The consolidation "could also create a structure that is more responsive--not only to consumers' needs, but to the legitimate concerns of all financial service providers, irrespective of size or statutory authority," he said.

New York CUs, he said, "feel it's essential to maintain credit union representation on the governing body of this new department." He added, "Just as vital is that any consolidated department includes an office specifically dedicated to credit unions to preserve the unique and vital role they play in communities throughout New York State. Such an office would guarantee appropriate expertise."

Mellin said also that creation of the new department "should not be undertaken as consolidation for its own sake, however. The state needs to seize this opportunity to ensure that financial oversight not only becomes more cost effective, but also fosters greater accountability."

The CUANY head also expressed dismay the existing Banking Department has not been far more forceful over the years in promoting the state charter. "It seems they could become a whole lot more and they don't and their reasoning has always been lack of resources," he said. His trade group would be less receptive to the consolidation plan if the agency had been more of an advocate for state CUs, he said.