News & Highlights

DREAM Big Contest!

After last week’s interview with Kirk Drake, CEO of Ongoing Operations I bought a copy of his new book, CU 2.0: A Guide for Credit Unions Competing in the Digital Age. We are truly fortunate to have this book in our industry. How often do you see a “Credit Union” book on amazon.com?

We give it two-thumbs up, a gold star, the credit union Pulitzer prize.

In the beginning of the book Kirk makes a very valid point.  in 2008, just 9 years ago, we were handed the financial world on a silver platter. Massive bank failures, mortgage loan foreclosures, customers struggling to get credit they needed while the banks raised fees. And yet credit unions market share soared from 7% to 8%. We can probably contribute some of that to the “Bank Transfer Day” Movement led by a non-credit union member in response to her frustrating relationship with B of A. We treated it as a one and done instead of seeing it as the re-charge of the credit union movement.

Why did that happen? Because we continue to operate in the old model which is ripe with over compliance and risk aversion. Credit unions are not known for being innovators. At our very best we are fast-followers. My favorite chapter is “Death by a Thousand Cuts” where Kirk describes the Finctech world in a way that I actually kind of understand Bitcoin now. We are in the business of moving money and yet these Fintech players like PayPal, Apply Pay, Venmo, even Starbucks are “using” our member’s money with little or no regulation to provide the level of service they have come to expect. Right now, in the click of a button or a swipe of my phone I can pay for something or buy something. In the meantime many credit unions still require a “wet signature” on a loan application.

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Five Things Your Credit Union Needs to Learn From a Bouncy House

Every year our Volunteer Fire Department hosts a 4th of July Picnic in our tiny little town complete with a parade, barbecue, burgers and dogs, kid’s games, silent auction, music and of course a big fireworks display. This year I was in charge of the kid’s activities. I don’t have kids, but I know what kids like – a bouncy house. And since our event is on the giant Town Hall lawn it’s a perfect spot to get your bounce on.

I put “Bouncy House Rentals” in the Google machine and to my surprise found there are several in the Albuquerque area. Who knew? I clicked on the first one listed, the page took too long to load and when it finally did a form popped up that said email us or call us today to get a quote. Pass. So I clicked on the second site listed. Loco Jumps. The page loaded right away.

The banner was a kid smiling and this promise: “Our Jumps are Always Clean and Sanitized.” Again, not having kids this isn’t something I was even thinking about but now that I read it, heck yes I want a clean and sanitized bouncy house.

The only other copy on the main page was this:

We provide the best rentals, we’re always on time, and always professional. So if your looking for the best jumpers possible in New Mexico, reserve them below or call anytime to speak with us in person at (505) 792-6620.

You could order by date (and then see what is available on that date) or by category. Since I was renting on the 4th of July (super busy day I assumed) I went for the date. This took me to an order screen where I could plug in my start and stop time (I assume I was renting by the hour) There were quite a few houses left but Beagle Bouncer caught my eye. Here’s his description:

Cool 3D design and it has a flatter bouncing surface for more jumping fun! Also known as the Cutest Jumper there is.

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NACUSO Spotlight on Kirk Drake, CEO of Ongoing Operations

Kirk with his oldest son, Warren

This month we are focusing on a long-time member and supporter Kirk Drake who has just published his first book CU2.0: A Guide for Credit Unions Competing in the Digital Age.

PART ONE: Life Story and Experiences

What’s your current position and can you give me a brief overview of what it is you do in your work?

 I am currently the President and CEO of Ongoing Operations, LLC and founder of Credit Union 2.0.  I focus on helping credit unions engage members digitally and compete with the onslaught of regulatory and fintech challenges – or as I like to call it Credit Union 2.0.

Where did you grow up and what was it like living there? Where did you go to school?

I grew up in Southern California until I was 15 and then my family moved to Southern Oregon.  I finished high school in Grants Pass, Oregon and feel more connected to that area.  It was a small town (20,000 people) that was really isolated from the mainstream – but was amazing for grounding me and providing some amazing opportunities like starting a high school bank. After that I attended George Washington University in Washington, DC and eventually graduated from the University of Maryland University College.

What would you say most motivates you to do what you do? What are you most excited or passionate about?

 I love meeting new people (especially passionate credit union people) and helping them solve their problems.   These days I am very motivated by helping our industry become relevant.   I feel that we have missed the boat on connecting to members digitally and are at great risk of becoming obsolete to consumers.  Helping credit unions connect in their communities and online has me fired up and focused!

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Is Your Credit Union Addicted to Bad Profits?

Last week I penned a blog on what it’s like being a member of a credit union. I shared my feeling that most of us do not know what the experience is like because we are in fact employees with an account where we work. An entirely different experience.

The day after that story ran I experienced first hand how awful it is to be an anonymous member. And it was my fault – I admit it. I totally forgot that I had scheduled my quarterly taxes to debit my checking account this month and it overdrew me. Luckily I had money in savings so my credit union transferred money to cover my house payment, which came in right after the taxes. They charged me $3.00 for the transfer. Not bad. But the next day three items came in and instead of transferring one time, the computer was set up to transfer individually so the credit union could collect $3.00 each time, and, for you compliance geeks out there you know what’s about to happen next … I’m dangerously close to my 6 unauthorized transfer limit from shares. The Reg D debacle.

And so it happened the next day, two more transfers and also the day when I happen to check my balance. Not only did I hit magic number six, but then courtesy pay kicked in and the fee jumped to $30.00 to cover my cell phone bill. I’m out $48.00 in fees and I am now unable to make a transfer from shares to keep this from happening again. I call the 800 number (that boasts 24 hour service) but of course this is out of their realm of assistance and I’m told a note has been put on my file for them to transfer tomorrow for another $3.00 fee.

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Do You Know What it’s Like Being a Member of Your Credit Union?

For the first 20 years of my career I worked in a credit union. Like many of you I started as a teller and worked my way up and around the org. chart holding positions like member service rep., loan officer, collector. Then I decided to take my talents “behind the scenes” in support functions such as card services, training, and a short time in HR. I had a great boss that used to remind us that “If we’re not serving a member, than we are serving someone that is.” Such a true statement about how a credit union works.

But for those first 20 years I was never a member of a credit union.  I know what some of you are thinking “Where did I have my money? In a bank?” Heck no. I was an employee of the credit union where my checking account was. That’s an entirely different relationship.

Every morning I would check the balance and history of my checking account. Because I could. This was years before we gave members that convenience with home banking. If I wanted a loan, I knew what our loan approval guidelines were and went into the process knowing I would be approved. In fact, all member loans took a back seat when an employee stepped up. It was wonderful. I never had to stand in a teller line on my lunch hour. Never had to endure the wait in a drive-up window or worse yet listen to the horrible recording on hold for the call center. I was insulated from all the torture.

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What are CUSOs Doing?

What are CUSOs doing?  This is a very common question I hear from credit union and CUSO folks.   From our vantage point of working with NACUSO and working with hundreds of CUSOs in the past 30 years, we have a unique perspective to know the CUSO universe.  Even NCUA used to call us on CUSO industry questions from time to time.  Now that CUSOs are becoming an essential part of the credit union business model, existing CUSOs are being asked to provide more services and new CUSOs are being formed.    Will there ever come a day when we have more CUSOs than credit unions…maybe?

Since the role of CUSOs is becoming so important to the success and survival of credit unions, NCUA saw the need to know more about CUSOs.   While NACUSO and NCUA had differing views on whether CUSOs could be required to report directly to NCUA, the silver lining is a better knowledge base about CUSOs.

The good news is that the NCUA’s CUSO Registry is a searchable data base and it attempts to be as comprehensive as possible.   The bad news is that NCUA does not share much data… only the CUSO’s name, address, telephone number, web site and services.  CUSOs were nervous about NCUA sharing their proprietary data and NCUA erred on the conservative side.

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I Don’t Want to Get My Shoes Wet! Or How I Learned to Get Over My Fear

This last week-end I treated myself to a trip to the Oregon coast to recharge. That meant I had to:

      go by myself (sorry dear husband)

    not engage with my electronics

    walk on the beach at least three times a day

    eat fresh seafood

    drink really good wine

    read a book

That was my plan and I was sticking with it. On walk #2 of the first day I made certain to be there around 2:30pm, low tide. This particular beach (Arch Cape) boasts some pretty cool tide pools if the ocean is out far enough. Sure you can pay to go touch a starfish or a sea anemone at the Newport Aquarium, and I have many times, but to see them in the “wild” is something altogether different.

I set out on the mile walk to the pool. When I got there, the tide was not out as far as I hoped. I was expecting more of a “desert landscape” that I could just walk on up to the edge of this giant rock and run my hand along the rough barnacles and muscles. But there was a sea of moss covered rocks and deep water between me and my destination. It was basically a river and the ocean tide was still feeding it. I studied it, tried to time the waves for minimal water interaction so I could safely cross. I walked up and down trying to find some kind of “path” with an old log or some makeshift bridge that perhaps another determined tourist had created. No luck. I did not want to get my shoes wet and I knew that if I tried to hop from one slippery mossy rock to another I was bound to fall. Gravity has never been my friend.

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Advocacy Updates

Report on Advocacy Fund spending… NACUSO Working for You

Through the support of our members and partners, NACUSO raised approximately $273,000 in contributions toward its Advocacy Fund (and predecessor Legal & Litigation Fund) over the past 3 years.  The goal of the two funds together are to enable NACUSO to conduct crucial advocacy work on behalf of CUSOs and their credit union owners / partners.

In keeping with our commitment to be fully transparent and to regularly communicate our usage of these dollars (we provided detail of how the funds were spent from 2014-2015 last year, which is also included in the attached Report), we would like to provide you with the following information, which was provided in detail to each contributor in the first quarter of 2017.  NACUSO spent the following amounts from the Advocacy funds during 2016:

$24,000     Dollar Associates, LLC - paid for advocacy work with Congress and NCUA on CUSO issues
$24,000     Messick & Lauer, P.C. - paid for advocacy work with NCUA and meetings with Congress on CUSO issues
$   718     Travel to Washington DC for meetings with Congress and NCUA
$48,718    Total amount spent influencing Congress and NCUA for favorable CUSO environment

The remaining funds, out of the total $273,000 in combined contributions, equal $110,323.  This represents the balance in Restricted Cash as of 12-31-16, as per the NACUSO Advocacy and Legal Fund Analysis report (click link below).

The NACUSO Board and its Legislative & Regulatory Advocacy Committee is continuing to prioritize the advocacy of a regulatory environment that is pro-CUSO and pro-collaboration within our industry.  NACUSO needs your support for this initiative and to accomplish its purposes.  While strategies may change over time based upon circumstances and opportunities to advance the cause of CUSOs, the necessity for funding of such initiatives is essential if NACUSO is going to remain in a position to impact the decision-making process for CUSOs and the credit unions that invest in, or utilize them.

Click to Contribute

For a summary of how NACUSO has worked to maintain an environment that is supportive of collaborative investment, the following report entitled NACUSO Working For You (see below) provides a summary of the work we have done on your behalf.  To capsulize some of its key points, a summary of what we feel are the NACUSO “wins” this past year are:

  • Effectively opposing the costly extension of Vendor Authority to NCUA.
  • Worked with NCUA on the revised MBL Rule.
  • Advocating for the expansion of CUSO powers to originate loans credit unions are authorized to make, to help bring scale and expertise benefits to credit unions in all loan categories.
  • Encouraged NCUA to be transparent in its budget and rule making including the OTR calculation.
  • Working with NCUA to minimize adverse impact of the CUSO Registry and to correct the acknowledgements initially in the Registry.

To emphasize the last bullet above, initially, in its first version of the CUSO Registry documentation that CUSOs were required to submit with their data to NCUA in 2016, the agency’s acknowledgement form required CUSOs – when submitting their data – to accept responsibility under regulations that only apply to credit unions but were not intended to, apply to CUSOs.  These acknowledgments, if left unchallenged and signed by CUSO officials, could have exposed CUSOs to potential penalties under regulations that do not, and were never intended to apply to CUSOs.  Upon becoming aware of this inappropriate acknowledgement requirement, NACUSO worked directly with senior NCUA staff to bring our concerns to their attention.  NCUA agreed to the NACUSO position and made the needed changes to the acknowledgements for the CUSO Registry data submission process.  In addition, for those CUSOs who had already submitted their registration and signed the acknowledgements, NACUSO developed a letter with the appropriate wording for those CUSOs to send to NCUA to clarify this acknowledgement concern.

Effective advocacy requires ongoing diligence in following every aspect of regulatory requirements impacting CUSOs and the credit unions that invest in them and benefit from them.  It necessitates prompt response at times and the ongoing resources to interact positively on behalf of the CUSO community on issues and requirements of all types.  With a new Congress now in session, educating them on the benefits of credit unions and the collaborations that enable them to cost effectively serve their members, as well as invest in innovation, through CUSOs that help spread and minimize risk, is an important message we are delivering.  We hope that you agree such diligent advocacy initiatives are crucial to the long-term viability of the collaborative movements within the credit union community.

We hope this report helps you see how we have carefully managed the funds entrusted to us, for Advocacy purposes.  We would be happy to answer any questions that you may have.  Thank you for your support, and for giving NACUSO the opportunity to support you as you serve your members.  Please consider adding your support to our advocacy efforts by contributing today.

View NACUSO’s 2016-17 Advocacy Plan 

View NACUSO’s Advocacy & Legal Fund Analysis

 

Best Regards,

Jack M. Antonini
President & CEO
NACUSO
Jack@nacuso.org

NACUSO Working For You

Legislative & Regulatory Advocacy Update

Vendor Authority

Knowing that obtaining vendor authority was the number one legislative issue for NCUA in 2015-16, Jack Antonini and Guy Messick met with key Congressional representatives in January to tell Congress why credit unions and CUSOs oppose the extension of this expansive, costly and unnecessary authority to NCUA.  When NCUA made their official request for vendor authority, Congress was not persuaded by their arguments.

We continue to monitor the situation to ensure that the Senate and House recognize that such an unwarranted extension of regulatory and examination authority beyond the current statutory mandate of NCUA is both controversial in the industry and potentially damaging to an industry that is dependent upon third party relationships because of their smaller size in comparison to many of their competitors.  Credit unions need third party support and collaborative innovation to continue to effectively meet their members’ needs, and a burdensome regulatory and examination regime for anyone who does business with a credit union will not foster that support and innovation.

NACUSO is focused on protecting credit union collaboration through CUSOs, but we need your help, so we can continue to be vigilant in monitoring legislation in Congress, please contribute to NACUSO’s Advocacy Fund today – click here to contribute.

NCUA’s MBL Rule

NACUSO was supportive of the positive changes in NCUA’s revised MBL Rule, including the greater authority to waive personal guarantees, a more balanced approach to construction loan limitations, enhanced flexibility on counting loan participations against the MBL cap and the improved treatment of 1-4 dwelling rental property.  NACUSO also, in consultation with our business lending CUSO members, recognized that the Conflict of Interest provisions in the new MBL Rule could be misconstrued by examiners, so we have engaged with NCUA Board members and senior NCUA staff about the issue, and sent a letter to explain our concern and our recommended solution (see NACUSO’s MBL Conflict of Interest Letter to NCUA ).

Expansion of CUSO Authorized Powers

NACUSO wrote to the NCUA Board in 2015 requesting an amendment to NCUA Regulations Part 712.5 to add to the list of authorized CUSO powers to help facilitate a competitive solution to the growing Internet and peer-to-peer lending competitors for car loans and unsecured loans faced by credit unions in today’s environment (see NACUSO’s letter).  Chairman Matz responded that she was not opposed to reconsidering new authorities for CUSOs, indicating “if CUSOs can legally provide additional services to benefit credit unions and their members without compromising safety and soundness, I would strongly support those efforts.”  Chairman Matz went on to say that she had asked NCUA staff to review the policy and safety and soundness considerations relative to our request, and this review is already underway (see Chairman Matz response).

NACUSO has since asked the NCUA Board to consider updating the CUSO powers to align CUSO loan support with the loans credit unions are authorized to provide to their members  (see NACUSO’s 2017 Expansion of CUSO Authorized Powers Letter to NCUA), so CUSOs can bring scale, risk mitigation and expertise benefits to credit unions in all loan categories, not just those listed in the regulations.  While we explained the reasons for updating the NCUA Rules and Regulations Part 712.5 defining the permissible pre-approved activities a CUSO may provide, we also referred to our advocacy efforts to have auto loans and consumer loans added to the list of CUSO activities over the past two years, and the support that NCUA has communicated regarding those efforts.  We respectfully submit that now is the time to update the CUSO regulations to clarify that CUSOs are authorized to assist credit unions with any loan type that credit unions are authorized to make.

Update on CUSO Rule Implementation

Pursuant to the CUSO Rule the NCUA adopted in November 2013, CUSOs have been required to report certain information directly to NCUA pursuant to the agreement with their investing credit unions.  NCUA built an on-line reporting system that went live in the first quarter of 2016, and CUSOs updated their CUSO Registry information in the first quarter of 2017.

NACUSO continues to work with regulators minimize the regulatory burden on CUSOs and to help credit unions realize the maximum benefit from collaboration through CUSOs.  We work to ensure regulations affecting credit unions and CUSOs are as favorable as possible, but we need your help to continue this regulatory advocacy work, please contribute to the NACUSO Advocacy Fund today.

NACUSO Supported Transparency on OTR

NACUSO has long expressed its concern about the growth of NCUA and its extension of its regulatory arm, both directly and indirectly, into areas of questionable statutory authority such as the de facto regulation and examination of CUSOs through the 2013 CUSO Rule.  The extension of regulatory authority by NCUA comes with increased costs, costs that are paid for ultimately by credit union members.

NCUA takes money from the insurance fund to pay for its operations through the Overhead Transfer Rate (“OTR”).  The OTR currently funds approximately 70% of NCUA’s budget.  NCUA does not have to justify its expenses or ask permission from anyone to take as much money as it deems appropriate from the share insurance fund for its operations.  Fortunately, under new leadership, NCUA has decided to be more transparent as part of its budget process and publish details of how it calculates the OTR.

NACUSO 2016-17 Legislative & Regulatory Advocacy Plan

As we explained when we announced the formation of the NACUSO Advocacy Fund two years ago, the regulatory climate that enabled credit unions to maximize the benefits of CUSOs and collaboration is under siege, and as an industry, we need to respond.  NACUSO established an Advocacy Fund to supplement its efforts to promote and protect a collaboration/CUSO friendly regulatory climate.

At the 2016 NACUSO Annual Conference, we shared our 2016-17 NACUSO Advocacy Plan, based upon the four basic precepts upon which our advocacy work is based.  Those four pillars are designed to support an environment that:

  • Encourages credit unions to deliver a better member experience and improve the financial well-being of members
  • Encourages credit unions to seek new collaborative ways to serve members needs
  • Rewards investment in innovation and collaboration
  • Supports the use of CUSOs as the incubators for collaboration and innovation so that credit unions can reap the benefits of entrepreneurialism without direct risks

The Advocacy Plan also identifies the key associational positions that NACUSO is focused on, for the benefit of CUSOs and their credit union owners, which are summarized as follows:

  • Supports the development of clear examination guidelines that recognizes that NCUA has review powers and not examination powers over CUSOs. Such guidelines would inhibit de facto regulatory creep that would treat CUSOs as regulated entities that would discourage innovation and collaboration. NACUSO will intervene with NCUA in the more egregious cases if the CUSO or the investing credit unions request NACUSO’s assistance.  NACUSO opposes any legislative efforts by NCUA to gain statutory authority to directly regulate and examine CUSOs through an unnecessary expansion of the agency’s examination authority over credit union vendors
  • NACUSO supports the modernization of the permitted CUSO Services list to include all loan types that credit unions can originate to help bring scale benefits as well as risk mitigation and expertise benefits to credit unions
  • NACUSO will encourage regulators to view innovation and collaboration as an essential part of a revitalized credit union model and adapt their regulations and supervision to encourage the responsible and prudent development of the collaborative model

Key strategies for accomplishing the NACUSO 2016-17 Legislative and Regulatory Advocacy Plan are detailed in the Advocacy Plan.  In order to have a maximum impact upon the regulators and the industry, CUSOs and their credit union owners must stand united as we promote the unique collaborative opportunities and risk sharing benefits that our CUSOs provide.   Together, our participation in collaboration advocacy efforts through NACUSO will be our most effective way of impacting the future regulatory environment under which CUSOs operate.

NACUSO will focus its advocacy efforts on those issues most critical to the CUSO community as a whole and will attempt to avoid watering down its message on key issues by taking public positions on all issues that may impact CUSOs or credit unions in a more indirect manner.

In the current environment it has become increasingly important for credit unions to find new sources of non-interest income in order to enhance earnings, build capital, and support member growth.  Thus, collaboration and innovation are more critical now than ever before to create sustainability for the credit union movement.  NACUSO educates the industry as a whole (CUSOs, credit unions and other providers) on the benefits of collaboration and innovation, facilitates cooperative business opportunities, and provides leadership on how to implement these strategies within a favorable legislative and regulatory environment.

It is the desire of NACUSO to be recognized as an effective organization in support of building a favorable legislative and regulatory environment through what we consider the four pillars of future credit union success – collaboration, innovation, growth and entrepreneurship.  NACUSO will be balanced in approach, but bold in action to aggressively promote this agenda and will seek to join with other like-minded organizations, when appropriate, to work in collaboration with NACUSO to see these key agenda items accomplished.

All of the organizations associated with the NACUSO Board of Directors have already made contributions to the NACUSO Advocacy Fund.   We urge you to add your collaborative voice to NACUSO’s advocacy efforts.  Please complete the commitment form today, and send your contributions to NACUSO so we can help you.  Please share with your friends in the industry who want to ensure a bright innovative, collaborative future for our industry and our members.  If you or your industry friends are not yet members of NACUSO, now is the time to join, and be part of the collaborative solution.  If you have questions about the NACUSO Advocacy Fund, click the link to go to the NACUSOAdvocacy Fund FAQ’s.

Thank you very much for your support, and for giving NACUSO the opportunity to serve you as you serve your members.  It is a privilege that we truly appreciate.

Sincerely,

Jack M. Antonini
President & CEO
NACUSO
Jack@nacuso.org

Jack M Antonini
President & CEO – NACUSO
jantonini@aol.com  (713) 208-0989
NACUSO’s 2018 Network Conference April 16-19 at Disneyland Resort in Anaheim, CA
Learn more about NACUSO in this short video!


NCUA Meeting Provides CUSO Guidance 6/16/16

NACUSO Visits NCUA to Discuss the CUSO Registry and CUSO Reviews

On June 14, Jack Antonini, NACUSO President and Guy Messick, NACUSO General Counsel met with NCUA Staff on the results of the CUSO Registry and the thinking on how CUSO Reviews will be handled.

The CUSO Registry sign-up period and the follow-up by NCUA found there were approximately 900 CUSOs.   NCUA believes that there are more CUSOs that have not reported.  Under the NCUA Regulations (Part 712.1(d)), “A CUSO also includes an entity in which a CUSO has an ownership interest of any amount, if that entity is engaged primarily in providing products or services to credit unions or credit union members.”   So these subsidiary CUSOs are considered CUSOs and required to make annual reports to NCUA.   The NCUA staff believes that many CUSOs were not fully aware of this requirement and there are a number of subsidiary CUSOs that have not reported.   NCUA will be following up with CUSOs to obtain these filings.   NCUA is also scrubbing the data and asking for clarification if the data is indicating that there may have been a reporting error. (more…)

Report on Advocacy Fund spending…NACUSO Working for you

Through the support of our partners, NACUSO raised approximately $63,000 in contributions toward its Legal and Litigation Fund in 2014 with a primary purpose to develop strategies for the most effective way to seek the repeal and/or mitigation of the impact of the CUSO Rule that NCUA had adopted in November 2013.  Subsequently, NACUSO established an Advocacy Fund to supplement the Legal and Litigation Fund.  The goal of the two funds together were to enable NACUSO to coordinate legal decision making, with a crucial advocacy component that will have more impact than the always risky option of legal action.  In total, $190,600 was contributed to the NACUSO Advocacy Fund.  Combined these two related initiatives received total contributions from NACUSO partners of approximately $253,600 in 2014 and 2015.

In keeping with our commitment to be fully transparent and to regularly communicate our usage of these dollars, we would like to provide you with the following information.  NACUSO spent the following amounts from the two funds during 2014 and 2015:

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CUSO Registry Clean Up Period 4/22/16

As most of you know, all CUSOs are obligated under the NCUA Regulations to register certain information directly with NCUA on an annual basis.   Over 800 CUSOs did so in February and March.   NCUA is now in the process of making sure all CUSOs have registered.   Their new deadline is April 30.  They are taking CUSO information from the credit union 5300 call reports and sending out letters reminding “CUSOs” that they have to register.   Some credit unions may have incorrectly listed a company as a CUSO.  Other credit unions list their CUSO but use an acronym for the CUSO instead of the CUSO’s full name.   NCUA, not knowing better is sending letters to any and all companies listed on the call reports. (more…)

Regulatory Update 3/15/16

Letter to NCUA regarding CUSO Registry Acknowledgement: Yesterday, NACUSO informed you of a change we negotiated with our General Counsel (Messick & Lauer) with the NCUA regarding the CUSO Registry Acknowledgment each CUSO is required to agree to when submitting their CUSO registration in the NCUA’s CUSO Registry system.  As we pointed out in our Regulatory Alert yesterday, the acknowledgment required CUSOs to agree to be bound by statutes that only apply to credit unions and which imposed penalties that are not applicable to CUSOs.

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Change to the CUSO Registry Acknowledgement 3/14/16

During the process of assisting with CUSO Registry questions, it came to our attention that in order to complete the CUSO Registry, CUSOs were required to agree to be bound by statutes that apply to credit unions and which imposed penalties that are not applicable to a CUSO.  On behalf of NACUSO and the many CUSOs in this industry, Messick & Lauer (NACUSO’s General Counsel) have advocated and negotiated to revise this acknowledgement to more accurately describe the duty of CUSOs to respond to the CUSO Registry.  It is a contractual duty with the credit union and not a direct regulatory obligation to NCUA.   As NCUA continues to pay more attention to CUSOs, NACUSO will continue to take action to be the voice of CUSOs and to resist any attempts at regulatory overreach.  The NCUA has changed the acknowledgement text.  For your reference, the text of the previous and current CUSO Registry acknowledgments are below. (more…)

Regulatory Update 2/26/16

NCUA’s CUSO Registry Training & Demonstration webinar held on February 11 is now available to be viewed.  If you missed the webinar, or want to view it again, to help you in completing the CUSO Registry, you can watch it by clicking on the following link:  View 2/11/16 Webinar. You have until March 31, 2016 to complete your initial registration of all CUSOs.