Sorry, but I disagree with Sarah Snell Cooke's assessment that home-based credit unions are preposterous. ("It's All About Location, Location, Location", Jan. 8, 2014, Credit Union Times.)

Home-based CUs have existed for many years, without this sudden and urgent discovery that they pose significant risks to examiners. If the NCUA wants contact info, they can review the List of Officials that is a part of every 5300 Call Report. This is a weak leg on which to stand.

As far as safety, security and privacy – well, all of these can be addressed individually with the target credit unions. If they are non-compliant, action can be taken. But to presume that all credit unions can afford the relocation to, as well as the ongoing expenses of, a commercial retail space is simply revealing the disconnect between what the NCUA perceives and the reality for these micro enterprises. I do respect (Cooke's) opinion, however, and hope that this will spur some valuable discussion on the subject.