Posts filed under ‘Advocacy’

NCUA To Credit Unions: You Never Had It So Good

I’m exaggerating only slightly this morning.  In written testimony before the House Financial Services Committee yesterday NCUA General Counsel Michael McKenna stated that 70% of NCUA’s final rules over the last two years have provided regulatory relief or greater clarity without imposing new compliance costs. That’s a relief, here I thought credit unions were being overburdened by excessive regulation.  I guess all those credit unions that have hired additional compliance staff over the last few years can rest easy.  

As both NAFCU and CUNA were quick to point out, when it comes to assessing the impact of regulations, it’s not so much the quantity but the quality of the regulations that has to be assessed.  In truth, the whole premise of yesterday’s hearing was a little silly.  Regulators are responsible for regulating and they wouldn’t be doing their job if the industries they oversee reported to Congress that they loved the job they are doing.  Instead of holding hearings, Congress should remind itself that regulations are, by definition, the outgrowth of laws it passes.  Since that is unlikely to happen, however, NCUA can’t simply point to statistics to get around the fact that credit unions face burdens today that they didn’t have to deal with five years ago.  For example, in recent years, NCUA has:

  • blurred the distinction between federal and state oversight of credit unions by passing regulations giving it more direct control over state chartered credit unions;
  • clamped down on CUSOs by making them report more information directly to the NCUA;
  • and, of course, joined other regulators in imposing numerous regulatory requirements, euphemistically referred to as guidance, on credit unions.  For example, just last week NCUA joined other regulators in emphasizing the need for small and mid-sized credit unions to take steps to guard against theft of debit card information.

(Incidentally, regulators try to have it both ways when it comes to issuing “Guidance”.  On the one hand, they’re never referred to as regulations, but on the other examiners consider them just as binding on an institution as a promulgated rule). 

Now, to be fair to NCUA, the agency has taken steps to minimize the regulatory burden by, for example, raising to $50 million the threshold for what is considered a complex credit union.  In addition, NCUA’s regulatory streamlining of the Low Income Credit Union designation process was a master stroke in using regulatory powers to benefit the industry.  Think about it.  Without getting a bill passed, NCUA gave thousands of credit unions the opportunity to seek out secondary capital and take in member business loans without having to be concerned about a  cap. 

In the end, what is really going on here can’t be quantified.  On the one hand, at its best NCUA has demonstrated a recognition that, given the huge divergence in the size and sophistication of credit unions, regulators should strive to avoid one-size fits all requirements.  On the other hand, at its worst, NCUA myopically views almost everything through the lens of the Share Insurance Fund with the result that it demonstrates a cavalier disregard of the right of state chartered credit unions to be regulated primarily by state regulators and often seeks to impose safety and soundness requirements that impinge on the right of credit unions to run their credit unions in the way that best benefits their members.

April 9, 2014 at 8:14 am Leave a comment

Why Credit Unions Are Wrong On Risk-Based Capital

As faithful readers of this blog will know, I occasionally feel the need to remind people that the opinions expressed are mine, and mine alone, although you, of course, are welcome to agree with me. 

Both NCUA and credit unions are making serious mistakes in the march toward a more sophisticated risk-based capital scheme for credit unions with at least $50 million in assets.  Another time I will talk about NCUA’s mistakes, but today I think it is time to take the industry to task.  Most importantly, the industry can’t have it both ways when it comes to risk-based capital.  For at least a decade, it has been pushing NCUA to adopt a risk-based capital formula arguing that a capital framework more in line with that of banks will free up capital at well run credit unions and ultimately help more members.  This sounds great, but it is flawed for two reasons. 

First, NCUA has always said that with any risk-based capital proposal there are not only going to be winners, but losers.  If the industry wants capital reform but continues to insist that NCUA’s proposal is fatally flawed, then it has an obligation to come up with a workable alternative.  However, my guess is that anything resembling industry consensus on what an alternative proposal would look like is impossible to obtain.  For instance, if you think the proposal places too much emphasis on concentration risk, does that mean you’re in favor of increasing risk ratings across the board?  And if you don’t think concentration risk should be dealt with by imposing higher risk ratings on mortgages and MBLs, then how else should NCUA account for concerns that too much concentration of any given asset poses a greater systemic risk to the industry?  There is no win-win here; there are winners and there are losers.

Which leads us to the second, more fundamental problem with the industry’s position on risk-based capital.  The simple truth is that despite the glorification of the BASEL framework, there is absolutely no indication that risk-based capital regimes actually work.  remember that some of the largest banks that failed over the past five years were subject to BASEL requirements.  In fact, as summarized in a recently released analysis from George Mason University “since 1991 the Federal Reserve has employed a risk-based measure of bank capital as its primary tool for regulating risk.  However, RBC regulations are easily exploited and susceptible to regulatory arbitrage.  Evidence indicates that such regulations have increased individual bank risk as well as systemic risk in the banking system.”  Also, read the excellent quotes in the CU Times provided by Chip Filson, who is doing a great job leading the charge against a risk-based capital regime. 

The myth of risk-based capital is underscored by NCUA’s proposal.  Risk rating is complicated but at its core it is nothing more than a policy judgement on the part of regulators about which assets pose the greatest relative risk to safety and soundness.  The problem is that such policy judgements are inevitably based on preventing the last financial crisis from occurring again.  In reality, whether the next financial crisis occurs in five or fifty years, no one knows which assets truly pose the greatest risk to the safety and soundness of this industry. 

Against this backdrop of uncertainty, it makes more sense to maintain general capital requirements than it does to provide regulators, financial institutions and the general public with false assurances that institutions are well capitalized.  In short, if it was up to me, we would scrap NCUA’s proposal all together not because the proposal is so flawed, but because risk-based capital doesn’t work as advertised.

April 8, 2014 at 8:28 am Leave a comment

Matz to Home-Based CUs: Drop Dead

With the tone of a parent anxious to get their free-loading college graduate to get his own place, Chairman Matz proclaimed Friday in an interview with CU Times that the days of the erstwhile home-based credit union are over.  Not withstanding the fact that the regulation requiring existing home based credit unions to find office space within two years is still pending, Matz told CU Times that as credit unions grow “I don’t think there is any justification for having a financial institution in somebody’s house.  I really think those days are over.”

As for those of us who believe that home-based credit unions are an important part of credit union history, Chairman Matz said, basically, what’s your point?  She stole one of my favorite metaphors when she pointed out that even though the “buggy whip was useful in its time, it’s not useful anymore. . .”

A few quick thoughts:

  • Of all the issues for NCUA to get fired up about, why, why, why is the Chairman so fired up about home-based credit unions?  There are approximately 7 such credit unions in New York State and nationwide, they represent a miniscule fraction of the industry.  Does their continued existence seriously pose a threat to the safety and soundness of credit unions?  If so, the industry is in much worse shape than I thought.
  • Do home-based credit unions really pose a safety threat to examiners?  Of course not.  Unless there is an epidemic of people setting up home-based credit unions so they can prey on examiners, this argument strikes me as somewhat paranoid.  To the extent that examiners simply feel that someone’s home is not the proper place to be doing an audit, then simply pass a regulation giving examiners the authority to mandate that examinations take place outside the home, perhaps at NCUA headquarters or another credit union. 
  • Is history a good enough reason to keep these credit unions open?  You bet it is.  Chairman Matz misses the point.  If the vast majority of credit unions were still using the financial equivalent of the buggy whip, then this regulatory eviction would be long overdue.  But the vast majority of credit unions moved out of houses decades ago.  By allowing home-based credit unions to remain there, NCUA allows the industry to maintain one of the most important symbols of its unique structure and evolution.  I think it is great to be able to tell people that the cooperative structure is so simple that a group of neighbors, church members and family members can bank out of their homes if they so choose. 
  • Is there a legitimate safety and soundness concern?  Chairman Matz comes across as a tad heavy handed in dismissing the home-based credit union.  Ultimately, it’s not for her and her fellow board members to decide what office space best reflects the professionalism of the industry but whether home-based credit unions pose a risk to the beloved Share Insurance Fund.  To the extent individual credit unions, whether they are operating out of a cutting edge office park or Uncle Bob’s basement, are not conducting their business consistent with safety and soundness, then regulators have every right in the world to clamp down on their practices.  But to categorically say that an entire type of credit union should be done away with is an abuse of regulatory authority that all credit unions should be concerned about.  Besides, I think it’s great that there are still some credit unions out there whose employees can start their day in their bathrobes with a cup of coffee.  On that note, off to work.

April 7, 2014 at 7:49 am Leave a comment

What Chris Brown, Anger Management, T-B-T-F Banks and Payday Loans Have In Common

One charge that makes the Lords of Finance angrier than Chris Brown in an anger management class is the suggestion that Too-Big-to-Fail (TBTF) banks enjoy an unfair advantage over their smaller financial counterparts because they can make more aggressive loans and investments secure in the knowledge that in a worse case scenario, they will be bailed out by the American taxpayer.

The latest evidence for this hypothesis was released recently by that bastion of left-wing extremism – the Federal Reserve Bank of New York. Specifically, a paper by two of its researchers concludes that “Too-Big-to-Fail banks engage in riskier activities by taking advantage of the likelihood that they’ll receive government aid.”

In previous work, the same researchers demonstrated that T-B-T-F Banks have lower borrowing costs because people know that, the protestations of the political class notwithstanding, if these mega-behemoths can’t pay their bills the federal government will.

It’s one thing to have advantages because of your economy of scale – Capitalism is supposed to work that way – it’s quite another to be so big that the free market can’t discipline a bank’s conduct and the political class is too dependent on campaign contributions and too nervous about tanking the economy to step into the breach by building real firewalls.

Credit unions should be calling for the breakup of the banks too, not because there is any chance of this happening anytime soon, but because it underscores how hypocritical it is for the banking industry to call for the end of the credit union tax exemption while getting as much if not more government protection as any industry in America.

A less dramatic but also informative piece of research comes from the CFPB, which released a report on Wednesday analyzing a year’s worth of data on payday loans. The findings are hardly surprising but they provide a good indication of where the Bureau is headed as it gets ready to propose national payday lending regulations.

Most importantly, the Bureau confirmed that payday loans are typically not used as an isolated financial tool to help consumers through unexpected rough spots, but rather can best be seen as high-priced, medium-term loans that are great at getting people further in debt. According to the Bureau’s research, 82% of all payday loans are renewed within 14 days.

As Director Richard Cordray concluded in a speech accompanying the report’s release:

“Our research confirms that too many borrowers get caught up in the debt traps these products can become. The stress of having to re-borrow the same dollars after already paying substantial fees is a heavy yoke that impairs a consumer’s financial freedom.”

The question is what can be done about it? Even if the Bureau has the authority to establish national payday lending standards that apply not only to states but to Indian reservations, the reality is that loan sharking is the world’s second oldest profession. If payday loans are made too restrictive they simply won’t be cost-effective enough for many credit unions or other lending institutions to offer; if the restrictions are too lenient then we could end up with a classic race to the bottom with institutions having to choose between foregoing needed revenue and taking a stand against loans that are in no consumer’s long-term interest.  

Let’s continue to outlaw these predatory loans but recognize that for better or worse people need short-term loan options. A good place to start would be with NCUA’s own “short-term, small-amount lending program.” I would love to see the program fine-tuned to attract more credit unions.

 

 

March 28, 2014 at 7:42 am Leave a comment

Credit Unions Score Major Victory

Credit unions scored a major victory on Friday when a federal appeals court in Washington reversed the decision of a district court and upheld regulations promulgated by the Federal Reserve Board to implement the dreaded Durbin Amendment.  The victory means that debit card issuing credit unions don’t have to spend this morning shopping around for additional payment networks.  It also means that you don’t have to worry about even lower debit interchange fees for larger institutions indirectly impacting your bottom line.

As many of you no doubt recall, the Durbin Amendment has two major components.  First, it calls on the Federal Reserve Board to limit debit interchange fees that could be collected by institutions with $10 billion or more in assets to an amount that is proportional to the cost incurred by the issuer with respect to a transaction.  It also prohibited limiting the number of payment card networks on which debit cards can be processed to one network.  The Federal Reserve interpreted these statutory mandates with regulations mandating that card issuers offer at least one PIN-network and one unaffiliated signature debit card network.  The Board also capped debit interchange fees for larger institutions at approximately $0.24 per transaction.

In a somewhat amusing twist of fate, many of our merchant friends ended up losing money as a result of the new regulations.  They went to court and in one of the most sarcastic decisions you are ever going to read, a federal district court in Washington concluded that the Federal Reserve misread the clear intention of the statute and ordered the Federal Reserve to go back to the drawing board and devise a debit card cap which included a narrower definition of transaction costs.  In addition, the judge ordered issuers to provide merchants with two networks for PIN-based debit transactions and two networks for signature-based debit transactions. 

I’ll spare you the gory details of the Appellate Court’s analysis, which hinged, among other things, on the difference between “which” and “that,” but the bottom line is that whereas the District Court saw the Durbin Amendment as a clearly drafted legislative mandate, the Appellate Court saw that it was a poorly drafted 11th hour amendment to Dodd-Frank.  As a result, the Fed was justified in interpreting the statute more liberally than the merchants would have liked.

NCUA Board Meeting

I didn’t get to blog as often as I normally do last week, but since we’re on the topic of Legislative interpretation, I want to make one comment about last week’s NCUA monthly board meeting.  At the meeting, the Board proposed joint regulations establishing a framework for the regulation of appraisal management companies.  This joint regulation is mandated by Dodd-Frank. 

Appraisal management companies are those that serve as intermediaries for appraisers and lenders.  Interestingly, while the NCUA issued the proposal, Chairman Matz complained that NCUA is “unable to enforce it,”  According to the Chairman, “NCUA remains the only financial services regulator lacking the necessary authority to examine vendors for safety and soundness in compliance with laws and regulations.” 

This is an important admission on the part of NCUA since many of us have been criticizing it for seeking to exercise oversight over third party vendors without jurisdiction.

American Hustle

As those of you with young children no doubt appreciate, with babysitters more costly than loan sharks and a night at the movies requiring a home equity loan, this is a key time of year for my wife and I as the Oscar nominees hit the pay-per-view circuit.  On Saturday night, we watched American Hustle and all I have to say is Twelve Years a Slave better be a pretty good movie because American Hustle is one of the best movies I’ve seen in years.  In fact, it is the best movie of its genre since The Sting starring Robert Redford and Paul Newman. 

On that note, have a pleasant day.

March 24, 2014 at 8:44 am Leave a comment

Just How Much Is Compliance Costing Your Credit Union?

A recent survey compiled by George Mason University provides the most detailed evidence I’ve seen of how much increased compliance responsibilities are imposing financial burdens on small lending institutions.  Although the survey just included banks with assets of $10 billion or less, the results are consistent with what we’ve all been hearing anecdotally about the impact Dodd-Frank is having on credit union budgets.

For example, in the aftermath of Dodd-Frank, most of these banks have:

  • hired an additional compliance person;
  • changed their mortgage lending offerings as a result of QM regulations in the case of 60% of respondents; and
  • experienced an increase in their annual compliance cost at a rate of at least 5% since 2010.

Another statistic that I found interesting was that 65% of the respondents feel that Dodd-Frank is now more burdensome to comply with than the dreaded Bank Secrecy Act.

What can we make of these survey results beyond the fact that it is a great time to be in compliance?  The researchers point out that increased compliance costs are an inevitable result of Dodd-Frank.  Even though the statute was intended to address practices of larger banks, small banks can’t spread out the cost of new compliance mandates over as many employees.  I know many of you did not go into the business to deal with compliance officers all day and you view the increased regulatory burden as a distraction from the core goals of your credit union.

Conversely, since I started working with compliance issues about seven years ago, I have always been of the opinion that some credit unions have underinvested in compliance.  To the extent that Dodd-Frank has forced those credit unions to devote more staff and time to compliance, this is not a bad thing..  the better your compliance staff the more efficient your operations will be and that will positively impact your bottom line.

March 19, 2014 at 8:44 am 2 comments

How Senate’s Housing Reforms Would Impact Credit Unions

This one goes in the will miracles never cease category. 

The moribund debate about the future of the U.S. housing market was jolted to life yesterday when the U.S. Senate Banking committee announced agreement on bi-partisan legislation to reconstruct the housing industry.  There is no issue pending on the legislative horizon that could have a more direct impact on credit unions. 

First, a refresher on where we stand with housing reform.  Historically, Fannie and Freddie have performed two major functions for credit unions.  They ensure that there is a market for selling their mortgages and, since Fannie and Freddie bundle these mortgages into securities, they help keep these mortgages competitively priced   Ironically, since the mortgage meltdown, to which Fannie and Freddie contributed, the housing market has become more not less dependent on these GSEs.  For example, under Dodd-Frank, a qualified mortgage includes any mortgage that these entities are willing to purchase.  This is a huge help for credit unions since Fannie and Freddie are willing to purchase mortgages that exceed the debt-to-income cap otherwise required for qualified mortgages.  However, this QM exemption lasts only as long as do Fannie and Freddie.

In yesterday’s announcement, the Senators said that the bi-partisan effort will be based on legislation previously introduced, S.1217.  As outlined in the press release, the Senate’s proposal scraps Fannie and Freddie and replaces them with a privately funded securitization platform,  In addition, the agreement announced yesterday would create “a mutual cooperative jointly owned by small lenders to ensure that lenders of all sizes have direct access to the secondary market so community banks and credit unions are not at the mercy of their larger competitors when Fannie Mae and Freddie Mac are dissolved.”

It’s an extremely encouraging sign and a credit to our lobbyist in D.C. that the concerns of credit unions are mentioned so prominently in the press release, but the devil is always in the details so we will have to see how this translates into legislation.

And, let’s keep in mind. even if the Senate passes housing reform this year, there’s a better chance that Russia will withdraw from Crimea than there is that the House of Representatives will go along with housing reform in an election year.  The issue is extremely easy to demagogue and there are plenty of ideological purists who want to hold our for getting the federal government out of the housing market completely. This, of course, will never happen but reality doesn’t seem to matter much in Washington. 

In the meantime, the cynic in me wonders if the huge amount of money being generated by Fannie and Freddie for the federal government will make it more difficult for policy-makers to scrap the existing system and implement the needed reforms.  Stay tuned.

March 12, 2014 at 9:06 am Leave a comment

3 Examples Of Confidentiality And Its Limits

One of the trickiest questions facing businesses of all sizes, regulators, lawyers and policy makers is how to draw a line between encouraging the disclosure of information in an age when a smart phone gives an employee access to more information than imaginable just five years ago but the need for confidentiality is as important as ever. 

Example 1:  credit unions are justifiably concerned over NCUA’s decision to give the public access to a risk-based net worth calculator designed to give credit unions a snapshot of how they would fare under the agency’s proposed RBNW framework.  NCUA justifies its decision to make the calculator publicly available by stressing the need to have an informed public debate on this important issue. 

Given the agency’s steadfast commitment to public discourse, I find it odd that it takes the agency two weeks to make an online video of its monthly board meetings available.  If you want to take a look at NCUA’s February 20th board meeting, it is available now.  There are people like myself for whom real time access to NCUA’s decisions and explanations as to why they are making the proposals they are making would be invaluable. 

NCUA should take its commitment to openness to the next logical level and start offering real time broadcasts of its monthly meetings.  If the NCUA truly believes that the public deserves real time access to an individual credit union’s potential net worth then surely that same public deserves timely information about NCUA’s latest regulatory initiatives.

Example 2:  We’ve all been there.  You’re sitting around the dinner table talking to your wife about the day’s events when you realize that your kids are listening to your every word.  You explain to them that there is some stuff that just stays within the family.  Do you really think this warning works?  I once talked to a pre-school teacher who told me that she knows more intimate details about her school kids’ parents than she would ever want.  

Many of you have probably already heard about a recent case in Florida in which a father successfully sued his ex-employer claiming age discrimination.  As is common in these cases, $80,000 of the settlement was contingent on the father neither “directly or indirectly” disclosing the terms of the agreement to third parties.  No one bothered explaining this to the ex-employee’s 20-year old daugter, who proudly reported her father’s victory to her 1,200 Facebook friends, replete with the admonition that the ex-employer should “SUCK IT.”  What I didn’t realize until I read the case was that the court’s ruling ostensibly had nothing to do with the Facebook post.  The father violated the agreement as soon as he talked about the settlement with his daughter.  However, on a practical level it is doubtful that the father’s indiscretion would have cost him $80,000 in the pre-Facebook era.  As for the 20-year old daughter with 1,200 friends, perhaps they can offer her some extra summer jobs as she may very well be paying for her own college education from here on in.

Many of you have to sign off on confidentiality agreements either as part of your employment contracts or legal settlements.  This case underscores the importance of well-drafted confidentiality clauses in the age of social media.  Whereas contracts typically use somewhat generic language prohibiting both direct and indirect disclosures, I wouldn’t be surprised if lawyers start seeking greater flexibility on behalf of executives entering into contracts.

Example 3:  Merchants in Texas, Florida and California recently filed lawsuits to invalidate state level laws banning surcharges on credit card purchases.  A group of merchants already won a similar lawsuit invalidating New York’s credit card surcharge prohibition (518 NY General Business Law).  That case is currently being appealed. 

In the New York case, the plaintiffs successfully argued that the credit card surcharge prohibition violated their first amendment rights.

March 7, 2014 at 9:00 am Leave a comment

Beware of Zombie Properties

The great Boston Celtic Center Bill Russell once commented that fans don’t think they react.  All too often I think the same can be said of our elected representatives. 

If you make mortgages in New Jersey, you should take a look at .A347, which overwhelmingly passed that state’s assembly late last week.  The bill is the latest attempt to deal with the serious problem of so-called zombie property.  This is property which has been abandoned following the commencement of a foreclosure but for which no foreclosure has been completed.  Localities not only in New Jersey but New York have been advocating for the authority to make the foreclosing lender maintain the property during the foreclosure process.  Attorney General Eric Schneiderman is seeking a similar approach for New York.

The legislation passed by New Jersey’s Assembly mandates that a creditor that files a notice to foreclose on residential property that subsequently becomes vacant may force the lender to cure any violations regarding state or local housing codes.  Keep in mind the views I express are mine and do not necessarily reflect those of the Association, let alone the good credit unions of New Jersey.  The most troubling aspect of this approach is that the lender is being asked to take responsibility for property it does not own.  Secondly, by mandating that the abandoned property be brought up to code the lender is not being required to simply maintain property but improve it.  Finally, what is the NJ Legislature going to do in those situations where a home owner seeks to reclaim property for which the foreclosure process is yet to be completed.

According to the National Association of Realtors, as of 2013, there were 300,000 zombie properties across the U.S.  I would bet you that those properties are disproportionately in states with drawn out foreclosure processes.  Rather than make lenders responsible for property they do not own, housing advocates should take a look in the mirror and realize that so-call foreclosure protections needlessly delay the transfer of property to lenders and indirectly drive up the cost of homeownership for everyone. 

My compromise position for the good people of New Jersey is to couple any requirement for lender foreclosure maintenance with an expedited foreclosure process for the affected property.

March 3, 2014 at 8:49 am Leave a comment

Ding Dong, the Witch is Dead

Well, it’s all but official that no major tax reform, let alone tax reform putting the credit union tax exemption at risk, will take place this year. Not only is the credit union tax exemption not to be included in draft legislation but no lesser an authority than Senate Minority Leader Mitch McConnell took tax reform off the table for this year. While this is, of course, good news, given the amount of time and energy that the industry has devoted to the issue over the last several months, the bankers have still scored a partial victory. We’re in a mid-term election year and we have yet to get serious traction on what I consider the single most important issue facing the industry: the need for secondary capital.

Why is secondary capital so important? Let me count the ways. First, it simply makes no sense for credit unions to be penalized while growing in popularity. This is precisely what happens every time a member opens an account in this low interest, moderate growth economy where it is extremely difficult to make money off other people’s money. If credit unions are going to grow then they need the ability every other financial institution has to seek out investors.

Second, any doubt as to the crucial need for secondary capital has been dispelled by the NCUA’s Risk Based Net Worth regulatory reform proposal. In its simplest form, there are two ways a credit union can improve its risk weighting. It can either reduce its assets or increase its capital. But unlike the nation’s largest banks, our largest credit unions don’t have the opportunity to seek out additional capital. In short, if NCUA’s proposal goes forward it will put the brakes on the growth of credit unions whose only sin is to be large.

I understand how divisive the secondary capital debate is within the industry. Credit unions are, at their core, mutual institutions. They have to remain that way if they are going to continue providing members a unique financial experience. But secondary capital reform can be introduced in ways that maintain the essence of the credit union movement, which is one person one vote. If an institution is willing to invest in a credit union it would only do so against the backdrop of restrictions that give it no more or less influence than any other member of a given credit union.

Let’s keep in mind that low income credit unions can already take secondary capital and no one can seriously suggest that these institutions, in the aggregate, do not advance the core missions of the credit union movement.

Tax reform is like one of those Friday the 13th movies. The villain never really dies. The industry must, of course, remain vigilant. But, we don’t want to win the battle and lose the war by letting concerns over the credit union tax exemption crowd out other important pieces of the credit union agenda.

February 26, 2014 at 9:04 am Leave a comment

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Authored By:

Henry Meier, Esq., Associate General Counsel, Credit Union Association of New York

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