I read with interest Mike Welch's column (CU Times, Nov. 17) on Norm D'Amours attacking credit unions in a recent speech, and as a career NCUA employee I have some comments. My career with NCUA started with General Nickerson as administrator in 1974 and finished with Dennis Dollar in 2003. The only dark spot in that time for me (and the credit union industry) was the reign of Norman D'amours. What he didn't get in his championing of small credit unions is that while the concept of small institutions providing critical financial services for limited income members is a service model that has limited applicability. The resources and expertise that are needed for member service cannot be obtained from the limited income membership base. Risk based lending, a concept that he championed, cannot occur totally at the high end of the risk scale. To work it requires a broad range of borrowers, not just a "risk based interest rate". Over time numbers change. When I started with NCUA there were over 20,000 credit unions. Today the number is less than 9,000 (or so). The math is simple. The concept of a large number of small institutions providing service to a variety of communities and income groups is gone. Now we have (and will continue to have, I hope), a moderate number of credit unions providing service to an ever increasing and diverse group of members. We call that economies of scale. Former NCUA chairmen Dollar and Roger Jepson realized that and promoted outreach through credit unions that could provide the resources to get services out to people with limited resources. Those gentlemen had the vision of helping the largest number of people in financial need in the most effective manner possible. While that focus does not fit the somewhat idyllic model of groups of small people working as group to their own financial betterment, it is getting the services out there. The function of the regulator is not to worry about the number of institutions and their smallness, but whether credit unions are doing their job; providing financial services to people who need them at reasonable cost. Mr. D'Amours didn't get it while he was there and apparently never will. Joseph Visconti Retired NCUA employee Austin, Texas