Location is important in nearly all businesses for various reasons, whether it be accessibility or security or tax treatment. It's a cost of doing business. At its December meeting, the NCUA Board issued a proposed rule that would require federal credit unions to operate out of commercial buildings zoned for retail use. The very fact that the agency has to issue a rule about this is preposterous.

Running a credit union out of someone's home presents major safety concerns. Any mentally unbalanced or criminal member could threaten the manager with no one else around, or worse yet, with family present. Examiners could be attacked by managers with no witnesses to what happened. Managers have challenged that examiners have no right to access home-based credit unions. While an extreme case that actually did occur in a commercial building, the Taupa Lithuanian Credit Union scenario was a huge eye opener to the safety issues examiners could face, and stockpiling a weapons arsenal would be much more likely and potentially legal in someone's home. Other less dramatic safety issues are of real concern for members and examiners, such as rickety staircases or dog bites. Really, who wants to see a rabid examiner?

Privacy concerns are another obvious problem for a home-based credit union. It is difficult to ensure the credit unions' records are safely locked up and that precautions have been taken to avoid accidental destruction by fire or flood in the manager's basement. Additionally, other members of the household might access these documents, inadvertently or for nefarious reasons, in violation of privacy laws.