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The CU2.0 Podcast
This podcast explores contemporary, critical thinking and issues impacting the nation's credit unions. What do they need to be doing to not just survive but prosper?
The CU2.0 Podcast
CU 2.0 Podcast Episode 371 Lobbyist Elizabeth Eurgubian on What's Up inside the Beltway
Whew, credit unions dodged the threat of loss of their tax exemption - but don’t think all is smooth sailing for credit unions in today’s turbulent Washington DC. Lots is happening that may impact credit unions, large and small.
On the show is repeat guest Elizabeth Eurgubian, a lobbyist - with the Defence Credit Union Council among her clients - who also has served as NCUA Director of the Office of External Affairs and Communications and Policy Advisor to Chairman Harper. Before that she was deputy chief advocacy officer at CUNA and before that she was a vice president and a lobbyist for ICBA.
Her specialty is regulatory matters and that means NCUA, but also CFPB and other agencies.
In this episode she talks about what’s up with NCUA’s one person board, the shrinking of CFPB, the GENIUS Act and the opportunity presented by stablecoins, and NCUA’s Central Liquidity Enhancements Act and why this matters to smaller credit unions in particular, and also NCUA’s recurring paperwork review and how it’s an opportunity for credit unions to seek changes at the agency.
See: there’s a lot happening inside the Beltway.
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Welcome to the CU2.0 podcast.
SPEAKER_00:Hi, and welcome to the CU2.0 podcast with big new ideas about credit unions and conversations about innovative technology with credit union and fintech leaders. Woo. Woo.
SPEAKER_02:Credit unions dodged the threat of loss of their tax exemption earlier this year, but don't think all is smooth sailing for credit unions in today's turbulent Washington, D.C. Lots is happening that may impact credit unions large and small. On the show is repeat guest Elizabeth Ergubian, a lobbyist with the Defense Credit Union Council among her clients, who also has served as NCUA Director of the Office of External Affairs and Communications and a policy advisor to Chairman Harper. Thank you so much for joining us. and NCUA's Central Liquidity Enhancement Act and why this matters to small credit unions in particular. And also there's NCUA's recurring paperwork review and how it's an opportunity for credit unions to seek changes at the agency. And yes, she says, NCUA definitely reads email sent in by credit unions. See, there is a lot happening inside the Beltway. Listen up. Now, with DCUC, your focus is regulatory.
SPEAKER_01:Yes.
SPEAKER_02:As opposed to legislative.
SPEAKER_01:They're a client of Atlas Advocacy, myself, and we do regulatory advocacy. We support them in that regard. Yep.
SPEAKER_02:So that means primarily this would be interfaced with NCUA, not exclusively, but primarily.
SPEAKER_01:You know, I mean, we help guide them on messaging and whatnot with The agencies, yeah, NCUA, CFPB, Treasury, SBA, whatever agency that they're dealing with on certain issues. And we also look at the regulations, look at the changes, look at the notices and issue spot for them on things that would be really important for them to pay attention to. Now,
SPEAKER_02:when last we talked on the table was taxation for credit unions, that's fallen off the table, at least for the time being. I'm sure it'll come back. We do have a whole bunch of issues to discuss. And one that you put down on your list is, and it's probably top of mind for many people, is NCUA board structure. What the heck's going on there? So we're down to one member of the three-person board.
SPEAKER_01:Right.
SPEAKER_02:What's happening with the other two at this point?
SPEAKER_01:So the other two have appealed their dismissal, and that's making its way through the court decision-making process. And we're seeing that with other dismissals by the administration like the FTC member that the Trump administration dismissed. And the reason these are being litigated is because he dismissed these individuals not for cause. And the argument is that that's not allowed. He has to be able to have cause in order to dismiss them because based on their role in statute as an independent agency, they they can only be removed by the sitting administration if there's cause.
SPEAKER_02:And specifically with the NCUA, those individuals were Senate-confirmed?
SPEAKER_01:Yes, Senate-confirmed. So right now they're waiting. They're sort of in the process of waiting and letting this run through the litigation. And it'll probably go to the Supreme Court. It'll be decided. And at that point, we'll know for certain whether or not this administration is dismissal of those two board members will be considered, you know, consistent with what the statute, the federal credit union act mandates now. So that means we have chairman Houtman who's acting by himself at the moment and his terms actually up. I mean, his term was up in August, but it's not unusual for board members and, and chairman to stay chairman chairwomen to stay past their term. So he's there until, you know, it's eventually until the president appoints somebody else. And that person Senate confirmed, and then his term will lapse at that
SPEAKER_02:point. So that board is weird. Two people have been kicked off of it. And the sitting board chair, the only board member, actually is termed out. His calendar has ended.
SPEAKER_01:But like I said, that's not unusual. I remember other occasions when the chair has stayed... passed their appointment until the president could appoint somebody new and get that person's Senate confirmed. It's probably complicated for the president to be able to do that now because he might face some hurdles in the Senate because they're not going to want to go, especially on the Democrat side, they're not going to want to work to confirm his replacement for the chair when they have two members that have been dismissed that they don't believe is lawful dismissal. So that politically gets a little messy. So my guess is Chairman Hauptman will be there until everything gets figured out with the other two board members. And once that gets decided by the courts, then the president can make a move on who he wants to replace Chairman Hauptman.
SPEAKER_02:Now, what's the operation, as far as you can tell? How is the operation at NCUA affected by both the board turmoil and the staff reductions. And I think something like 15% of the staff was dismissed, if my memory's right.
SPEAKER_01:Right. I believe they're at 900 and something full-time staff members. It's under 1,000, the last I was told. There's a lot of functions of the NCUA that could be handled because we have delegated authorities. So the board delegates authorities to different division departments to lead. Not everything has to go to a board decision. So there are a lot of decisions that could be made at the department. You know, the everyday examination function, all of that could be done at the department level. It could be run by the chair. The chairman, you know, makes decisions regarding the call reports, examinations, supervisory highlights All of that goes with the chair. Where it gets a little more difficult, or actually a lot more difficult, is if there's regulations that are proposed and finalized and you don't have a board quorum. That's where you're going to face a legal battle if that happens. And that hasn't happened yet. There's only been briefings. There haven't been any proposed or final regulations. The budget hasn't been debated or a new budget voted on. That's another area where you're going to you might face a challenge if you don't have a full board quorum. Or if there's appeals, like if you're dealing with mergers, you're dealing with field of membership issues, and a credit union appeals a decision that was made at the department level, that would go to a board vote. And if you don't have a quorum there, then you're going to face some legal challenge as well. So when those occasions come up, eventually they will, that's when it's going to get more murky just having one individual on the board representing the entire agency. And so as soon as we could get a full board or a quorum, at least two members, which would be a quorum, that's going to make things, I think, make people a lot more comfortable so that they're not, the agency is not vulnerable to a legal challenge when some of these decisions have to be made.
UNKNOWN:Yeah.
SPEAKER_02:Yeah, that's interesting. If the NCUA were to oppose a merger at this point, I think the credit unions, if they chose, could sue on the grounds that you just don't have, you can't do that.
SPEAKER_01:Well, yeah, if you appeal decisions and those decisions are decided at the board, with the board. And if you only have one member and the one member is saying, well, I'm one and that's one is a quorum, that's an interpretation, certainly. That's certainly an interpretation of the Federal Credit Union Act. Whether a core is going to agree with that interpretation is another story i interpret things all over the place like i can interpret things however i want my interpretation is not relevant the court's interpretation is what's relevant so when you expose yourself to a challenge yeah now now you're taking it out of the hands of the statute now court's going to decide that
SPEAKER_02:so the good news and what you're saying is that as far as you can tell ncoa operationally is chugging along as it had without it's like the sky didn't fall down you
SPEAKER_01:know there's a lot of things that could run you know i don't want to say on autopilot but there is a lot of aspects of the agency that could run with the chair and
SPEAKER_02:with the staff reduction too
SPEAKER_01:oh yeah
SPEAKER_02:yeah you know i i don't some months ago there was a lot of concern about what the heck i mean i have not heard panic so far
SPEAKER_01:i i personally have always thought the ncua was a lean agency uh you know i've worked at the federal Reserve Board prior to many years ago. And even when I worked at the Fed, I thought the NCUA was a lean agency. I really wish it had more individuals working there and really looking at issues than it did. I've always felt this. We're in a situation where they're downsizing the agency. It's not my decision to do that. I think they're very capable individuals there that really care about credit unions and want to do good work, and that's to the industry's advantage. So in that regard, I think that's a positive. At the same time, when you have a very lean agency and something goes wrong, there's only so much people can do. There's only so much bandwidth the agency has. So that's what concerns me. If things are moving great, it doesn't concern me, but it's when things aren't. It's when you have a big cybersecurity attack or a big cyber breach, or if something happens and there's a run on credit unions. It's when you have these emergency situations that having those, the amount of people, the amount of FTEs there really does make a difference and you could absorb the issue. I think
SPEAKER_02:too, the bank examiner job, first of all, there are fewer bank examiners now, so probably be bigger time between examinations, which is not a good thing. And secondly, more tasks have been given to the bank examiner. like to do a technology oversight thing. Many of them aren't qualified to do that. And I'm not putting down. It's kind of like if you said to me, part of your job is to do a modern Greek translation of the podcast. I'd say, wait, hold up. Out of my competency here. There are costs to staff reduction in addition to the money saved. There are some costs, unfortunately.
SPEAKER_01:Absolutely. Absolutely. I'm hopeful. I'm hoping that What happens is, you know, they had some individuals that left, that took retirement, that took, you know, buyout, whatever. And then I know once a hiring freeze is lifted by the administration, maybe they could bring back certain employees that could work on some of these areas that they really need specialty focus on. And they could then focus where they put their resources. You know, that would be ideal. But yeah, I mean, it's... It was always a lean agency and that always concerned me. And now it's even leaner. So it does absolutely concern me. But I do want to say working there, it was some of the most dedicated individuals I've ever worked with in my entire career. So I have a lot of faith that they'll get through this time. I just don't want to see something environmental happen that is so great that it becomes difficult for them to absorb it or deal with it with the limited resources. resources.
SPEAKER_02:Now, what's going on at CFPB that credit unions should be concerned about or at least take notice of?
SPEAKER_01:With CFPB, the thing that's always concerned me there is, I mean, that agency is completely, I mean, they've lost like 90% of the agency, probably maybe even more than that. They may have maybe a couple hundred people working at CFPB. And some folks, I'll hear in the industry find that to be favorable. They think, oh, this is great. The agency was over burdensome to begin with. It should have never been created to begin with. So we're happy with this. But the issue is there's a lot of powers, a lot of authority that provincial regulators had that went to the CFPB. And now the CFPB has that authority. But if the CFPB is not doing those tasks, no Nobody's doing those tasks. They're not going back to the potential regulator. And some of that is supervision over institutions over$10 billion in assets, examination and supervision over depositories over$10 billion in assets, non-banks, some of these other companies. Pretty much any company that touches consumer financial services was under the purview of the CFPB. And some of that is good for credit unions because it's not right for a credit union to be examined, supervised regularly by state examiner by their federal prudential regulator. But then these large institutions, they're not getting that same supervision for consumer financial protection. And they're the ones that presumably have the greater risk to the industry. So that's where I have a hard time grappling with that. If the CFPB is not going to examine these large institutions, not going to have supervision over them due to their staffing limitations, then who Who's going to do that? And if nobody's going to do that, then why are credit unions being examined for these things, the ones that are under$10 billion in assets? Because our prudential regulators are still there. They're still doing that job, and there's state regulators doing it as well. So that, to me, is not a level playing field, first of all. Also, it doesn't fairly address risk, because I'm going to go out on a limb here and say the consumer protection issues at a$50 million credit union probably don't have– they're doing something really out of compliance, it probably doesn't have the same risk to the industry as JPMorgan Chase doing something greatly out of compliance. Or
SPEAKER_02:even Silicon Valley Bank.
SPEAKER_01:Right. Yeah. I mean, we got to think back to why, whether you agree or disagree with the CFPB, the reason for its establishment was to address the mortgage crisis and what happened there. That was with large institutions. So, You know, a lot of the problems that trickled down and impacted the smaller institutions started with the big ones.
SPEAKER_02:And credit unions were victims in that process.
SPEAKER_01:That's correct. Because
SPEAKER_02:they bought bags of mortgage loans that were junk.
SPEAKER_01:Right.
SPEAKER_02:And they bought them from large institutions. They didn't buy them from a guy in the street corner. Many credit unions, particularly the corporate credit unions, just got kicked to hell in that deal and went out of business. Yeah. You know, I've talked to CEOs of a couple of credit unions that are over to They are regulated by CFPB. They had no gripes about it. Really didn't see it as that. It wasn't that big a deal to them. Whereas other people act as, oh, geez, we have to have lunch with the Antichrist. Not according to these people. It was really not that big a deal.
SPEAKER_01:Yeah. Nothing's a big deal until there's a fire. You know what I mean? I don't worry about putting my fire extinguishers everywhere until there's a fire and I need that freaking extinguisher. So that's the issue that concerns me. Same with the NCUA. We talk about limited staff members and when everything's going fine, there's nothing to worry about. It's the time when nothing's going fine that you worry and being prepared for those incidents. And the way we're setting up this infrastructure, it doesn't give me a lot of confidence that we're prepared for those incidents. Does it give me confidence that we're prepared for the day-to-day? Yeah, pretty much. I think we could handle the day-to-day. It's when there's something that goes wrong. And sometimes that's not within the control of credit unions. Sometimes it's a large institution. Sometimes it's a Silicon Valley bank. Sometimes it's a JP Morgan. Sometimes it's a countrywide things that are outside of the control of smaller institutions. Yet the smaller institutions are going to face the punishment for them, you know, in a myriad of ways, whether it's regulatory, whether it's what happens with consumers, whether it's anxiety, you know, the market is extremely emotional. So things that happen in a large large scale trickle down to impact smaller institutions. And we've seen this time and time again. So when people ask me, or does it concern me? None of this really concerns me if things go well, but things never go well. There's always something that happens. And I don't think we're prepared for that when that does happen. That's what concerns me.
SPEAKER_02:Now, another issue is NCUA's Central Liquidity Enhancement Act.
SPEAKER_01:Yes.
SPEAKER_02:What's that and how, why should credit unions be interested in that?
SPEAKER_01:This was an issue that when I was at the NCUA, you know, so I led the Office of External Affairs and Communications under Chairman Harker and was his policy advisor. This was an issue we really wanted to see Congress make some changes on. And even before I was at NCUA, it was something the NCUA fought for. It's really to give some enhancements to the way credit unions can access the central liquidity facility. There were many enhancements made temporarily during COVID. during that time for like two, three year period to deal with that. But then they expired. They sunset. What we'd like to see at the NCUA is to have these enhancements permanently. So it becomes easier for smaller credit unions to access liquidity through the CLF, going through, you know, agent members, corporate credit unions as agent members in particular. And there's some red tape there, the way the statute's currently written. And we kind of wanted to clean a little bit of that up so that it allows smaller credit unions easier access to that liquidity fund. So there is legislation right now in Congress where they're going over this issue. It's such a no-brainer. It costs taxpayers nothing to support this. It doesn't cost taxpayers any money. And the one piece of legislation right now is the NCUA Central Liquidity Enhancements Act, S2545. But this issue has been been really advocated for by the NCUA for a long time. It was when I was there, all the board members, Democrat, Republican, strongly supported. I know I don't want to speak for the current chairman, but from my impression, he's, you know, has supported this and has been, you know, mentioned it as being extremely important. It has support from the industry. It has support from, you know, strong support from the agency. And it's just one of these changes that gives a little bit of a buffers should there be a problem. Maybe it's because I'm an attorney and I'm trained to look for problems. I'm always trying to, as my mom says, solve the problem before it happens. So if there's ever a liquidity crunch later down the line, this is already done. Now, this is not something you fight for in a liquidity crisis. You fight for it ahead of time. So when that liquidity crisis eventually comes, smaller credit unions can access this fund easier. But you don't wait for the crisis.
SPEAKER_02:To boil this down, right now a small credit union is having a pretty big problem, has a lot of red tape and has to cut through
SPEAKER_01:to
SPEAKER_02:get money. And all this is saying is we can enhance and speed up this process and it's not going to involve a heck of a lot of risk.
SPEAKER_01:No, no. It would just allow corporate credit unions to act as agent members for a subset of their credit unions, which makes it easier for them to get into the fund and help those members, which makes it easier for smaller credit unions to then access the funds. Now, there's other CLF enhancements that the NCUA and the industry have really pushed for, but this one is just one of two or three pieces of legislation that we'd like to see go through. And
SPEAKER_02:we're basically talking about... tiny amounts of money. This is not consequential to the credit union industry as a whole, to the country.
SPEAKER_01:No, there's no taxpayer money in this.
SPEAKER_02:It's just shoveling a little money out the door to a credit union that's having a liquidity problem. Doing it fast enough so it actually helps them. Taking too long can be a problem.
SPEAKER_01:It
SPEAKER_02:seems like a no-brainer.
SPEAKER_01:It is a no-brainer. Some people may say, well, Elizabeth, that's not an issue right now, like I said before.
SPEAKER_02:But it will be.
SPEAKER_01:It will be.
SPEAKER_02:I mean, my heavens, this stuff is cyclical.
SPEAKER_01:That's right.
SPEAKER_02:Every generation has this liquidity problem. I mean, look at all the SNLs that went out of business in the late 80s, early 90s. And then 2008 rolls around, we have another liquidity crisis, blah, blah, blah. We'll have one. I mean, I'm I don't have my crystal ball as cloudy today, so I'm not predicting when, but we will have one.
SPEAKER_01:Yeah, and as I think Chairman Harper used to say, you don't fix the roof when it's raining. Well, that's
SPEAKER_02:when everybody wants to fix the roof, but roofers always tell you you can't come because it's got too many costs, plus it's dangerous to work on a wet roof. Tell me about this genius app.
SPEAKER_01:So, yes, this is one of these issues that I think we're going to be really talking about for a while and I'm hearing it in the credit union industry as well. And, you know, this was recently passed that gives, you know, a federal regulatory framework for payment stable coins and is giving, is sort of creating this framework so that folks in the industry, including credit unions, can participate in using stable coins. And, you know, this is a new area. The Genius Act would assign supervision to regulators, including the NCUA for purposes of credit unions, the OCC for non-banks, the Federal Reserve. So the NCUA will be looking at regulations on this too, which is a good opportunity for credit unions to really weigh in on how they can be really involved in this new way of having payments be faster, cheaper, and more user-friendly for consumers. So this is one of those areas where credit unions sometimes have this wait-and-see situation philosophy on getting involved in some of these new technologies like stable coins. And I mean, I know there are some in the industry that are saying credit unions can't really afford to sit back and wait. They really need to start getting involved with this and seeing how they can utilize it for their membership. And their membership is perfect for this because it's community based. And this isn't like a Bitcoin type of situation where you have a fluidity regarding what it's, you know, Bitcoin is worth. These are stable coins. So they're tied to the dollar. They're tied to something that keeps them stable. And all it's doing is creating another mechanism for money to transfer with ease and with less cost. That's pretty much what you're doing here. This is the bread and butter for credit unions. Credit unions really should be getting involved in this. And I know there's some workshops probably out there. There's some trainings. There's some education. This is a great opportunity for credit unions to partner with CUSOs that really have the expertise in this area. And I would encourage credit unions to develop as much as possible and use this as an opportunity to figure out ways to help their members even more and use this technology as a way to help their members even more, especially because, and I'm not an expert in this, I'm learning it just like everybody else, probably going to have an impact on interchange. Now that you have, maybe not quickly, maybe not immediately, but over time it's going to and That's a revenue source for credit unions. So if they could sort of look at this issue as a way to help their consumers make payments easier, faster, get involved in this market, work with CUSOs, this would be a nice avenue for them, given the structure of credit unions, given their member service philosophy, and given the fact that there's going to be a necessity to look at other ways to serve their consumers as other revenue streams start to diminish like interchange.
SPEAKER_02:So how would credit
SPEAKER_01:unions get a seat at this table? I mean, the table is already set. So there's not provisions put in place that would make it difficult for credit unions to get involved in this area. Some might say, oh, this is really for bigger institutions. It's not really something for credit unions to get involved in. They don't know what they're doing. That couldn't be further from the truth. This is exactly the type of technology credit unions should be getting involved in. This is exactly the type of thing that would really help their members. But they do have to have a seat at the table now. They do have to be communicating with their regulator, uh, learning about the issue, seeing if it's something that they could work through with CUSOs, and making sure their regulator is at the table in interagency conversations on this. A lot of times... When there's interagency rulemakings, and I know this working at the Fed, the NCUA is not always the biggest player at the table. You know, I mean, that's, you have the Fed, you have the FDIC, you have the OCC, whatever. And then there's the NCUA. NCUA may not be the biggest player there. In this case, they really have to be an active voice as these rules are promulgated. You know, as much communication as the agency could give to the industry and transparency and as much involvement as the agency could, or the industry could have in making sure credit unions are very well represented and that rules favor them will greatly benefit credit unions in the long term. I think one thing that credit unions have to their advantage is that the current chairman knows these issues pretty well and cares about them. I would leverage that if I were the industry.
SPEAKER_02:You mentioned a few minutes ago interchange. What's the status of interchange right now? Many credit unions, That is really essential to their operations is the money that they're making on interchange.
SPEAKER_01:With the Genius Act, if payments become made primarily through mechanisms through stable coins, that could eventually impact the revenue that institutions make through interchange. I mean, I don't see that happening overnight, but it could eventually have an impact on it. And that's why it's all the more important that credit unions get involved with issuing stable. Well, there's this
SPEAKER_02:other bill backed by big merchants like Walmart that would allow different payment routes to come up and in the process allow significant reductions in interchange.
SPEAKER_01:Yes, right. And that could have an impact. Yes, absolutely.
SPEAKER_02:So what's the status of that?
SPEAKER_01:I don't know what the status of that legislation is, but any of these changes to interchange, even if nothing happens with that, just the Genius Act could have an impact on interchange. I'm only even thinking about that. That alone could have an impact.
SPEAKER_02:This Walmart bill, assuming it's not fully implemented, will come back and will come back and will come back. There's an inevitability to interchange rates going down. To me, it's got a union have to prepare for that day.
SPEAKER_01:Here's the lesson. Whenever you have, Chairman Harper used to say it's that overdraft protection and people would misread sometimes what he was saying. Whenever you have a way that you make money, you always have to make the assumption. And let's say you're concentrated in that way. Let's say a lot of your revenue comes from making money by interchange or by overdraft or by one of these things. And you become somewhat dependent on that revenue. You have to prepare for the day it's going to go away. I would prepare for the day players in the marketplace won't be able to achieve the same level of revenue that they made with overdraft that they did in the past. So what does that mean? You have to prepare for that day.
SPEAKER_02:And this is happening right now.
SPEAKER_01:Absolutely. And it's going to happen with interchange too.
SPEAKER_02:With the biggest, some big banks reducing overdraft fees to next to nothing, or I think in some cases, nothing. This is going to trickle down throughout everything. You cannot charge$29 for an overdraft anymore. I mean, I'm Some institutions still are, but those days are numbered.
SPEAKER_01:You see it in overdraft, you can eventually see it in interchange. When you're dependent on fee income, you always have to have a game plan to become less dependent on that in the occasion that it eventually becomes unable to, you become unable to charge for it. And that's always going to happen either by regulation, by someone in the marketplace coming and doing something that changes the market. And now you can't be competitive if you charge these types of fees. There's a new technology that makes those fees, makes the product obsolete so consumers don't need it anymore. Something always comes up eventually. Blockbuster, we saw it with that. Same thing with overdraft. Same thing with maybe interchange coming up. So the lesson here is, well, when or why these things happen, I don't think is irrelevant. What's relevant is you have to prepare for if it does what are you going to do to replace that revenue
SPEAKER_02:now on your list of topics and i i love or maybe i hate this because it's so got washington dc alphabet soup that we have the ncaa voluntary egr pra review i love egr hey ladies and gentlemen today we're going to talk about the egr pra review i hope you brought your notes what the heck is this about
SPEAKER_01:okay that's so that's And the reason I like to bring stuff like this up is because it's boring. No one likes to talk about reg reviews. IGRIPRA is the acronym, and it's where the agencies will take a look at their rules and see where they could do some streamlining, trying to update them, modernize their rules, because the rules are written years ago. At some point, they become dated, and we kind of forget about it, and especially in this ever-evolving industry where every Everything's changing overnight. Our rules have to keep up with all of that so that the industry can work with them. The NCUA does a one third regulatory review every year where they look at one third of their regulations. So they put out one third of their rules for public comment. What can we change with these one third? And they do that every year. And then they analyze the comments and they make changes based on that. And they actually do it. A lot of agencies kind of do that and just kind of it's academic. It's an academic exercise. I don't feel like it's academic at all with the NCUA. There were a lot of rulemakings that have happened because of these reviews. And this one is voluntary, where the other agencies have to do it. The NCUA does it by voluntary nature, and it's the Economic Growth and Regulatory Paperwork Reduction Act, IGREFRA rule, where they're, again, taking a look at all of their regulations. And right now they're looking at, for this year, they're looking at three sections. I think it's consumer protection, capital, and public policy. programs. It might be the third one. So I always point this out because it's an excellent time for folks in the industry to take a look at those three topics, see if there's anything in the rules that really troubles them, current NCUA regulations that makes it difficult to do their job, even if they're little things. The little things taken together add up and become big things. And really communicate with their trade associations, communicate with whoever they have doing their advocacy, or just Write down a letter themselves to the agency because the agency reads everything. Chairman reads everything. All these folks read everything. I used to think when I would write comma letters, who the heck's going to read this? I felt like no one's reading this. I could tell you, I guarantee you, based on my work at the NCUA, they read everything. The board members go through all those letters themselves and read them. It's unbelievable. They really care about the feedback that the industry gives them on these things, whether it's through letters, whether it's through media, it's always very helpful to them. And then they go through those common letters and see what changes can be made to the regulations that aren't going to hurt the safety and soundness of institutions, but that are going to make things easier for credit unions to run. So I always want to point this out because it's not sexy. It's not provocative. It's not fun. Like interchange is fun. Taxation. These are all fun issues that, you know, we could talk about and debate and looking at little, you know, detail-oriented regulations or things at the operational level that are small, like a deadline for getting in a merger application or board member change to your board, the deadline for that. Some of these are very minuscule changes, but if they're problematic for your institution, write them down, send them to somebody or send a letter yourself by October 8th, I think is the SIGGRIPRA deadline, so that the agency can make these changes and make things easier for your institution.
SPEAKER_02:You're making a good point, which is, to an outsider, to me, all the paperwork at an NCUA seems irrelevant, boring. On the other hand, this is the essence of the institution. The institution actually lives by the regulatory rules that are down there. If there's stuff in those regulations, stuff in the rules that a credit union doesn't like, finds difficult to comply with and pointless, speak up. Now's the time.
SPEAKER_01:some might not understand that they're actually going to be listened to. When you send in letters, I mean, the NCUA is an agency that doesn't get typically a ton of comment letters. I mean, if you were in a situation like the CFPB where you're getting thousands of letters sometimes on issues or hundreds or thousands, it might feel like, oh, no one's going to look at my position. That's not the case there, but it might feel like that. But even at the NCUA, we get like 30 letters, 20 letters. I mean, not a lot of letters on some of these things. And I would think to myself, gosh, your industry is really missing an opportunity here because all of these letters are getting read. Even the most, you know, seemingly benign recommendation is getting looked at and analyzed and could be, you know, taken into account in an upcoming rulemaking if they could stick it in something, you know, stick it in a change that they're going to make. It's really an area that's not provocative and interesting and fun, but the area where you can really, even the smallest credit union, have an amazing impact on the entire industry. And I think it gets overlooked. So whenever you see these reviews, I can't urge people enough to figure out what's happening in your institution that's problematic. Tell your trade association, tell whoever works for you on advocacy, or just write a letter with that one issue. You that one issue, say, hey, I don't have time to analyze the whole rule, but here's an issue that really is upsetting to our credit union that makes our jobs difficult and put that one issue. And then say, I defer to the trade association on everything else. That's fine. And I wanna point this out, especially because even when I was at CUNA working on regulatory advocacy, we were always trying to get feedback from the industry on things that could make their lives better in terms of operations. And it wasn't always easy to get that feedback. You know, as an advocate, I'm not in the credit union, so I'm not seeing that day-to-day that everybody else is seeing. So that's the other reason why it's really helpful for credit unions to pay attention to that. And
SPEAKER_02:we've proven here that there is still reason for concern, even though taxation is off the tape. Although, as I said earlier, we'll come back. Before we go, think hard about how you Get in touch with me. This is rjmcgarvey at gmail.com. Robert McGarvey again. That's rjmcgarvey at gmail.com. Get in touch. We'll figure out a way that you can help. We need your support. We want your support. We thank you for your support. The CU 2.0 Podcast.