On the other hand here in NYC we have a slew of credit unions that have been around for decades that are doing fine, working out of such “unprofessional” areas as the backs of churches or in a corner somewhere.

Nobody's having to bail them out. In fact, they took substantial hits to net worth because of the corporate credit union fiasco that was in part the NCUA's doing. Talk about professionalism.

The real problem is it may be hard for some of us to believe, but there are a lot of people out there in our country who've never been into a bank nor want to go into one. For instance, I was working with Lac Courte Oreilles credit union in Wisconsin – it's on a reservation – and they were astounded at the number of 50+ year old new members that had never seen a bank. (They used cash and money orders to get by.)

My posting here is more of a musing about how things have changed, and lamenting NCUA's true colors showing, vis-à-vis tiny credit unions.

Yes, of course, credit unions need to grow and most of them need to be run from offices, and of course the consolidation of the number of credit unions will continue.

But, the NCUA's “kick them while they're down” approach is less than helpful. (The NCUA means well, I am sure, but the effect of yet another rule/regulation is to “kick them while they're down.”)

By the way, I am completing a strategic planning session at Love Gospel Assembly FCU in the Bronx. They started in 2005 with manual record keeping and only volunteers and only open on Sundays. They now have a professional office and help many, many people. But would they have been able to start with the new rule being proposed? Maybe not.

By the way, I just got back from a six-month gig in Mongolia working with credit unions there. Talk about small! Wow! But they are really important to the people there. It was fascinating. «Rural» is really rural there.

Brian Gately, CUDE

CEO

Credit Union Consulting Services

Brooklyn, N.Y.