Posts tagged ‘mbl’

Post Mortem Of Taxi CU’s Likely To Result In Greater MBL Scrutiny

Even if you have never been anywhere near a medallion loan, if your credit union engages in member business lending, expect even more scrutiny of your lending practices. That’s my overarching takeaway after reviewing the report of NCUA’s inspector general analyzing the demise of Melrose CU, LOMTO CU and Bay Ridge FCU which costs the share insurance fund $765.5 million. I’m going to highlight those parts of the report which might have the greatest operational impact on credit unions, particularly those that aggressively offer member business loans.

Get used to hearing more about NCUA’s Enterprise Risk Management. The inspector general recommends that NCUA institute a more formal process to identify and document concentration risk both within credit unions and among groups of credit unions to spot loan “concentrations” that could potentially pose a significant risk to the Share Insurance Fund.

Expect more aggressive examinations even if your credit union is doing just fine. Prior to 2014, all three of these credit unions were well capitalized. According to the inspector general, examiners involved in the supervision of these credit unions felt they had insufficient grounds to take formal enforcement actions against these credit unions for repeatedly failing to comply with Documents Of Resolution because the credit unions enjoyed profitability and strong capital positions. Not true concluded the inspector general who notes that the existing regulatory framework in “no way limits the authority of the NCUA Board or appropriate state official…to take additional supervisory actions to address unsafe or unsound practices or conditions” irrespective of how well capitalized credit union is.

Expect more scrutiny of concentration limits. As I know readers of this blog are well aware, credit union MBL balances are generally capped at the lesser of 1.75 of a credit union’s net worth or 12.25% of the credit union’s total assets. One of the exceptions to this requirement is for credit unions “that have a history of primarily making member business loans” as of September 1998. Ironically this provision was included in the law primarily to accommodate taxi credit unions.

However all credit unions are still subject to 12 CFR 723.8 which limits the aggregate amount of outstanding business loans which can be lent to any one member or group of associated members to 15% of a credit union’s net worth unless they get a waiver. The inspector general’s report is critical of the failure of examiners to take steps against these credit unions for not complying with this prohibition. It complains that credit union management was allowed to disregard examiner findings.

For me, the bottom line is that regulators have concluded there are more lessons to be learned from the demise of these credit unions than simply a failure to recognize the threat posed by Uber and Lyft before it was too late. Like it or not, no matter how responsibly your credit union executes its MBL program, expect examiners to put your program under the microscope if they haven’t done so already.

April 3, 2019 at 9:30 am 2 comments

Independent Bankers Sue NCUA Over Pending MBL Regs.; Plus My Top-Secret Plan For CU Growth

Today was going to be a real special blog post.   I was not only going to  reveal my top-secret plan for defeating ISIS,  but, as an added bonus,  my top-secret plan guaranteeing  the credit union industry grows and prospers without a single merger for the next 50 years.  But I’ve  decided that I will only reveal these plans after you elect me President.

In the meantime, I  will content myself with  telling you that the Independent Community Bankers filed a lawsuit in Northern Virginia yesterday alleging that NCUA abused its discretion when it promulgated regulations revising Member Business Loan regulations. Strip away all of its hyperbole, and the complaint comes down to an assertion  that NCUA doesn’t  have the authority to exclude loan participation interests from the calculation of the  credit union MBL loan cap. The bankers are seeking to block the regulations from taking effect in January.

With apologies to those of you for whom  this is as basic as the arithmetic my second grader will be learning this year, since 1998 the Federal Credit Union Act has limited  the aggregate amount of member business loans   a federally insured credit union can make at any time to the lesser of 1.75 times the actual net worth of a credit union; or  1.75 times the minimum net worth required for a credit union to be well capitalized. (12 USCA 1757A).  Under existing regulations participation interests in member business loans and member business loans purchased from other lenders count against a credit union’s aggregate limit on net member business loan balances.  CUs can  purchase participation interests that put them over the MBL cap but only  with NCUA’s permission. 12 CFR 723.16(b).

So, what has our banking counterparts so fired up?  The regulations that start to take effect in January stipulate that participation interests in business loans held by credit unions will be classified as commercial loans as opposed to MBL loans and will no longer be counted against the cap.   The change only  applies to loans that a credit union does not originate.

According to the independent bankers, this regulatory change amounts to a violation of the Administrative Procedures Act which prohibits regulators from promulgating rules “not in accordance with the law.” They argue that based on NCUA’s previous interpretation a cu holding a participation interest  should be counted against the cap.

The problem is that the Supreme Court recently reaffirmed that regulators have the right to change their regulatory interpretations even without going through a formal comment and review process. Perez v. Mortgage Bankers Ass’n, 135 S. Ct. 1199, 1210, 191 L. Ed. 2d 186 (2015).  In addition, NCUA’s new regulation is consistent with the English language.  According to Merriam Webster online Making is defined as   “the action or process of producing or making something.” A cu that originates a loan is making a loan; a cu that purchases a portion of that loan isn’t producing anything.

And the Independents won’t even get  to the merits of their case unless they can show how their members have been harmed in very specific ways.  This is a tough one: There is plenty of evidence to suggest that small businesses are having a tough time finding banks willing to make them loans. Are bankers really being squeezed out of the market because some credit unions purchase participation interests? Whaat?

Pure speculation on my part but I suspectt  that the Independents are laying the groundwork for a further legal assault on the NCUA if and when it finalizes FOM regulations. Plus, even if they lose this lawsuit they will  use it as another example to Congress  of how the NCUA helps credit unions  too much.  I guess they have forgotten about the imposition of sophisticated risk based capital requirements on larger credit unions.

For credit unions  it’s important not to overreact to this latest banker provocation. It’s just the latest example of the banking industry seeking to limit the choices  of Main Street America so that it can maximize its own profits.

 

 

September 8, 2016 at 8:51 am Leave a comment

MBL Proposal Will Only Be as Good as Its Guidance

The blog is going on its summer hiatus. I could say that I am using the upcoming week to help get the kids ready for school, but the truth is that with two fantasy football drafts to prepare for I need to take a break from analyzing credit union news and regulations to ponder really important questions like: Who will Green Bay’s primary receiver be this year? Are there any running backs worth drafting in the first round? And just how many weeks will Tom Brady miss?

But before I get started I wanted to remind you of NCUA’s proposed MBL amendments and why they are even more important than they appear to be.

In case you missed it, NCUA is proposing to give credit unions greater flexibility in making MBL loans. It is moving to what it describes as a principles-based approach under which the existing detailed mandates will be replaced with a requirement that credit unions actively engaged in making MBL loans, or that are over $200 million in assets, design and implement a broad range of policies and procedures addressing MBL lending. For example, the existing requirement that a credit union have at least one person with two years of experience underwriting its MBL loans would be replaced with a requirement that staff have experience directly related to the specific types of commercial lending in which the credit union is engaged. This is including, but not limited to, demonstrated experience in conducting commercial credit analysis and evaluating the risk of a borrowing relationship using a credit risk rating system.

Credit unions will be evaluated on the basis of “supervisory guidance to examiners, which would be shared with credit unions, to provide more extensive discussion of expectations in relation to the revised rule.” Which brings me to why this proposal is even more important than meets the eye: it will give both credit unions and the NCUA the opportunity to hash out once and for all the difference between supervisory guidance and regulations. Based on my reading of the case law-and keeping in mind this is my opinion- from a compliance standpoint there is no practical distinction between an agency’s interpretation of its regulation and a regulation itself.

For example, earlier this year the Supreme Court upheld the right of the DOL to issue an interpretation making mortgage originators nonexempt employees eligible for overtime. (Perez v. Mortgage Bankers Ass’n, 135 S. Ct. 1199, 1212, 191 L. Ed. 2d 186 (2015). The mortgage bankers argued that this “interpretation” was an amendment to a rule which could only be changed after notice and comment. The Supreme Court said that a regulation is only amended when language is changed. As Justice Scalia commented in a concurring opinion “[a]gencies may now use these rules not just to advise the public, but also to bind them. After all, if an interpretive rule gets deference, the people are bound to obey it on pain of sanction, no less surely than they are bound to obey substantive rules, which are accorded similar deference. Interpretive rules that command deference do have the force of law.”

Also remember that even when an agency interpretation is intended to give a credit union greater flexibility that same guidance gives examiners greater flexibility to determine if a credit union is acting properly.

Now don’t get me wrong. I’m not saying that NCUA isn’t genuinely interested in giving CUs greater flexibility. It is, and it deserves a tremendous pat on the back for its willingness to do so. But because the new MBL framework will only be as useful as NCUA’s guidance and examiner oversight, an ongoing dialogue with the agency is crucial. Everyone needs to be on the same page.

That’s why industry stakeholders, including the New York Credit Union Association, are urging NCUA to submit its MBL guidance to a formal notice and comment period. Doing so will help everyone understand just how much additional flexibility they have to make MBL loans. In addition, everyone has to understand that there will be bumps along the road. Adults have to be willing to sit around a table and talk out their differences.

On that note – see you next Tuesday as the blog marks its fourth anniversary.

August 27, 2015 at 9:08 am Leave a comment

What’s Not To Like About NCUA’s MBL Reforms

On paper, the NCUA’s proposed shift away from a prescriptive MBL framework to a principles-based framework is everything credit unions could have hoped for and more. It does away with mandates like the two-year experience requirement and instead requires that credit unions that have $250 million or more in assets or that actively engage in MBL lending have detailed policies and procedures. But my guess is that while many credit unions will find the changes a welcome relief from certain aspects of compliance; others will soon be longing for the good old days of detailed MBL regulations. Here is why.

  • Most importantly, with great power comes great responsibility.  The changes give responsible credit unions greater flexibility on the assumption that credit union boards and senior management have the expertise to properly administer complex MBL programs.  On a practical level, your credit union should maintain many of the constraints existing regulations already impose on them.  All that NCUA is allowing you to do is responsibly modify those policies to reflect the unique attributes of your credit union.
  • Credit unions really won’t know how much flexibility they have until they start seeing the guidance from NCUA that will be used as the basis for future examinations.  Take a look at some previous guidance issued by the NCUA and you will soon realize that they can be just as prescriptive as regulations but without the benefit of having gone through a comment period as is required of proposed amendments.
  • Examiners will also have more flexibility.  One of the most common refrains of credit unions is that there is too much inconsistency among examiners.  A principles-based system could produce even more confusion. If the system works properly, examiners will justifiably ask tough questions to assess a credit union’s due diligence.  For example, it is appropriate for an examiner to ask what criteria they use in assuring that their MBL staff is qualified.  It is not appropriate for an examiner to confuse his or her beliefs as to what constitutes the “best criteria” with the only safe and sound way of making MBL loans.
  • Principles-based regulation is not without its risks.  Whereas your erstwhile compliance officer can now go to her erstwhile CEO and say “You can’t make that loan because it violates an NCUA regulation,” under the principles-based approach she can only say “You shouldn’t make that loan because it violates our lending policies.”  When times are good, bending of the rules won’t matter; but if we learned anything from 2007-08 it’s that we usually won’t know that the good times have ended until it’s too late.
  • The proposal hastens the divide between big and small credit unions.  Credit unions with $250 million or more in assets will have to implement detailed policies.  Those with less than $250 million in assets that are not regularly originating MBL loans will not.  On a policy level, this makes sense.  But in the name of mandate relief, the industry is willingly going along with proposals that divide big and small credit unions more effectively than bankers ever could.  Every time the industry agrees to further divisions along asset lines, it is making it that much easier for Congress to one day tax larger credit unions.

June 25, 2015 at 8:55 am Leave a comment

What Dustin Johnson Teaches Us About The MBL Rule

There are two approaches to being a caddy of a professional golfer.  One time I went to the Woman’s US Open on Long Island and was surprised by how involved some of the caddies were, not only in picking out clubs but in helping to position some of the world’s best players before they shot.  They did everything but swing.   This is a prescriptive approach to caddying:  intricately lay out every step taken to insure the best results.

Then there is a principles-based approach.  The caddy recognizes that he is simply assisting someone who already knows what he is doing.  He hands out the proper club and might suggest a putting line but you hardly seem him in the picture.  His goal is to stay out of the way of his charge’s proper execution.

On Thursday, the NCUA not only proposed radical revision to its Member Business Loan (MBL) regulations, but also a radical revision of how it regulates MBL activities.  Specifically, NCUA is proposing to shift from a prescriptive approach to a principles-based approach.  This means that many of the nettlesome provisions of the MBL loan process will be eliminated.  Those credit unions most actively involved in MBL loans will instead have to have detailed policies and procedures that are unique to their membership and lending practices.  Examiners will judge these practices against guidance developed by NCUA.  (http://www.ncua.gov/about/Documents/Agenda%20Items/AG20150618Item6b.pdf)

For the record, I think it’s a great and original idea that is well worth trying, but whether it ultimately has a positive or negative impact will vary widely based on the competency of individual credit unions and how much flexibility credit unions in general are given by examiners.  Some credit unions will relish the increased flexibility; others will find the lack of specific bright line rules less helpful.  In today’s blog, I’m going to go over the positives of the proposal and in tomorrow’s I will outline the potential negatives.

Just how radical is this proposal? The amendments clarify that the MBL cap is a multiple of a credit union’s net worth requirements, not a fixed percentage of assets. Another part of the proposal that could provide MBL cap relief has to do with the introduction of a commercial loan category.  Commercial loans are loans that wouldn’t be counted against a credit union’s MBL cap.  For example, under existing regulations a mortgage to purchase a second home that is not the borrower’s primary residence is an MBL (assuming the mortgage is for at least $50,000).  Such loans would be classified as commercial loans and not counted against the MBL cap.  The idea closely tracks NCUA’s Risk-Based Capital proposal.

But wait . . . there’s more.  Currently, there is a host of concentration limits placed on MBL loans and a corresponding list of available waivers.  The proposal would do away with seven such limits and waivers. This means, for example, that credit unions would no longer have to get personal guarantees for their loans; would no longer be subject to a specific loan to value ratio and would no longer have to have someone with at least two years of experience overseeing your MBL program.

If you participate out portions of your MBLs, another change has to do with the definition of “associational borrowers.”  Current regulations limit how much money can be lent to any one such borrower and by proposing a narrower definition your credit union will have greater flexibility in making and selling loans.

Okay, you ask, so what is the catch?  In place of the existing prescriptive regulations, credit unions will have to have detailed policies explaining why they structure their MBL programs the way they do.

The good news is that you no longer have a regulatory requirement to get personal guarantees when you make MBL loans. The bad news is that your policies and procedures better explain the circumstances under which the credit union grants such loans.  The good news is your credit union will no longer have to have someone with two years of MBL experience.  The bad news is it will need policies and procedures outlining the minimum qualifications of its MBL employees.  Examiners will be the ultimate arbitrators of your efforts.

Credit unions with both assets less than $250 million and total commercial loans less than 15 percent of net worth that are not regularly originating and selling or participating out commercial loans would be exempted from creating and implementing these more involved procedures. Still this new approach means big responsibilities for larger credit unions and their boards.  More on that tomorrow.

 

 

 

 

June 23, 2015 at 10:08 am Leave a comment

What is the Real MBL Cap?

At the Association’s Annual Convention the man who stole the show was none other than NCUA’s newest board member, J. Mark McWatters. Usually, attendees listen in respectful silence as the board member du jour explains how he feels the pain of being over-regulated while in the next breath explaining the need for additional regulation.

But in McWatters, we have at least one board member who sincerely believes the fewer regulations, the better. And, he seems to believe that when regulations are necessary they should be focused as narrowly as possible on the issue they seek to address. I’ve never seen any audience respond so well to a lawyer in my life, especially one who feels the need to mention he’s a lawyer about once every thirty seconds. His message was like catnip in a room full of kittens.

I also drank a good bit of his Kool-Aid. The part of his speech that got me the most intrigued was when he raised the possibility that NCUA could, if it wanted to, raise the MBL cap, at least for larger credit unions, without additional legislation. This is not a theoretical discussion. At its Board Meeting this Thursday, NCUA will be unveiling proposed MBL reforms and McWatters urged the audience to scrutinize and comment on this proposal.

First, a quick primer. The Federal Credit Union Act does not explicitly cap Member Business Loans (MBL) at 12.25% of a credit union’s assets. Instead, it caps MBLs at the lesser of 1.75 x the actual net worth of the credit union or 1.75 x the minimum net worth required for a credit union to be well-capitalized. Since credit unions have to have at least a 7% net worth to be well-capitalized, we have all gotten used to assuming that the MBL cap is 12.25%. However, take a closer look at the statute, as McWatters urges, and here is where it gets interesting.

As we all know from NCUA’s Risk-Based Capital proposal, NCUA feels it has the authority to define when complex credit unions, which it is seeking to define as those with $100 million or more in assets, are well-capitalized. If NCUA has its way, such credit unions will be well-capitalized only if they have a minimum Risk-Based Capital ratio of 10%. An argument can be made that based on a plain reading of the statute, these credit unions’ MBL cap would be 17.5%. Intriguing, isn’t it?

Of course, as NCUA has made abundantly clear, reasonable minds can differ about what constraint the Act actually places on credit unions. Still this interpretation is certainly supported by the statute and deserves to be given serious consideration by the entire Board.

June 16, 2015 at 8:45 am 1 comment

Congress Passes ATM Disclosure Bill

Even if it threw salt on the credit union MBL wound, credit unions got a bit of welcome news yesterday when the House passed and sent to the President for his signature H.R. 4367, which eliminates the federal requirements under the Electronic Fund Transfer Act that financial institutions conspicuously place physical ATM fee notices.  By doing away with this requirement Congress gave a well deserved kick in the gut to bottom feeding lawyers everywhere, some of whom were developing a specialty in starting class action lawsuits against credit unions that didn’t post this required notice even though existing electronic disclosures during ATM transactions provided more than enough notice to consumers.

My compliance brethren have been quick to point out that New York has its own disclosure requirement.  So, if your ATM branch is located in New York, continue to post disclosure signage.  However, removing the New York requirement is one of our top legislative priorities and with the federal law about to be amended, this should take much of the wind out of the sails for this type of litigation.

Now for the bad news.  The Senate voted to proceed to debate on the merits the Transactional Account Guarantee (TAG) bill pushed by community and independent bankers, which extends total FDIC insurance coverage to non-interest bearing accounts in excess of $250,000.  This means that not only has the credit union industry been unable to get this bill tied to MBL legislation, but let’s face it, the bankers demonstrated an impressive amount of political muscle by getting strong bi-partisan support for their top legislative agenda item in the lame-duck session.  On the bright side, passage in the House is far from certain and the cynic in me wonders if the success of the Senate vote, in part, reflects a political calculus that Senators could vote yes for the bill knowing that it has little chance of becoming law.

 

December 12, 2012 at 7:34 am 2 comments

What Can Be Gleaned From The Town Hall Meeting?

Yesterday, NCUA Chairwoman Debbie Matz and senior staff fielded questions from credit union personnel for an hour and a half.  Here are my takeaways.

It appears that the Board will decide at its November meeting that credit unions will not have to pay a share insurance fund premium next year.  But remember this is distinct from the assessment that credit unions pay into the Corporate Stabilization Fund.  The industry is currently committed to paying into that fund until 2021.

The agency is working on a guidance to clarify when a Document of Resolution should be issued as opposed to just an examiner finding.  In order for the guidance be successful, NCUA is trying to define when a credit union’s failure represents a material risk to the safety and soundness of the credit union.  Judging by the number of questions about examiners and examination procedures, as well as the perception among some credit unions that examiners are more aggressively issuing DOR’s than they had in the past, a more uniform definition would be in everyone’s best interest.

NCUA will be issuing guidance on expanded use of MBL exemptions.  While it would, of course, be better to see Congress raise the cap, NCUA can expedite the process by granting MBL waivers and reminding credit unions that such waivers are available.

As I pointed out in a previous blog, one of the real potential advantages to those credit unions with under $30 million in assets being classified as “small” credit unions for regulatory purposes-as NCUA proposed at its last meeting – is the possibility that NCUA will expand its plan to streamline the examination process for well functioning credit unions with under $10 million in assets to this larger class of small credit unions.  This may happen, and is certainly under consideration, but is by no means a done deal.

I was happy that someone asked for an update on NCUA’s consideration of authorizing the expanded use of derivatives by credit unions for the purpose of hedging against interest-rate spikes.  It seems to me that if you’re going to stress the dangers posed by interest-rate volatility, then you have to provide credit unions the financial tools to deal with the problem.  Properly used, interest rate swaps could help guard against too much exposure to long-term mortgages.  However, the speakers pointed out that the use of derivatives requires a degree of sophistication not only for the credit unions that would use them but for the staff that would be responsible for monitoring their use.  The bottom line is NCUA seems to recognize the benefit of these products, but is still trying to decide if the benefit is outweighed by the potential costs both to the safety and soundness of individual credit unions and the examination process for the agency.

Finally, the webinar talked about a legal opinion letter issued yesterday opining that NCUA may approve a credit union’s request to receive a change in its charter and subsequently merge with another credit union with the same type of field of membership.

Have a nice weekend, I’ll be popping back into your inbox on Tuesday.

 

October 5, 2012 at 7:10 am Leave a comment

Small businesses facing credit crunch

The latest evidence of the need for lifting the Member Business Loan cap comes from that organ of credit union propaganda, the Federal Reserve Bank of New York.  According to a study it released yesterday, “[T]he New York Fed’s analysis suggests that there’s demand that banks aren’t meeting, even as weaker businesses are opting not to borrow.”  In addition, demand is greatest for loans of $100,000 or less in the New York area, precisely the market that credit unions would be most able to help.

The bankers’ opposition to raising the Member Business Loan cap is based, in part, on a chicken vs. egg argument.  They argue that they are more than willing to supply loans if only more businesses were applying to get them.  But according to the report, more than a quarter of businesses surveyed by the bank indicated that they were so discouraged by the higher lending standards applied to them by banks that they aren’t even bothering to apply for loans in the first place.  Common sense tells you that in this environment we should be maximizing the number of lenders willing to provide loans to small businesses.  Hopefully common sense will not be trumped by banker opposition and political myopia.  It’s a long shot, but I can dream.

Standard Chartered Agrees to Fines

Yesterday afternoon, the Department of Financial Services won its game of regulatory chicken with Standard Chartered when the UK’s fifth largest bank agreed to pay a $340 million fine and appoint an outside monitor to settle allegations that it had intentionally circumvented American sanctions against Iran by using its New York branch to funnel funds to that country.  Although the DFS’s actions were harshly criticized in Britain and I half expected J.K. Rowling to criticize the regulator, at the end of the day, the bank settled rather than face a hearing at which it could have lost its New York licence.  The settlement is a big victory for DFS. which now demonstrates that it is a force to be reckoned with and Governor Cuomo, who can point to the settlement as vindication of his push to create the DFS.  If the Governor does run for President, the DFS has just given him one of his  talking points.

August 15, 2012 at 6:58 am Leave a comment

The $800 trillion fraud?

Four amazing things happened in the week I went on vacation: the Supreme Court upheld the Affordable Care Act, physicists discovered one of the most essential particles for the building of the universe, a bank CEO named  Dimond resigned under pressure over the LIBOR scandal, and my Verizon cable guy actually showed up on time.

Don’t underestimate the impact that LIBOR could have.  First, credit unions use the index to establish interest rates on a wide range of products.  Credit unions, of course, are not unique in using this rate, which is used as the benchmark for an estimated $800 trillion worth of financial instruments.  We don’t know all the facts yet.  But if, as appears likely, Barclays was not alone in manipulating the LIBOR, the liability facing the world’s largest banks could make the settlement with state attorneys general look like small claims court.  As one anonymous chief executive of an international bank told the Economist, “this is the banking industry’s tobacco moment. It’s that big.” For example, if a member paid more on a home equity loan or your credit union received less interest on the loan because banks lied about their borrowing costs, then someone should look into getting their money back.  This is the most blatant example yet of banker disconnect from main street.  Anyone who doesn’t think that we need to better regulate major banking institutions after finding out that they see nothing wrong with price-fixing,  doesn’t believe in capitalism, let alone basic fairness.

Community Banks not doing enough to stimulate the economy?

This is from Reuters this morning:  Community banks “trumpet the small business loans they make because they spur job creation, a big deal in this economy with a 8.2% unemployment rate. But not every community bank is the quintessential hometown lender portrayed in Frank Capra’s “It’s a Wonderful Life”… There are more than 800 Community Banks that…lend less than half of their deposits.”   Camden Fine, President of the Independent Community Bankers of America, and one of the primary opponents on the new business lending expansion for credit unions is quoted as saying “[n]early all Community Banks are privately owned, usually by a single-family.  If the owner is risk-averse, then so is the bank… The FDIC can’t make a bank lend money.  It’s a free country.”

I couldn’t agree more, which is why I believe that credit unions should be free to make small business loans unencumbered by a government-imposed lending cap.  And one more thing:  if so many small community banks are not making loans to begin with, who is the member business lending cap really protecting in the first place?

How I spent my summer vacation

For those of you heading out to Cape Cod for your summer vacation I strongly recommend a visit to the Four Seas Homemade Ice Cream Parlor in Centerville.  It’s some of the best ice cream I’ve ever tasted.  My brother-in-law and his father, who actually lives on the Cape, assures me that their chocolate frappe may be the best concoction since water.

Incidentally, I also got to my first Met game at Citi Field and I have to admit it’s the nicest minor-league ballpark that I’ve ever seen.

July 9, 2012 at 8:15 am 4 comments

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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