The OTR is the funding the NCUSIF provides to the NCUA for overseeing state charters as it pertains to safety and soundness issues. Each year, the NCUA sets the rate based on the percent of time spent on state charter oversight.

Federal credit unions want it higher to minimize the NCUA operating budget they fully fund. State charters want it lower because the NCUA is not their primary regulator, even though the federal agency gives state regulators computers and develops software to assist with the regulation of these credit unions.

The NCUA's 2013 Annual Report stated that 2,449 of the 6,554 credit unions were state chartered. State-chartered credit unions had 44 million members to FCUs' 53 million, and $491 billion in assets to FCUs' $571 billion.

Additionally, in some cases the NCUA just reviews state regulators' work, but these data don't account for the complexities of individual credit unions and the great flexibility of some state regs, which are significant factors. The OTR is a legitimate charge, and to its credit, the agency has tried to clarify how it determines the OTR in the last decade.

Technological challenges/CU lack of preparation for the digital economy/intelligent self-service

I'm pretty typical as a consumer when I say I don't care how technology works, as long as it works. So ease of use and reliability are two priorities for me. So is efficiency; I would much rather ring up my groceries at the self-checkout than wait in line. Yes, banking is about relationships but technology does not preclude that.

The credit unions that matter are ready for the digital economy or at least well on their way; the ones that aren't will not matter very soon.

And that's OK, too.

Lack of data strategy

Credit unions possess a wealth of data about their members. Harnessing, interpreting and properly employing that data are infinitely crucial. Great branding and marketing is far more strategic than most credit it, but turn a sophisticated marketing executive loose on that data. Use it to develop every communication – written, spoken, body language, visual cues, scents, whatever – among credit union employees and externally to the field of membership. Rigorously developed branding digs into that data and generates results to the top line.

Response to online reviews

If credit unions are not monitoring their image online, see the paragraph about the ones that do not matter. For those that are, see the paragraph immediately preceding this one. You can't bury your head in the sand, railing that social media is just a fad. One billion people use Facebook. What are the chances your members and potential members are not among that billion? Considerable brand reputation damage can be promulgated anywhere.

Risk-based capital

Proposal bad. Looking forward to revisions. Until then, I just can't write about it again.

CFPB

Finally, CFPB management, which is supposed to protect consumers from discrimination, among other things, has been caught up in a web of discrimination and bullying tactics. The demographic breakdown of its employee review does demonstrate discrimination is involved. The agency, however, could not provide us with the demographic breakdown of its managers. Ponder that.

The agency's fix is implementing a pass/fail review system. In the meantime, the agency is spending $5 million to give everyone a raise as if they scored perfectly on their review. Good thing the CFPB has unlimited resources via the American taxpayers they're saving from discrimination. Let's give everyone a trophy for participating.

The agency hosted listening sessions with its employees to find out their thoughts about the culture. The commentary was very consistent, yet CFPB management fails to admit its lapses. The 39-page report uses phrases like "perceived unfairness" and "perception" of "structural inequalities" 21 times. That much perception is reality, even if unintended, and it stems from the culture exhibited by management.

Sarah Snell Cooke is publisher/editor-in-chief of CU Times. She can be reached at [email protected].