New York to CU’s: Don’t Forget About Us
Last week I saw one of the best examples in years of why it is so important for all credit unions in New York that there be a viable State Charter. In the aftermath of NCUA’s decision to amend its field of membership regulations to give credit unions greater flexibility in taking on additional members, Department of Financial Services, Superintendent Maria T. Vullo, issued a statement in which she pointed out that NCUA made these changes, in part in response to the more flexible FOM’s offered by states such as New York. She also encouraged “all credit unions to take advantage of New York law to provide financial services to all New Yorkers and pledges to timely review all applications by new or existing credit unions seeking to be chartered by New York State”.
The Press Release warmed my cynical heart for several reasons. First, the Superintendent is spot on. NCUA Board members were refreshingly frank in acknowledging that they were putting forward FOM reforms, in part, to keep the federal charter as attractive as possible. New York is an anomaly in that all but 17 of its credit unions are federally chartered. Nevertheless, its FOM makes this state among the most attractive for field of membership purposes because credit unions can mix- and- match community, association , and employer groups. It’s possible that federal law gives your credit union all the flexibility it needs, but if charter expansion is a primary concern, the state’s law is worth taking a look at.
Second, it is great to see the DFS openly encouraging credit unions to consider taking advantage of New York’s Law. There is a lot more that we can accomplish for all credit unions with a truly committed state level partner.
Third, while I am encouraged by the DFS’s statement, both the legislature and the DFS should remember that new mandates have consequences. For example, any Federal Credit Union thinking of converting to a state charter would be nuts to do so before the state finalizes its new cybersecurity regulations and explains precisely what it expects credit unions to do to comply with this surprisingly detailed mandate.
Does anybody really know what time it is?
I love the extra hour sleep but could someone please explain to me why, in a country as technology savvy as our own and the internet capable of telling me that I’ve run out of milk we can’t come up with a way of automatically updating all clocks to reflect the actual time? As I was getting ready for work this morning, I had to repeatedly remind myself that I wasn’t running an hour late. By the way, why do they make car clocks so difficult to change that only James Bond can make it look easy?