In response, some credit unions have decided to charge fees for certain services that otherwise might have been offered for free, in the name of consumer protection of course.

The Bureau of Consumer Financial Protection, also born out of the Dodd-Frank Act, like any other government bureaucracy will only add to the compliance burden and expenses. Though it is encouraging the bureau has shared streamlined and combined TILA and RESPA paperwork, adding another rulemaking body logically can't make things easier.

The NCUA has already created an office of 13 staffers dedicated to consumer financial protection in response; the agency's budget approved in 2009 said it expects the office will be fully staffed at 30. By 2010, the authorized staffing level was 37, though only 30 were included in the NCUA budget. Additionally, Dodd-Frank also required an Office of Minority and Women Inclusion with staffing of six at the NCUA. Each item, plus the National Treasury Employees Union contract, pushes the NCUA budget, which is entirely funded by credit unions, higher and higher.

At the same time, credit unions are having a tough time lending and margins are compressing even further. Credit unions' loan-to-share ratio fell below 70% in the first quarter of this year, according to CUNA, for the first time since 1994. ARMs, fixed-rate mortgages and used autos are leading the way in credit union lending.

And straw polls I've done show that most credit unions are selling off the fixed-rate mortgages to help avoid the interest rate risk, which the NCUA has been strongly encouraging.

But what will ultimately be the role of Fannie Mae and Freddie Mac in the housing market and how will that impact your credit union's ability to underwrite mortgages? Will a credit union solution arise? There are rumblings of this as the market has stabilized.

Used autos have been a popular option for cash-strapped, nervous consumers, but how will Japan's earthquake affect that? Toyotas and Hondas have been known for their long life spans, but if the parts that previously were coming out of Japan are unavailable, what will that do to used auto lending? Should credit unions be making nice with the domestic dealerships?

Then there's the competition. Target has introduced a pass-through rewards debit card (see article, page 16). Rewards will push them top of wallet and what little interchange income you were getting into the retailer's pocket. Ironic that retailers are usually at fault in card data security breaches, yet they could be taking the interchange income that credit unions and other financial institutions are supposed to be collecting to pay for expenses related to breaches.

The American Banker also recently reported a linkup between Microsoft's Xbox and PayPal. We recently reported (in the May 4 issue) on some overseas banks integrating Xbox's Kinect into their branch functionality.

With the national average credit union ROA at 51 basis points as of year-end 2010, what's a credit union to do? Credit unions don't need to turn a huge profit, but they at least need to keep the lights on. But if credit unions don't generate earnings, they can't grow and offer the services their members expect from financial institutions. Then they could become extinct by irrelevancy.