’s recent post The NCUA’s role has become writing a check and giving the bad news, he challenged me about how the insurance fund got its start:

Chip, did you, Bucky, and Ed build this system to simply sell our members to someone else when the going got tough? Was the insurance fund designed to punish credit unions, and reward non-CU problem solvers? Was the point of our investment to hire consultants to broker our problems away? Was the point of insurance not to keep us better off, but whole. Somehow, feeling whole and true to the game is not something I associate with the managers of our fund today. Are they insurance people, or just money managers and political fixers?

When all of this was set up, we saw the need to see it as a system and not an aggregation of independently funded and operating institutions. As to the insurance fund we had to start somewhere. The bottom line is we could not prove with numbers that the 1% plan was a better way, because there were no audited numbers and therefore no accurate loss reserves. Just a cash basis kind of accounting. And 10-15 years of successful state operations. We now have the numbers and almost 30 years of experience. The critical factor is there is so much money that NCUA can use it as a slush fund, not just insurance; and they can claim they are doing their duty just by liquidations—which was not the intent. They seem to be opportuning the system instead of managing or running the fund the way it should work.

In Randy’s blog, he makes the case that he sees the NCUA’s practice of liquidating versus solving credit union problems as just that; mismanagement, a departure from the design, and ratifying their actions by a misinterpretation of the design in the best light, and a clear perversion of the design in the worst light. The $1.62 billion cash outlay to close Melrose and Lompto is just an extreme case of NCUA’s inability to effectively resolve problems, whether they be temporary, such as leadership performance or a CEO transition, or longer term with overvalued assets. NCUA has outsourced its responsibilities to third party, for-profit firms such as Barclays and Black Rock in the case of the corporates. More routinely today, examiners strongly “encourage” credit unions that are having organizational shortcomings to seek a merger rather than working with the credit union to sustain operations.

One study by a CDFI group calculates the age of the average founding date of all active credit union charters today as 1954. Many are older. All have lived through the 70s oil crisis, the recession and double-digit inflation and unemployment of the 1980s, deregulation, multiple banking crises including the shuttering of the S&L industry, the Internet revolution and even the Great Recession. So why would someone quit the charter now having survived a history of economic perils that have caused so many other industries to fail? I believe people give up when they are told repeatedly that the unique capabilities possessed within their credit union charter no longer matter. Members can get the same or better deal elsewhere.

The unique co-op design was not just at the member-owner level. The regulatory system followed the same principles. Whereas the banking industry had three separate institutions responsible for chartering (OCC), liquidity (the Fed) and insurance (FDIC); credit unions created a unified regulatory structure with all three oversight functions under a single board. This approach reflected both the fact that co-ops were a unique financial system outside traditional clearing house and liquidity options. More importantly the structure of the CLF and NCUSIF copied the member-owner design of the credit union model. Consolidated oversight allowed different funds for different needs, good coordination and greater efficiency in sharing information and data. But the cost was the checks and balances of three different institutions in the banking sector.

And credit unions’ combined regulatory capabilities were extremely effective in responding to the economic, political and financial upheavals that occurred. From the 1980s onward.

The structure of the NCUSIF with the 1% deposit and a retained earnings range of 20-30 basis points on top proved to be an ingenious solution. When the NCUSIF was launched in 1971 it had no ability to build retained earnings as did the FDIC and FSLIC both created in the 1930s. The fund’s equity ratio never exceeded .30 basis points of insured shares. The premium-only system did not work. A better way was found by copying the structure and successful experiences of the 16-state chartered private insurance funds.

But the solution was more than design: it also changed the role of the fund from a purely “insurance-pay out the loss and move on model” to a co-op venture capital fund that could be used to stabilize, and recapitalize if necessary to support credit unions affected by internal or external events. Because credit unions had no access to outside capital, the NCUSIF became the capital provider “of last resort”. No institution experiencing a financial downturn will have access to normal capital markets. Title II of the FCU Act created a special section for providing fund assistance (section 208) to provide financial help for credit unions to right themselves when falling short of required capital standards. Capital assistance was an integral part of the NCUSIF design. Credit unions have no other capital options which is why the role of the NCUSIF is so vital.

These early NCUSIF workouts succeeded and saved the NCUSIF and credit unions hundreds of millions of dollars during the 1980s recession and challenges from the transition to deregulation. More importantly, this was the commitment NCUA made to credit unions who were concerned that sending more money all at once to Washington (versus an annual premium) which they feared would just increase the temptation to spend it.

Most importantly the fund’s design worked as intended:

  • From 1971-1984 when the NCUSIF could rely only on premiums (1/12th of 1% or 8 basis points) the fund’s annual insurance loss rate was 4.16 basis points or half of the annual premium.
  • From 1985 through 2007 the fund’s annual loss rate was only 1.6 basis points. Moreover, the fund required an outside audit according to private company standards so that the loss reserving expense and allowance accounts remained objectively verifiable. In seven years there was not even an insurance loss. In other words, a yield of only 1.6% interest per year on the 1% deposit would be sufficient to cover the annual loss, before adding interest on retained earnings.
  • The fund’s normal operating level of 1.2-1.3% of insured shares was 81 times more than the rate of the annual insurance loss. And the 10 basis point retained earnings range in the NOL would have covered a catastrophic loss six times the average with no need for a premium. Today that 10 basis point range is almost $1.2 billion.
  • The design worked because of the accountability that was part of the fund’s reporting structure plus the ability and willingness of examiners to assist with problem resolution.

From 2008 through 2018 the loss rate jumped to 1.9 basis points due to NCUA’s practice of liquidating problems versus solving them, which began with the corporate resolution which was moved off the NCUSIF’s balance sheet and onto a separate fund of the TCCUSF. This liquidation pattern carried over into the shutdown of all lenders affected by the taxi medallion disruption. But a second factor was the NCUA’s transferring an increasing percentage of its every growing operating budget to the NCUSIF through the overhead transfer rate. Thus, over 90% of the NCUSIF operating expenses were not from managing the insurance fund, but rather paying for NCUA’s overall operations.

NCUA has changed both the practice and the cooperatively designed approach to use the NCUSIF to liquidate rather than rehabilitate credit union downturns. Instead of using cooperatively provided resources to support turnarounds, NCUA used them to make the problems go away: merge them for someone else to worry about or liquidate. Instead of being a source for system support, it became an off ramp for credit union charters.

About Chip Filson

A nationally recognized leader in the credit union industry, Filson is an astute author, frequent speaker, and consultant for the credit union movement. He has more than 40 years of experience in government, financial institutions, and business. Filson’s breadth of experience makes him an authority on a range of topics, including analysis of credit union trends, credit union public and market-facing opportunities, and strategies for enhancing member value. His contributions to the cooperative movement have been demonstrated with his analysis and advocacy for the corporate credit union system, NCUA’s Corporate Stabilization role, and the need for regulatory reform.

Chip co-founded Callahan & Associates. Filson has held concurrent positions at the National Credit Union Administration (NCUA) as president of the Central Liquidity Facility (CLF) and Director of the Office of Programs, which includes the NCUSIF and the examination process. He holds a magna cum laude undergraduate degree in government from Harvard University. After being awarded a Rhodes Scholarship, he earned a master’s degree in politics, philosophy, and economics from Oxford University in England. He also holds an MBA in management from Northwestern University’s Kellogg School in Chicago.

The Next NCUA Board Member Will Probably Be Cut from the Same Cloth

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On 3/28 Chip Filson pushed this to our marketplace. Did you read it? Did you yawn, and then delete it? Or did you think about it and act on it? I can think of a few things to do with this posting:

  • Send it to my board and declare that the future based on these new board members will probably be a lot more of the same – they are cut from known cloth with known track records, and with no new things in sight.
  • I would then send it to everyone I know that might have some influence over this process and say I hope McWatters’ replacement is at least a small if not major course adjustment.
  • I would drop every contribution to the political side of our industry—there are no lobbies that really are as upset as our members are with these leaders—until they decided to do something about the way we assign NCUA board members. I would follow that up by pushing for future administrations to actually have a plan or project for these seat warmers to lead on, if they can lead. Board members are supposed to push for something other than bureaucratic constants.
  • I would then study board members that get appointed to the agencies that lead our competitors and consider the fact that we do not get the same draft picks for our hopes and dreams. Another thing to point out as we think about our political contributions and support lent to others. Have you read the writings or speeches made by Chairman Jelena McWilliams? Wow.
  • And finally, I would send all politicians a message: My Organization Has Left the Building – savings its money to survive the political system’s wake washing up my strategies and hope I have enough saved to avoid being washed away by their actions. Because based on the history that Chip lays out here, there are no players coming to the NCUA that are worth the money to stay engaged.

You might say, Randy hold on here, we can’t change anything by quitting, we need to influence the game. To that I say we have to REVOLT against the current game, and since so many of us just do not know how to really get our politicians’ attention that might be a sucker’s bet. I have no kingdom to offer in exchange for a solution here, just my hope. Chip gets me thinking…..

One Step Forward and Two Steps Back

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What Does the Changing of the Guard at NCUA Mean?

NCUA Board Member Richard Metsger, whose term expired in August 2017, leaves shortly. Two board members, Harper and Hood, will fill the Metsger “democratic” seat and the vacancy that has existed since Debra Matz resigned in 2016.

NCUA’s role is unique and consequential. No other organization in the cooperative system has the influence and resources to affect the direction of the entire credit union enterprise as does the regulator.

This three-person turnover in the Agency’s leadership is an opportunity to assess the past and to consider what the new board members may need to address. This new leadership configuration should be at the front and center of everyone’s attention who believes a course change is necessary.

Metsger’s Tenure

Metsger’s nearly six-year tenure is important because for that time he was effectively “in the majority.” He was the automatic second vote for Chairman Matz until her departure in early 2016; he served as chair from May 2016 to January 2017. And as the only other board member with Chair McWatters, he was effectively co-chair for any decisions requiring Board approval, for his veto would mean nothing gets passed.

While facts do not always tell their own story, they are an important place to start when evaluating a person’s leadership contribution. Some of the outcomes during Metsger’s term include:

  • A 33% increase in NCUA’s budget from $251.4 million in 2013 to $334.8 million for 2020, the second year of the most recent two-year approval process.
  • A reduction in NCUA staffing from 1,261.5 FTEs to 1,173 and closure of two regional offices.
  • A total of 935 federal credit union charter cancellations since 2013. The total decline in NCUSIF insured state and federal credit unions was 1,443, or 21% of the industry numbers at the end of 2012, the year prior to his arrival.
  • Granting 4 de novo federal charters in the same six years.
  • Reporting the first ever loss in the history of the NCUSIF in 2017 of $229.1 million.
  • Recording the single largest cash payout by the NCUSIF for natural person credit union resolution in 2018 of $1.165 billion. The previous highest cash payout was $349 million in 2012.
  • Approving the “merger” of over $3.1 billion of TCCUSF surplus into the NCUSIF in 2017 despite the Congressional language accompanying the enabling legislation which stated: “These provisions are intended to ensure that the activities of the Fund are restricted to resolving problems in the corporate credit union system and not used for other purposes, such as for dealing with natural person credit union problems.”
  • Raising the NOL of the NCUSIF for the first time since the fund was restructured with the 1% deposit in 1984, despite comments from credit unions in which only 12 of 663 (1.4%) respondents were in favor. As pointed out in credit union comments, the numbers presented by staff were fictional, not related to any real data or historical validation, and contradicted by auditors’ own comments about contingent liabilities.
  • By raising the NOL to 1.39 and “merging” the TCCUSF surplus, Metsger admitted in a December 8, 2017 speech that staff analysis “reinforces why we needed to increase the fund’s normal operating level this year, to account for any significant losses that otherwise might have required a sudden and significant premium charge to credit unions.” The statement confirms the intent to circumvent the FCU Act’s premium restrictions when the NOL was above 1.3% of insured shares and use the TCCUSF for natural person losses.
  • Passage of the 400-page risk-based capital rule despite overwhelming evidence that that the approach was intellectually flawed and legally dubious. This was the most burdensome, lengthy and intrusive rule ever imposed on insured credit unions. This action continues even though the FDIC’s own experience as stated repeatedly by Vice Chairman Tom Hoenig’s is that “a more dependable measure of capital strength is the tangible leverage ratio” or in credit union terms, the net worth ratio.

Even Metsger’s description of the $160 million NCUSIF 2019 “dividend” as the second highest in fund history is a misstatement. NCUSIF retained the entire $3.1 billion TCCUSF surplus, the ongoing earnings on that amount plus NGN fees—all intended by Congress to go back to credit unions. NCUA still owes the industry $2.2 billion before any return could accurately be called a “dividend.”

One might counter the above summary with the industry’s continued growth in assets and members despite the decline in charters and increasing NCUA burdens. I believe a more accurate assessment would be that credit unions have succeeded in spite of NCUA, not because of their oversight.

Two Steps Back?

If Metsger’s departure is a step forward, what about the two NCUA returnees in Harper and Hood as board members? Will they just rely on previous experience to continue past practice or will they see a need for change, and if so where and how? How would they interpret the trends above?

One point of commonality among all three is that the terms cooperative system and cooperative design are almost never used or referred to. The term “cooperative association” is in the first paragraph of the FCU Act. It is the most important factor distinguishing credit unions from other financial firms. It characterizes credit unions’ singular responsibility to the member-owner.

Cooperative design also creates a different regulatory agenda from banks where there is an ongoing challenge of balancing shareholder interests, with fair consumer treatment and with the public’s backstop of insurance and liquidity safety nets. Instead of regulators trying to align private wealth with public purpose, credit unions create common wealth that can be “paid forward” to benefit future members and communities.

Expectations of a Board

The Federal Credit Union Act is clear on the Board’s role in that it uses the term “manage” the agency. That word can have a lot of different interpretations. But there can be no doubt that this is where the buck stops, not matter how responsibilities are assigned by the Chair.

Unfortunately, in their board role, members most often present themselves as performers at public meetings, reading scripts, and never discussing real policy or “management” options. The role of the board to ask thoughtful questions and/or to challenge prepared positions and data never occurs. Staff’s assessments and conclusions are accepted without meaningful dialogue.

Instead of leading, the board merely endorses the staff’s interpretations and in-house views. No outside perspective from the members, policy perspective or even board expertise is provided. Board members become merely voyeurs going through pre-staged motions of accountability.

Can either Hood or Harper learn from versus repeat these past experiences?

McWatters’ Conundrum

So, will McWatters stay the course charted with Metsger? Or has he been biding his time to make real change until he has a second vote?

McWatters’ initial participation in 2014 as a minority board member was very encouraging for credit unions. He was bright, willing to listen, unfailingly polite and responsive to issues brought to his attention. His dissents around NCUA budget processes and substance, the risk-based capital rule and other interpretations of authority (think corporate capital rule) were positive contributions on critical topics. He openly challenged the “regulatory aggression” practiced by the agency on credit unions after the Great Recession including the then Chairman’s very public feud with State Employees Credit Union in North Carolina. Or even the agency’s self-justifying so-called appeals process.

McWatters repeatedly showed, while in the minority on the board, the competence to challenge the regulatory status quo. His long essay style, legal briefs of dissents were a level of effort and insight never seen at the board level.

But somehow those positions dissolved once he became Chair. Was this because he felt checkmated by having only one other board member? Or that it was not his role, but staff’s, to initiate change? Was his assessment that personal circumstances did not allow him to “manage” the agency, so he must revert to a role that credit unions refer to as a “knife and fork” director?

One role of a Chair is to help define the contribution expected of other board members in their collective capacity to lead the NCUA. Can he recover from a period of passive leadership where bipartisanship seems the only justification for action? Can he break the cycle of hyperbolic spending through the NCUSIF’s manipulation of numbers to underwrite off budget expenses? Can he rise above the Orwellian use of “safety and soundness” to justify any and every regulatory event? Will he articulate the unique value of cooperatives in the American financial system and re-energize the entrepreneurial spirit that animated almost 50,000 charter creations in the 20th century but almost none in the 21st?

I don’t know what the answers to these questions will be. But what I believe is that credit unions are running out of runway to correct the trends that Metsger inherited and then dramatically extended. If these trends continue, the endgame is becoming clear. An independent cooperative financial choice for the next generation will just be an episode for economic history texts, much like the S&L system which expired in the last century.

About Chip Filson

A nationally recognized leader in the credit union industry, Filson is an astute author, frequent speaker, and consultant for the credit union movement. He has more than 40 years of experience in government, financial institutions, and business. Filson’s breadth of experience makes him an authority on a range of topics, including analysis of credit union trends, credit union public and market-facing opportunities, and strategies for enhancing member value. His contributions to the cooperative movement have been demonstrated with his analysis and advocacy for the corporate credit union system, NCUA’s Corporate Stabilization role, and the need for regulatory reform.

Chip co-founded Callahan & Associates. Filson has held concurrent positions at the National Credit Union Administration (NCUA) as president of the Central Liquidity Facility (CLF) and Director of the Office of Programs, which includes the NCUSIF and the examination process. He holds a magna cum laude undergraduate degree in government from Harvard University. After being awarded a Rhodes Scholarship, he earned a master’s degree in politics, philosophy, and economics from Oxford University in England. He also holds an MBA in management from Northwestern University’s Kellogg School in Chicago.

The NCUA’s role has become writing a check and giving the bad news

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Mike Shafer responded to my most recent article and offered a different view of the issue at hand as one in which the NCUA has the unenviable task of performing clean up duty. Firstly, thanks Mike for speaking up on this topic and sharing your opinion!

Thanks also for making my point that the NCUA did what it has always done, and we were all happy to let them off the hook.  We will lightly criticize the NCUA for letting credit unions make this a system issue (raking in CU profits short-term with no plan for the ultimate rainy day), but then just forgive the NCUA when they have to deal with the consequences. Do you sense a pattern here?

Or is it just all part of the game? CUs maximize their independent success for as long as possible and then dump their ultimate failures on the system? Could you imagine if that was the game, and it was stated so directly?  How would people see the design and how would they change it?

One perspective: CUs owe nothing to the system from their independent success year over year. In which case, the NCUA really has no role in assigning some premium or hold back from success against future ultimate failure. Alternatively, credit unions’ ultimate failures are equally divided by the system independent of their successes from the past. In which case, the NCUA really has no role in the end, but to write a check and tell the system about the bad news. (This is the opportunity to improve.)

After you gotten the bad news over and over, and you went back to the design statement over and over, do you think it reasonable to let everyone off the hook without trying to improve it? (Chip sure does not think that way.) What if we all pushed hard to stop getting the bad news and made the design work better.

  • What happened to the $ represented by the extreme Net Worth? Were they extreme or should they have been seen as mandatory per the RISK? (This is a tough thing to size up – I am not a fan of RBC.)
  • How did the system benefit from the independent success of these credit unions (direct sourcing CUs and the participating CUs)? Is there a reason to rejoice in the net returns to the system even after the failure?
  • Who made the call it was time to declare Ultimate Failure? Here is my bone to pick with the current culture of the NCUA: they did.
  • Who decided to end the CU work out, and stop working with the members? Here is my bone to pick with the current culture of the NCUA: they did.
  • Who decided that writing a check was better than pushing through as owners of the situation with the members? Here is my bone to pick with the current culture of the NCUA: they did.
  • Who likes to benefit from calling it a crisis and being the white knight? Here is my bone to pick with the current culture of the NCUA: they did.
  • Who accepts the design and even justifies the writing of checks, the increasing budgets of the NCUA, and the liquidators profile? The industry does, because it can’t and won’t work to change the design.

Now don’t get me wrong, I have no simple fix to this design. Frankly, I am not sure I need one because I am ok with the net return to the system over the life of member economies (years of gains less the shut down costs model). But what I hate is the posturing of everything as a crisis and that the NCUA is doing a good job, instead of a mediocre one at best.

I am sure that Chip sees the design a bit differently. Perhaps he does not believe in this statement:  The NCUA really has no role in the end but to write a check and tell the system about the bad news.

Maybe he believes and we should too that:

  • The NCUA should do everything in its power to see that the independent credit union completes the work out directly with the members and delays the Ultimate Failure declaration until all is lost.
  • The NCUA should write checks and ensure the ability of the system to complete the work out with the members, not just pay for the problem to be transferred out of the system without care or concern for the impact on credit union owners, their communities, and the sense of our independence as cooperatives.
  • And in doing all of that the NCUA should be accountable for the situation of both success wasted, and failures not managed to the minimal loss.
  • We all should look for more than convenience in dealing with failure, we should look to the pride of helping CU with their independent management of success and failures via a system that pushes them and us not to quit on customer-owners at the drop of a hat.

Tell Me Why I’m Wrong

Read Chip Filson’s response to Randy

Chip Filson deserves an answer from all of us as credit union professionals

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Is it possible that Chip Filson is the last NCUA critical thinker of his generation or just a one-trick pony?

Read this most recent posting from Chip Filson on CreditUnions.com. Within just a few seconds you will pause and think “Oh, Chip, are you ever going to give up on kicking this dog? Does anyone really think it matters if we critique the NCUA’s action anymore? Does it make a difference?” But then you will read on—I always do. Chip Filson is a friend of mine and I believe his opinions on the system and the NCUA are valuable on many levels.

First, they remind me that the NCUA is not just an insurance firm or a regulator – they were designed to be more. They were designed to foster and separate the concept of a consumer-owned financial system that saw the world through a community lens and with bigger goals than just banking.  Chip might be the last true commentator who had a pulpit focused on wanting the NCUA to be more than just a government agency.

Second, they remind me that you have to look further than today’s headlines to ADD it all up. And while the numbers are getting so large that we round to the nearest billion these days, Chip reminds us that the NCUA only rounds numbers up or down based on their own internal goals to look good. The NCUA is no longer balanced by anything other than its own sense of importance. And board members are no longer the voice of reason, they are simply the promoters of a bureaucrat’s reputation. Chip might be the last true historian with enough perseverance to audit, research, and painstakingly try to sum up the NCUA’s actions in totals to paint stories as lessons for the future, not just sound bites without conscience.  

Third, they remind me that counting on the central planners of Washington and all those that see our business, credit unions, as some fine-tuned social model for justice is becoming more and more fool’s folly. For those who make up the industry have lost much of their fire over injustice, lost much of their indignation of those who would tread on consumers that act to be owners of community businesses, and have lost faith in political structures that cannot see a reason to separate a cooperative system from the evaluations and constructs of for-profit designs for banking and community action. Chip might be the last CU leader that truly reminds me to maintain hope that the NCUA could be more, and that counting on our system to heal itself is still worth the effort.

Today, the article strikes out against the way 8,000 member-borrowers were discounted and forgotten. Yesterday, there were dozens of moments Chip reminded us that the NCUA was off track. But what I am the most dismayed about in thinking about all of these articles is that they never rallied my generation of CU leaders and CU organizations to any recognizable effort to change anything at the NCUA. We have yet to mount any effort that showed us that any administration’s intent for the credit union industry was greater than a quid quo pro nod to a third level constituent owed a favor. We never got anyone’s attention for the effort to build a better NCUA, a better insurance fund, or a better machine to improve our own solutions.

We are capable community, small business builders, but we might be little else if Chip will be the last commentator to try to rally our ire and hopes for bigger things. Tell Me Why I’m Wrong.

You do not see this every day, but now is the time to see it more

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A CU industry ICON reaches out to the Washington Post for more light on credit union regulatory agency’s disrespect for 100M American citizen-owners of credit unions

Many of us have long become accustomed to Chip Filson’s warnings related to NCUA excesses and lack of respect for process expectations or rules.  He constantly lets us know that the current administration at the NCUA and ineffective board cares little about due process, transparency, or even the hint of propriety in the use of their power to just wipe out credit union owners’ capital and the future it represents. So when he published his most recent article on the NCUA’s spending $1.5B of member funds, many of us might have just sighed “there he goes again”, and way too many of us might have given up trying to connect the dots with all of the numbers, acronyms, and references to the NCUA’s shenanigans. It is news, but it is just expected news these days.

What was surprising to me was when I read this email from Chip to the Washington Post, because his indictment of the NCUA in his email was much easier to consume, to engage with, and to “feel” as an industry supporter. I have always been able to feel Chip’s passion for the system, and even his hopes that the NCUA would play up. But when I put this article, our industry apathy to the details, and this reach out to the real world together I knew things were changing. Keep going Chip, and keep pushing for people to pay attention.

For now is the time to push harder. With the recent announcement of Rodney Hood for another round at the NCUA as a board member, the recent push to fill the other empty seat, and the pending need to replace McWatters, there could be no bigger reason to try to get the attention of all of the people who might care about those 100 million citizens. Now is the time to push for a different type of leader on the board. Rodney Hood shows no signal, from his past or current activities, that he will change a thing for the better as a future board member. I predict that he will be recycling the agency’s disrespect for all of us with his passive, quiet demeanor of a bureaucrat without the skills to lead.

Now is the time to push the President to actually have a “project” for the NCUA Board. Something that calls for leaders. Now is the time for the administration to do more than dole out appointments as an afterthought. Now is the time for the administration to give the NCUA Board a job! Change the path of the CU industry by actually caring about the owners of credit unions as much as they care about the owners of for profit financial service models. Now is time to push for a new day.

I hate to see icons of the credit union industry (e.g. Chip) pushed to calling on the Washington Post, but now is the time to reach out and demand somebody shines a light on the need for a better NCUA Board with a real agenda. Tell Me Why I’m Wrong.

The tides of change don’t affect the legacies we leave behind

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Thoughts on the merger of Progressive Credit Union

I recently read an article from Chip Filson about the merger of Progressive Credit Union, a 16-year CU*Answers client, and PenFed, and it got me thinking. To some the merger may have come as a surprise, but for those aware of what made Progressive so successful for many years, the taxi medallion industry, it did not come as a shock. Rather, Progressive was caught up in the tides of an industry being swept away by Uber and other rideshare services. But instead of serving as a cautionary tale, I think Progressive’s legacy will be one to inspire others looking for that next big thing.

There’s no doubt that Progressive was a long-term leader in leveraging a marketplace for its members and the members of many other credit unions—they positively worked by proxy for us all. Robert Familant and his team creatively encouraged community lending (participation lending) and its evolution to aggregate capabilities to reach more people than they could otherwise have done alone.

And Progressive did leverage the medallion economy to great success, seeing their assets rise with the bubbling medallion prices, which climbed from an average of roughly $200K in 2002 to $1M in 2014, and have since crashed back down to 2002 levels. As new entries into the market disrupted the medallion industry, Progressive, among many others, was part of the wave requiring everyone to adjust to new norms.

No insurance company puts any credence to the idea of working things out, whether it be living through a portfolio of loans, or working through lawsuits, or trying to defend taking on hard roads ahead. They put so much weight on removing the topic from the to do list, that they weight their models for only their goals. While I think that the credit union might have been able to work it out over the long term, the NCUA would never have allowed them to continue riding the roller coaster of adjustment. They doomed the credit union for convenience and a sense of calm—get Progressive and medallions out of the news.

The taxi medallion business was a great business and the lifetime earnings of those who were good at it cannot be denied as anything but positive. It had its phases of wins and losses, but on the balance did very well for Progressive and its members. Its time has run out and so has Progressive’s. Not being flippant here, far from it, I respect Robert, Progressive, and all of the CUs that helped their members through the years based on the economies created by medallions and credit union hard work.

Every generation must learn this evolution of economies and the wins and losses that come with it. To 1) see the constant need to search for opportunities; 2) constantly consider how those situations might be disrupted; 3) avoid the impatience of disconnected regulatory oversight; and 4) see the long-lasting triumph of those who lead into the future without regret instead of clinging to the injustice of what was. There are lessons to be learned, adjustments to be made in the next cycle, and joy over the fact that it worked for Progressive for as long as it did.

Tell Me Why I’m Wrong

Scale is not everything

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Be careful not to dismiss ownership as some inconsequential detail on the path to success

I received a comment from Gregg Stockdale on my last piece, “The risks of vendor consolidation on the credit union industry“. In it he wrote:

“What disrupter of the credit union industry followed this model?  -“Only ownership can prioritize disruption of the status quo, competitors and the core of innovation. Cooperative ownership of our solutions is the key”  Also, “Protecting the decisions and mechanisms for maintaining our differential is the mandate for the future”  –  What differential?  Other than ownership, how is a cu different from a bank?  Cu’s are very bank-like and banks have become cu-like in their service offerings.  The big disrupters have come from outside the entire industry and many are privately owned.”

I agree whether a CUSO, CU, or any other company is a disrupter can be difficult to identify without close examination. But I contend there are many in the CUSO space as vendors, and in the credit union space, when they are judged locally by their consumer-owners (members) who meet or surpass the bar for disruption. Where I think Gregg was off track is his MACRO EXPECTATIONS from these ideas. He dismisses CU ownership as the DIFFERENTIAL that counts. It does count, and it should. Credit unions represent consumer owners, citizen ownership, and ultimately the best of community ownership model in society. Our economy and government should be more aware of that and be more demanding of that differential. If they were, it would be more than just an internal goal of cooperatives to focus on disrupting, it would be a national goal and mandate that they do. For that reason I judge the NCUA not to be a cooperative regulator, but just a bank regulator hiding under a cooperative banner.

Owners, no matter what their type, can internally mandate that their approach to the marketplace be disruptive to their competitors, for their consumers, and for the status quo. We both can be disappointed when their efforts are not STUNNING and APPARENT to the outside world, but their efforts can be real. They can be real one consumer at a time. So when he mentions the “big disrupters” he is scaling disruption with a MACRO EXPECTATION again. Why?

That is the point of my blog – vendor mergers like Fiserv and First Data are based on the MACRO EXPECTATIONS that scale is all that matters. And that when scale wipes out the nuance of niche approaches by simple rolling over the needs of those niche players we lose something, and in our case (CU supporters and believers) we might lose everything when we buy from these vendors.

I do believe that CU*Answers is a disruptive force, but not one that will move the world or even vendor analysts. I believe the force mandated by our ownership will move our industry to respect itself via our intent. I believe the force mandated by our ownership will move our industry to see that the cooperative inherent win-win model with consumers is powerful because consumers are the owner. And I believe that that is a disruptive idea for the ages when highlighted, amplified, and sincere in its efforts. So I focus on the micro-disruption of the owner’s intent, the owner’s heart to move things given a chance. Every community’s heart given a chance. I believe that our industry should be concerned when the vendor marketplace consolidations take that chance away.

Thanks to Gregg for commenting and pushing the conversation further.

The risks of vendor consolidation on the credit union industry

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By now you’ve probably read about the announced Fiserv-First Data merger. In an opinion piece, one person suggested that “small banks and credit unions fear big fintech.”

“Fear” is the wrong word here though. It should have been “CU Thinkers See the Long-Term Challenges in Vendor Consolidation.”

It is not just competitors merging here that should concern credit union planners and leaders. It is the consolidation of focus, project resources, and price to ROI expectations that should worry a niche-based industry like the credit union industry. When the vendor marketplace or the industries that support a marketplace design, like financial services, become so out of proportion with segments of customer niches, then those niches are mandated to more and more.

Those niches, in this case credit unions, struggle with each renewing contract and acceptance of norms other than the ones that they count on to propel their unique success. What appears to be simply buying tactics at one level of the credit union becomes accepting new conditions that change the very culture and business approaches that once were the defining differentiators for credit union success.

  1. Focus – As these super-firms–these glaciers–set their marketplace priorities and execute their plans, they will continue to marginalize credit unions and their drive to be unique in a commoditized, externally defined marketplace. How will CUs set their own unique priorities?
  2. Project Resources – With vendor consolidation combined with resource scarcity we see in the labor markets, these recombining firms have less project management focused on niche marketplaces and the concerns of those marketplaces to project manage CU adjustments and change priorities.
  3. Price – Does a vendor design its prices for its success or to the needs of its clients after absorbing the prices cast upon them? CUs are increasingly becoming price takers and massagers through CU distributors like PSCU, COOP, etc., but less so price innovators through ownership or via their own manufacturing of solutions.

While some segments of the CU industry believe they can grow and keep pace with the scale that can keep them in the game with these firms, other segments will feel these pressures growing. Credit unions are not just struggling with the need to compete with other financial service segments for consumer connections, they are or will struggle to find a vendor focus that does not simply press them into being weaker versions of their competitors via commoditizing of their business models – not just their tools that support their products. And like cancer, one day you wake up and find you’ve been eaten from the inside out, and the body does not respond to the mind’s desire to execute its own plan.

CUs must continue to prioritize their own uniqueness, and that is the ownership model. Cooperative ownership is the key to being the manufacturer of price and culture even in spaces that seem dominated by commodity tones. Pushing to design prices that allow a client to earn out on the investment, pushing to focus resource and project management based on the timing of the client, and pushing to ensure that models for shared and cooperative execution come to the forefront.

We are an industry of cooperatives, and that required sense of connection is important to our futures. Only ownership can prioritize disruption of the status quo, competitors, and the core of innovation. Cooperative ownership of our solutions is the key to:

  • Price Disruption – to ensure our cooperative models can earn the ROI on the prices they pay.
  • Access Disruption – to ensure that the things CUs need are not walled off from them or relegate them to the back of the line.
  • Execution Disruption – to ensure that when service engagement options need cooperative alternatives, they are there.

Protecting the decisions and mechanisms for maintaining our differential is the mandate for the future. Whether it be in our dismay about a regulator who seems as resolved as ever to a one-way model for financial service firms or about the fact that we increasingly rely on vendors where we are only an afterthought in their strategies, we all, the customer-owners and members of credit union cooperatives, should not fear the future. We should simply mandate the future to the greatest extent we can by mobilizing active ownership in every level of our value stack or vertical capabilities.

Tell Me Why I’m Wrong.

The new norm for credit unions should be a return to a norm seemingly forgotten

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Last month, Randy sent out an email regarding a generational approach not to how credit unions view their consumer-owners, but how they see themselves and their own staff. He posed the question of whether CUs and CU leaders are self-aware enough to expect norms to change or do they just find themselves out of sync with where they are today and behind the gun. How will new generations of leaders decide what it means to be a credit union moving forward? I took up the intellectual challenge and suggest the following…

Future executive and managerial skills will need to be fine-tuned to meet the evolution of the credit union into what I would call a “pure financial intermediary.” In the purest sense, tomorrow’s credit union would act more as a broker of the member’s financial needs, all while controlling the brand identity of the credit union as seen by the member/owner and the general public. To be successful, small, medium and yes, even the largest credit unions, will identify the expanding requirements to build collaborative operational and aggregated funding and depository solutions to lower operating costs and maximize the fee return on networked lending and depository solutions. The concentration of expertise in shared operational and transactional solutions owned by a network of credit unions will eliminate duplicative overhead expense and minimize, reduce or even eliminate the growing costs of managing balance sheet risk.

By aggressively building collaborative scale, fully leveraging technological tools and refining the special skills necessary for a successful, networked business strategy, tomorrow’s credit union leaders will be able to not only sustain the credit union model but should aim to be the pre-eminent solution for all consumer-based retail and small business financial solutions. We’ll beat the banks and the fintechs by being  “greater than the sum of the parts.” We have often “talked” this strategy, but our execution has sucked.

Adopting this strategy allows the individual credit union to focus and concentrate on what we have traditionally been the best at: providing the expertise necessary to identify and meet the life time needs of the individual credit union owner and member. This strategy also requires that CU management teams possess and execute the skills necessary to be a good network partner. We’ve all seen in our many collaborative efforts among credit unions, some credit union CEOs and their teams are great partners in any networked effort, some not so much.

This is a learned skill! Some will never be comfortable in anything but the traditional vertical hierarchy, but credit union survival and our desire to provide the very best in product design, pricing and delivery/distribution channels demands that future leaders learn and execute the skills required of a networked model. Think about it… at some point in the past, a group of individuals decided to create a network in order meet financial needs that they found lacking in other institutions or completely barred from. We need to take that same strategy up more than a few notches than we find in our current institutional solutions.

In the future , if you think you can manage in isolation or think you and your team can manage in the networked world without a new set of skills, good luck.