Credit unions by and large have been seen as the good guys in the ongoing housing finance crisis. In general, more conservative underwriting prevented most credit unions from making the mortgage loans that were most likely to wind up delinquent. Further, when credit union loans have become delinquent, CUs have generally been better positioned to modify them to help out their struggling members, particularly when they have not sold the loans or, if they did sell them, they retained the servicing.

But some CU executives charge that an NCUA policy on how credit unions must track modified loans actually increases their paperwork burden so much that it can lead them to decide on foreclosures over modification in some circumstances.

The NCUA's policy on troubled debt restructuring is meant to keep an eye on modified or restructured loans to make sure that borrowers who had trouble making previous loan payments are able to make the new loan payments. CU executives acknowledge that such tracking needs to take place. But they contend that the way NCUA requires them to track the loans both increases their burden and needlessly hurts borrowers  seeking to repair damaged credit ratings.