As we explained when we announced the formation of the NACUSO Advocacy Fund a few months 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 has established an Advocacy Fund to supplement its efforts to promote and protect a collaboration/CUSO friendly regulatory climate.
As was announced at the NACUSO Annual Conference, we have developed a NACUSO 2015-16 Legislative & Regulatory 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 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 will be focused on, for the benefit of CUSOs and their credit union owners, which are summarized as follows:
- Withdrawal of the 2013 CUSO Rule
- Making the reporting and review process as efficient and non-disruptive as possible, if the CUSO Rule is not repealed
- Oppose the granting of direct regulatory authority over CUSOs and other vendors
- Opposing the risk rating of CUSO investments over 100% in RBC2
- Expanding the services CUSOs can offer
- Encouraging regulators to adapt their supervision to accommodate new services and processes to minimize cost and disruption
- Oppose risk based NCUSIF premiums, which are unnecessary and duplicative of risk based capital, and would deplete credit union capital to the detriment of investing in innovative and collaborative CUSOs
Key strategies for accomplishing the NACUSO 2015-16 Legislative and Regulatory Advocacy Plan are detailed in the attached 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, from the impact of the CUSO Rule to the risk based capital requirement for CUSOs.
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 maintain necessary 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 have questions about the NACUSO Advocacy Fund, click from the links below to view NACUSO’s Advocacy Fund FAQ’s.
Jack Antonini, President & CEO