News & Highlights

The Story of CU Lunch Local: An annual celebration of credit unions commitment to community.

Posted by & filed under Blog.

CU Lunch Local aims to raise awareness about the importance of supporting local small businesses across Michigan. Studies show that money spent at local businesses tend to stay in the community and a greater percentage of every dollar spent is recirculated at the local level when compared with non-local businesses. CU Lunch Local was founded in 2011 in collaboration with Michigan Business Connection, a commercial lending CUSO.

Bill Beardsley, CEO of Michigan Business Connection and Board Member of NACUSO sat down with us to talk about CU Lunch Local. A unique way to celebrate International Credit Union Week.

Tell me a little bit about how this movement came to be? 

CU Lunch Local was born in 2012, when MBC reached out to its credit unions’ marketing departments to come up with ideas on how to capitalize on the impact the credit union industry has on local economies. On one of those calls, the idea of a “cash mob” type of event was thrown out to the group. Everyone loved it, and from there it was just a matter of sorting out the details. Since that time CU Lunch Local has become an annual event. One that we want to continue to see grow.

What is a cash mob? 

Cash mob events are similar to flash mob events, but with one key difference. Instead of dancing in the street, people who participate in cash mob events spend money.

Their goal is to support local businesses and encourage others to buy local. On October 17th, we hope to have hundreds of credit unions from all around the country that  will commit to dine, shop, or buy local.

Do you know how many credit unions participated last year?

That’s a tough question to answer. We ask participants to sign up, but we know there are dozens of participants that just go for it, and participate without signing up. I can estimate that we’re in the hundreds though.

What is your goal for this year? 

We’d like to see more states and more credit unions, and CUSOs join the movement. We’d also love to see credit unions, leagues, and other partner organizations “tag” another organization and challenge them to join CU Lunch Local this year.

What are some of your best memories of CU Lunch Local? 

There are just so many, it’s impossible to name just one. Every year one of the best parts about this event is, that we’ve always said, CU Lunch Local can be as simple as buying a cup of coffee locally and then sharing that purchase via social media with the hashtag #culunchlocal. But, the reality is credit unions and the industry go all out, and the ideas and the impact and the fun everyone has with CU Lunch Local is amazing.  

How can credit unions and CUSOs get involved?

Getting involved is easy. First, like the official CU Lunch Local FB page, www.facebook.com/culunchlocal, then sign up, http://signup.com/go/AXePFmr, questions and requests for the logo, etc. can be emailed to: jessica@in-fusiongroup.com.

The “E” in DREAM Big Contest: Educate and Excite!

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When I was the VP Marketing for First Tech Credit Union I was in charge of the website. This is back in 1997 when websites were in their infancy. We paid an inordinate amount of money for the first one to be built (read, as much as my first home). My job was to keep the content fresh. We had pages and pages of marketing copy. But I wondered, was anyone reading it? When they land on the home page, where do they go next? Is our navigation working?

Microsoft (who was one of our SEGs) had just come out with some fancy software that could tell us just that. The guy in IT described it to me in this way “Imagine a field of freshly fallen snow, this software is going to show you the footprints in that snow so you can see the “path” people take when they go to your website. Yay! I couldn’t wait to see the results. I never could have imagined it at the time. There was a muddy trough directly to the home banking login. The majority of the pages were not visited even ONCE!

What an eye opener. Fast forward 20 years and here we have Kirk’s book telling us that members are probably still doing the same thing. That’s why most of us don’t dare bury the login to home banking for fear of losing them entirely. So how do we get our members to read our stuff? It’s so simple, make it relevant and compelling and local! Yes local.

Last week we talked about how the Google machine rules the world. If you want to be found you need to know how Google sees the world. Google loves local. Create local content that is hyper-targeted at an age group, a population, an experience or a region – whatever it is, target it in a way that Bank of America or other big banks can’t. I just looked at several credit union websites and few even have “content.” Most have copy, which isn’t the same thing. Here’s the difference.

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The “R” in the DREAM Big Contest: Recreate and Reinforce

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Kirk Drake (right) with Mike Lawson at 2017 NACUSO Network Conference

Last week we talked about the importance of differentiating with data … the “D” in Dream. Now let’s begin by talking about the Google machine. I cannot even remember my life before it? Did we go to the library to do research? Pull out our 10 year old Encyclopedia Brittanica? If you’re a Millennial reading this – Google it – it’s a thing.

Anyway- Kirk cracks the code on getting Google’s attention. Put simply, the ultimate goal is to have someone in your field of membership searching for a solution to a problem and bam – you have the answer and land on the top (or near) the first page of responses. So just for fun Google “good financing for a car loan in (insert your city name).” Was your credit union there? If so, congratulations. If not, why?

I don’t know of a credit union out there that doesn’t want to be known as the “trusted resource for financial services.”  How do you earn that trust? Not by product pushing and always leading with rate. Not with clever ads and shiny happy people on your website. It’s about identifying with your target audience and giving them resources, content, information and education, about stuff that has nothing to do with your products and services. A really good example is Point West Credit Union in Portland, Oregon. They were founded in 1932 to serve employees of Multnomah County. After the Great Recession of 2008 they focused their mission on community development. They received their CDFI designation in 2013 and merged two very small diverse credit unions in – NAACP and Hacienda Community.  In 2016 they funded $5.4 million in affordable loans to non-citizens! That’s a real differentiator. They have created a community within their community.  On Point West’s site they have a page dedicated to resources for non-citizens.

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A Message From the Future…

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An encoded message is received from the future. In includes a warning from the last Credit Union President who sends back something to help rebalance the future between credit unions and fintech providers. WhatIsDSP.com

Improving Member Loyalty at Credit Unions | CloudCherry & NACUSO | Webinar

Posted by & filed under Video.

Is your Credit Union able to keep up with member expectations? Also, how do you deliver memorable experiences that boost loyalty?

Watch this webinar hosted by CloudCherry in association with NACUSO to learn about mapping and improving multi-channel member journeys and increasing member retention rates. Denise Wymore, Membership and Advocacy Director at NACUSO, and Rose Bentley, Member Experience Expert at CloudCherry, also talk about improving member loyalty and retention rates.

Voluntary Mergers: The Stuff No One Says Out Loud by Guy Messick

Posted by & filed under Blog.

I get it.  You want to merge with a peer sized credit union.  Together you will have more scale, twice the number of branches, twice the membership size, twice the assets…twice, twice, twice.    Having all things twice should create the golden ticket of economies of scale.   But after the merger you seem to have twice the payroll but not twice the benefits.  What happened?   The dirty little details get in the way.

  1. If you don’t trim the payroll, you don’t save money. People are the highest cost of operations.   Unless you have fewer employees after the merger, you are not going to save money.   Are you willing to make those decisions?
  2. If you don’t trim the vendors, you don’t save money. The continuing credit union needs to quickly decide what vendor to use for each service.  Having multiple vendors for a service within a credit union does not create efficiencies.
  3. Be ruthless in you vendor selection. Past relationships with vendors are great but that is not a reason to keep a vendor if the vendor is not competitive on price and quality.  Buying a foursome at your credit union golf outing is not a sufficient reason to keep a vendor.
  4. The cost of terminating vendor relationships is a cost of the merger and should be calculated into the decision.  This is especially true for core IT services where the termination fees can be excessive.
  5. The staff expertise needed to run a credit union of X size is not the same as running a credit union of 2X size. The general level of expertise has to increase significantly if the size and complexity of the operation increases significantly.   There are all-star employees working at smaller credit union who could work at any sized credit union but the overall expertise level at smaller credit unions is not equal to the overall expertise required at larger more complex credit unions.  If the merger puts you in a peer class that is significantly larger, are you willing to make the necessary changes in staff?  That is a significant hidden merger cost.
  6. Larger credit unions tend to have different operational processes and a more formalized protocol and policy structure, which is often required to ensure consistency in member loans and regulatory compliance. Are you ready for that?
  7. The technology tools in a larger credit union tend to be more extensive and expensive than in a smaller credit union. Do you understand that cost and has that been a part of the analysis?
  8. If the merger puts your credit union within the jurisdiction of the CFPB, are you ready for the enormous costs of that oversight?
  9. Do you have the attitude to analyze the profitability of services and cut services that cannot be self-sustaining?
  10. Have you gotten past the post-merger identity of the CEO and directors? Does the board have the vision and talent for a larger, more complicated organization?
  11. How are you dealing with the staff issues? What will be the organizational structure and who is in each of the slots?  How are those decisions being made…by unemotional analysis or by cutting internal deals to be “fair”?
  12. How are you dealing with different salary levels and employee benefits? Do you have to pay retention bonuses to keep key employees around for the transition?
  13. Can you close branches? Do you have keep unprofitable branches open?
  14. Is there a strategy to tear down the “us vs. them” walls and tribe-like behavior that sometimes occurs post-merger?
  15. Do you have the metrics to measure the success of the merger?

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DREAM Big Contest!

Posted by & filed under Blog.

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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Advocacy Updates

Report on Advocacy Fund spending… NACUSO Working for You

Posted by & filed under Advocacy Fund, Regulatory Advocacy.

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
                    

                    

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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
                    

                    

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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
                    

                    

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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
                    

                    

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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
                    

                    

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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
                    

                    

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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.