NCUA Public Affairs Specialist John Fairbanks said the credit unions insured by the NCUA have about 0.65% of their total assets invested in the bonds that are the subject of the fiscal crisis. The cooperativas, by comparison, have millions of dollars invested in government bonds.

There have been no discussions of the NCUA taking over the cooperativas, Sosa-Llaorens and Fairbanks said. 

"An NCUA staff member has made a single trip to Puerto Rico to get a first-hand look at the situation," Fairbanks noted.

The memo to the House committee stated more technical and oversight assistance might be needed from the Treasury Department in consultation with the NCUA.

"Involvement of these agencies may require congressional authorization and we advocate such consideration by the committee," the memo said.

Until now, the cooperativas have not suffered tremendously from the island's fiscal crisis, said Luis Gallardo, an attorney and a city council member in Aguas Buenas, who has written extensively on the Puerto Rican debacle.

"Actually, in comparison to commercial banks, co-ops in Puerto Rico are actually holding it down pretty well," he said. "Don't get me wrong, there have been major losses and a little more than a third with deficits at the moment, but they are hanging in there."

The cooperativas currently have more than 966,000 members and total assets of $8.47 billion.

The memo also stated the island's cooperativas constitute one of the main institutional investors in commonwealth bonds and that the Puerto Rican government has an "inherent duty to protect the safety and soundness of financial systems and of preserving the savings of members and depositors."

Congress indicated it is struggling with how to deal with the Puerto Rico crisis. The House Natural Resources Committee recently released a draft of legislation that would place the crisis in the hands of a fiscal oversight board. That board would have authority over the cooperativas.

"We continue our conversation with the government," Sosa-Llorens said, adding that the negotiations are complex.

The Puerto Rican government has offered proposals that Sosa-Llorens said would put the cooperativas at a distinct disadvantage over other investors. The cooperativas group is proposing that investors voluntarily accept payment on the bonds based on the entry point — the price at which each bondholder purchased the bonds. That would be much fairer than other proposals that have been offered — plans that Sos-Llorens said would favor mainland borrowers over island borrowers.

In addition, in the memo, cooperativa representatives alleged that COSSEC pushed the cooperativas to purchase government bonds through improper use of its regulatory powers, threats of punitive taxation and increasing the regulatory limits of such investments.

It also said Puerto Rican law and regulations limited the cooperativas' investment options.

"Time has confirmed the inappropriateness of these regulatory actions and the risks resulting from having relied on them," it said.

COSSEC officials could not be reached for comment.

Meanwhile, it's business as usual at most cooperativas, Gallardo said.

"On the streets, it is common to hear that 'co-ops are the only ones lending right now,'" he commented.