On May 20, I posted remarks on BRUEN Credit Union Blog (www.cbruen.com/blog) about the failure of a very small 213-member, $175,000-asset and, surprisingly, 50-year old credit union with a delinquency rate of 40%.

I subsequently received criticism from the Credit Union Times Editor-in-Chief Sarah Snell Cooke for making the following observation: "It is my opinion that there are credit unions that are too small to exist. How small? Guess I would start by finding ways to shutter anything less than $1 million and then raise the bar from there."

Whether one likes it or not, in today's complex operating environment the small credit union's days are numbered. It has become nearly impossible for the over 1,000 credit unions in the NCUA peer group under $2 million in assets to successfully achieve the minimum regulatory standards expected from a federally insured financial institution.