But credit union executives don't work for private companies. They work for nonprofit organizations owned by the members who pay their salaries. Credit unions are one of the only, if not the only, nonprofits not to disclose executive salaries. I don't see how they can avoid it.

-Low-income service data collection will also become a reality--not a Community Reinvestment Act requirement but, again, from NCUA's Outreach Task Force proposal. The collection will hardly present any more burden to credit unions except those that are not online and those credit unions need to ask themselves where they are heading in the 21st century and beyond.

NCUA's proposal would have the data disseminated in aggregate so no individual credit unions would be singled out. However, I firmly believe NCUA needs to be cautious not to regulate according to findings from this data collection--that's not its purpose.

I've heard from some, 'What if Congress asks NCUA for more specific information?' So what? Credit unions overall have nothing to hide, and maybe those credit unions that need to be doing a little bit more to serve their respective fields of membership will get a swift kick in the pants.

Credit unions would show up the banks and provide proof that they don't need CRA. That won't satisfy House Financial Services Committee Chairman Barney Frank (D-Mass.), but it sure could sway some fence sitters in Congress.

-Treasury's Blueprint proposal could be a blessing in the conversions arena. There has been buzz around Washington for years about merging the Office of the Comptroller of the Currency and the Office of Thrift Supervision; I think that has a high probability of happening in the next five to 10 years because of their similarities. The thrift trade association has even merged with the American Bankers Association.

A credit union seeking to convert to a mutual savings bank and then add a mutual holding company where it can sell off 50% in stocks, as has been the recent trend, would lose that reason to convert.

On the other hand, it's been suggested to me that credit unions might use the consolidation of all the depository institution regulators, including credit unions, to be the perfect reason to convert if they're all going to become banks anyway. Not going to happen: Credit unions are too strong a force in Congress. Frank has said as much, as has Capital Markets Subcommittee Chairman Paul Kanjorski (D-Pa.).

In my mind, the structure as a nonprofit cooperative takes precedence over the function as a financial institution.

-Ah yes, cooperatives. Credit unions need to do more of that, and by this I mean, you guessed it, a national branding campaign. I really don't understand the resistance. Absolutely credit unions should maintain a strong individual brand but that does not have to be to the exclusion of a national credit union brand.

Look at the Got Milk? campaign, which has proven both popular and effective. Milk had an even bigger advantage than credit unions--everyone knows what it is. Skim, 2%, whole milk. How many Americans know what a credit union is? How many credit union members really know what a credit union is?

True story: A couple nights ago out of the blue at the dinner table, my six-year-old son asked me the difference between a bank and a credit union. I smirked proudly and tried to explain in kindergarten terms. I'm in the industry, but credit unions need to prompt the children of nurses and schoolteachers and janitors to ask this question. How else do you capture Gen Y, or even Z?

-The war and the housing crisis has taken nearly everything off the legislative agenda for the year. Last I heard there were two open, scheduled legislative days left for the U.S. Congress. Like someone with little or no savings hitting an emergency situation, sacrifices have to be made. Advancing the Credit Union Regulatory Improvements Act (H.R. 1537), while a noble cause, will be one of them.

The bright side is the best bet for CURIA, or its spawn, the Credit Union Regulatory Relief Act (H.R. 5519), is to move it piecemeal, even now more than before. No one believed CURIA would pass as is anyway. Credit union lobbyists were creative in trying to attach the member business lending initiatives as part of the stimulus bill. Keep it up!

However, I wonder at the wisdom of CURRA. Will those key provisions in CURIA that are not in CURRA, like broader business lending expansion and capital reform, fall on deaf ears without the milder provisions encapsulated in CURRA if it passes?

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