Have you read the last two postings of Tell Me Why I’m Wrong? Vic Pantea and Patrick Sickels commented on an NCUA Interagency Statement Clarifying the Role of Supervisory Guidance and while they may not be riveting, they are informative. Do not get me wrong, their postings are good work. Logging the document and ideas for a rainy day after a bad exit interview with your examiner is probably prudent. You know those meetings… the ones where the board wants to know what the heck happened in that last exam and why the examiner is throwing their weight around when you promised you are in compliance with the rules.
It is a good document to pull out during a board member orientation where you discuss the concept of being a regulated firm heavily leveraged not only by the rules, but by the feelings of your insurance agent (the NCUA) as well. Remind the new board member to consider Vic’s optimism and support. “I hope that more CU CEOs and Boards will fearlessly and forcefully argue for those strategies and solutions that they have created for the benefit of the members they serve that are within the powers granted them but in conflict with “supervisory guidance.”
The problem with the two postings is WHO CARES? Who thinks an interagency statement that was designed as a “get out of jail card” for the NCUA board and home office bureaucrats to explain that they do try to “temper” their field agents is going to change anything?
I struggled when Patrick brought the statement to my attention. Patrick’s lawyer side was showing a “precedent for arguments not yet made” kind of thing. Too many times I have seen field examiners blow off the home office’s cautions at the NCUA, and the oversight of the NCUA by other government officials has seldom seemed to weigh in on the side of a CU under pressure. And Vic, reminded me that this might help CUs play up, but is there momentum to be gained when you only hear about when CUs gave in and almost never about the wins made through pushing back? For a second, I wondered if it would be better to post an opinion piece of the value of serving warm pork rinds at loan closings, but I gave in. I took the bait that NCUA was sincere.
But now I worry that even if the NCUA were sincere, the game is set and we all will respond year after year in the same groove: capitulation to our fate. We need supervisory guidance no matter the consequences. Tell Me Why I’m Wrong.
P.s. Are we pushing for a new norm?