I just read Mike Welch's Jan. 12 column, "Waving the Flag for Small CUs Not Smart," on small credit unions and I just had to share my thoughts. I think a lot of us fear not so much the disappearance of small credit unions but rather the disappearance of all credit unions. There are more small credit unions than larger ones so naturally we are losing more small ones, but we are also losing medium and large ones. Mergers, conversions and heavy competition between credit unions have reduced the number of federally-insured credit unions from 10,998 as of the end of 1998 to 9,369 at year end 2003, a reduction of over 3% per year on average. In 2003 this accelerated to 3.3%. This means in 10 years, even if the rate of consolidation stays the same and does not accelerate, the number of credit unions will be reduced another 30% or more to approximately 6,500. These are troubling statistics because unlike banks and other industries, the credit union industry has no realistic means of rejuvenating itself by forming new credit unions. Do we really think that the current regulations for forming new credit unions will produce viable financial institutions that are capable of serving their members? These regulations are old and antiquated and were developed during different economic conditions and a different time in history. Welch's example of "mom and pop grocery stores" etc. also seems wrong. Small business is the backbone of our economy rather than a dying concept as you suggest. Thousands of small businesses are started every year. Some are successful, many fail, some grow, and some get bought by larger businesses. Regardless of what this all means, the movement seems to be content on ignoring these troubling statistics. Rather then seeking changes in regulations that would make it more realistic to charter and develop new credit unions, credit union leadership is more interested in changing regulations dealing with secondary capital, business lending and PCA. I wonder which credit unions need these changes? Ray Ponteri CEO El Paso Employees FCU El Paso, Texas