Joliet, Ill.

“We are proud to have been the lending choice for a myriad of new firefighters sent off in their first new car. We have conducted countless share transactions, opened sixteen new accounts, and counseled members on the red flags of elder financial abuse. We work hard, often late nights and weekends – but it's worth it because we are serving our members in the way they deserve to be served,” said Joliet Firefighters President Robert Surinak in his comment letter to the NCUA.

“While the home based model no longer fits the needs of the vast majority of credit unions – it fits us. The proposed rule to mandate a commercial office would lead to our demise, and leave 522 devoid of the credit union they built, and that is unconscionable.”

Read more: B. I. Federal Credit Union …

B. I. Federal Credit Union

$5 million

Pittsburgh, Pa.

“One advantage we have as a home-based credit union is minimal expenses for fixed assets such as a building or lease expenses. Moving out of our current location into some type of retail or similar space will have a dramatic impact on our budget should this rule be finalized,” said the credit union's board of directors in a comment letter.

“We do not believe the NCUA has the legal authority under the Federal Credit Union Act to require a credit union to operate in any particular type of office space or working environment. We trust you will consider our comments in good faith, and will ultimately determine not to require our credit union to move into commercial office space,” wrote the board of directors.

The board's letter also said B. I. provides a safe environment for examiners.

“During examination cycles we have always maintained a clean, safe and healthy working environment for our own staff and for visiting NCUA staff and have never received any complaints,” the comment letter said. “We have a dedicated phone and fax machine line, email address and website.”

Read more: Our Family Social Credit Union …

Our Family Social Credit Union

$521,016

Omaha, Neb.

“If this rule is passed, and if it then applies to OFSCU, it will likely mean the end of our credit union,” wrote David Cain, president of the board of directors, in his comment letter.

“We currently have almost 500 members, all cousins, living in more than 20 states. While we may be small, we have been a lifesaver to countless cousins, as we have made over 1,000 loans to cousins totaling over $6,000,000.00 since 1950. We know that many of our borrowers would not have been granted loans without us, as the amount was too small or the credit rating too low,” he also wrote.

Larry Cain, correspondence secretary on the board of directors, also sent a comment letter to the NCUA.

“Regarding the safety concerns of the examiners, we have never had any issues with our examinations. In 63 years, our (home-based credit union) has never had any pets on the premises,” wrote Larry Cain.

“Thus, we have never had any issues with violent pets or allergies related to pets. In 63 years, we have never had examiners climb up or down steps in our homes. The visits have always been conducted at the same dining room table we have our board of director meetings and supervisory audits,” he added.

Read more: First Frontier Federal Credit Union …

First Frontier Federal Credit Union

$449,099

Lynbrook, N.Y.

First Frontier Treasurer Dan Maloney wasn't pleased when he watched the NCUA's video recording of its monthly December board meeting, when it introduced the proposed home-based rule.

“If you listen to that board meeting, they were making all these jokes about how all these credit unions are old or whatever and they're just waiting to die,” Maloney said. “I mean, that's pure B.S. There's no backup to their anecdotal stories. There's no statistics, no numbers, no nothing. It's an inside joke to them that 'these credit unions are all dying and we're just going to finish them off.'”

Cecil Maloney, president of First Frontier, said although he voted for President Obama, he is frustrated with his administration over the NCUA's proposed home-based credit union rule.

“I voted for President Obama … here we have Obama leading this government and all these federal agencies are cracking down on the little people – why is that? I just don't understand it,” Cecil Maloney said. “I think he knows everything that's happening and it's breaking my heart to think that we may have to close down after 28 years of trying to do the right thing for people.”

Read more: Aldersgate Federal Credit Union …

Aldersgate Federal Credit Union

$4 million

Marion, Ill.

“I am respectfully requesting the NCUA withdraw its proposed rule, as the requirements would paralyze this credit union and effectively remove small home-based credit unions from the collective credit union map,” said Manager Marilyn Sullins in her comment letter to the NCUA, adding that her credit union is run by volunteers.

“The rule, if passed, would significantly increase our operating expenses and consequently, negatively affect not only our 754 members but also the financial health of the credit union,” Sullins also said.