I'm not a fan of the bureau. For starters, its effort is duplicative. If a credit union is breaking the law, or allowing members or vendors to do so, the NCUA should detect that in its exams. If existing financial regulators are unable to effectively monitor those activities, they should be provided with more resources – or forced to use existing resources more effectively – instead of creating yet another government bureau to double check their work.

It's enough to make me SMH.

Additionally, FinCEN is one of those secretive, conspiracy theory-inducing agencies that used 9/11 to increase its powers and as a result, weaken privacy rights.

Yes, terrorists could harm the U.S. by taking down our financial system. However, anytime the government uses fear of an overseas boogie man to collect vast amounts of data on the everyday activities of Americans, I'm suspicious and can't help but SMH.

The leaked document called out 50 credit unions that FinCEN said works with suspicious money services businesses. However, none of these credit unions were accused of breaking the law or violating regulations.

Instead, FinCEN said the network is concerned credit unions aren't sophisticated enough to detect money laundering operations and might not report them to authorities. Here's the part that makes me SMH: FinCEN arrived at this conclusion because credit unions are filing more suspicious activity reports to authorities.

After 9/11, there was a much publicized federal government effort to increase communication and information sharing among agencies. The million-dollar Sensitive Compartmented Information Facility at the NCUA, required by Treasury no less, was part of that effort.

But did FinCEN involve the NCUA in this report at all? My sources say no. Instead, FinCEN delivered the report to the NCUA like an authority figure to a peon. That doesn't say much about Treasury's confidence in the NCUA or its respect for the agency's regulatory authority. SMH.

NCUA Chairman Debbie Matz should be furious FinCEN produced this report without any input from the industry's primary regulator. Further, she should be livid the report was leaked from such a secretive agency.

This leak wasn't an accident.

They say there are no true friends in Washington, and that's especially true for journalists. Oh, people are friendly, but only as long as it advances their agenda. Even among true friends there's the understanding the agenda always come first. It's always about the agenda.

I'm not sure what the agenda was here. Maybe the Treasury is trying to chip away at the NCUA's reputation in an attempt to disband the agency. Maybe a banking lobbyist convinced a FinCEN employee to leak the information for banker political gain on Capitol Hill. Maybe this is another example of Treasury's Operation Choke Point initiative, which bullies financial institutions into cutting ties with industries it claims are risky, but are also conveniently politically unfavorable.

I don't know, but each possibility makes me SMH.

I also SMH because the NCUA continues to focus so much on protecting the share insurance fund while focusing too little on the industry's reputation risk that arises from fraud.

Maybe another NCUA action that makes me SMH could solve this problem. Joe Shoshoo, WesCorp's former onsite examiner, was recently named the agency's specialty examiner of the year. Maybe the NCUA should put him in charge of BSA compliance.

(Don't laugh. Remember, this is Washington, it could happen!)

CU Times has pressed the reputation risk issue for years, and now that NCUA Board Member Mark McWatters is focused on the topic, I'm sure we'll cover it again in the future.

And I'm sure I'll SMH.