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.
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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. (more…)