Sometimes, it pays to get back to basics. The long-standing credit union motto “not for profit, not for charity, but for service” is a relevant and very useful tool to use as credit unions move forward into the 21st century. Since their inception nearly 100 years ago, America’s credit unions have been committed to serving their members. It is that commitment of member service that has propelled these not-for-profit financial cooperatives into the vital and indispensable role they play for consumers all across the economic spectrum. Through the vision of Edward Filene, the founder of the credit union movement in the United States in 1908, America’s financial cooperative system flourished in the Northeast; soon a “movement” was afoot to expand the credit union system across the United States. The guiding principle of financial cooperatives of “people helping people” remains consistent to this day. The unique structure as member-owned, volunteer-run, not-for-profit cooperatives has resulted in a sustained safe and sound credit union system. The credit union system is at the forefront of realizing an “ownership society” for Americans from all walks of life. Whether it is helping members buy their first home, send a child to college, provide access to affordable health care, or open or expand a small business to create jobs and empower the entrepreneurial spirit, credit unions have been a vital partner to millions of Americans. America’s credit unions are known for their excellence in serving consumers; anecdotal evidence, combined with survey after survey showing high levels of satisfaction with credit unions, makes this case quite powerfully. But there is a challenge that accompanies this stellar reputation. That challenge is to reassure lawmakers that credit unions are fulfilling their legislative mission, and to be able to continue doing so with minimal government mandates and burdensome regulation. With over 85 million members nationwide, credit unions continue to be a target of those who desire to curtail consumer choice of financial services. In today’s challenging political climate and financial services’ competitive nature, the nation’s credit unions are positioned more than ever to demonstrate service to their members, especially to those serving underserved neighborhoods and the “unbanked”. It is proven everyday. However, I encourage credit unions to consider that in this ever changing, dynamic marketplace and legislative environment, credit unions can seize this opportunity to document their service and success in serving millions of hard working Americans. The recent announcement by the NCUA of its intent to begin a pilot initiative to collect data from some federal credit unions should not alarm those with a belief that the NCUA is on a track toward enacting a Community Reinvestment Act-like regulatory requirement. Nothing could be further from the truth. I sincerely believe credit unions are serving their members, and furthermore, look forward to a comprehensive review of membership data highlighting the role of how credit unions are meeting the financial needs of their members. For the last few years, NCUA has had a team of dedicated agency staff exploring ways to realize that in order to collect data, we must have a process that does not create a heavy-handed, micro-managing regulatory burden of excessive paperwork. Toward this goal, recently NCUA requested a review with the Office of Management and Budget for this proposed pilot initiative to collect the data under the Paperwork Reduction Act. We are pleased that NCUA’s plan would allow for gathering data without burdensome surveys and unnecessary forms. Through the examination and supervision process, the agency can ascertain information utilizing the normal methods and procedures. The examiners are planning to collect the data as part of the routine examination process. With specific interest expressed by Congress and the Government Accountability Office (GAO) concerning the measurement of service to members, the NCUA plans to initiate a process to collect data from Federal credit unions in the following areas: *The extent and type of services provided to members; *The income distribution of members, ; and *The reliability and value of this preliminary data. To ensure this data is statistically sound for federal credit unions, a random selection process was used to identify 481 federal credit unions across charter types for participation. After the information is aggregated, it is likely NCUA will determine that additional or different data should be collected from a larger number of credit unions to allow for a valid statistical analysis and discussion of member service by charter type. It is our belief that any assessment of income distribution must also include an assessment of the types of services offered by a credit union. Credit union staff involvement would be limited and focused on discussions with management or other appropriate personnel. Once the initial valid statistical sample has been collected, the information will be reviewed for its completeness and accuracy. After review, it will be consolidated and made available to Congress and/or the GAO, along with the NCUA’s comments and analysis. I have long believed that credit union members are the truest and fairest arbiter when it comes to measuring service. NCUA understands the role you play in the lives of your members and encourages you to continue that culture of service to all of your membership. Edward Filene said it best, “the credit union movement.it is a great movement, worthy of great deeds, deserving of great loyalty.”

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