The NCUA's recent proposal that credit unions pay the federal regulator a fee to oversee the derivatives program has raised complaints among credit unions. NAFCU immediately fired off a statement supporting credit unions' entry into derivatives, but blasting the fee as setting bad precedent because the $250 million threshold would divide the industry, and the fee itself would create a barrier to credit unions' use of derivatives. On the contrary, I find the idea innovative.

The proposed fee would set precedent but not necessarily a bad one if taken in a broader context. I'm not arguing that the NCUA's proposed dollar amount for the program is correct, but hear me out on the concept.

The vast majority of credit unions apply risk-based pricing to their lending programs. The members they trust more to pay them back are charged less. The non-borrowers don't pay interest on loans they didn't take out. Credit unions charge members fees for the products they use because there are expenses and values attached to them. I don't know about your credit union, but mine doesn't charge me because another member used a foreign ATM.