Regulators require a substantial amount of information to evaluate a proposed merger. Faced with the task of assembling a merger package, credit unions can respond in one of three ways:
* Submit an incomplete package and supplement it as information becomes available or is requested.
* Gather and submit anything that might possibly be of interest to the regulators.
* Submit a complete, well-organized package that includes no extraneous information.
The first two responses are appealing because they allow the review process to begin sooner. Starting sooner, however, does not necessarily lead to finishing sooner.
Each request for additional information introduces lag time-identifying missing information, requesting that information, waiting for it to be delivered, and then waiting for the package to rise again to the top of the review queue. Credit union staff must interrupt other activities to respond to each request. Any time or effort saved in preparing the incomplete initial package is lost with the first or second request for additional information.
Submitting a grab bag of information leads to an even less timely result than a well-organized but incomplete package. The review process takes longer because regulator resources are required to organize as well as evaluate the information. This is in addition to the delays caused by an incomplete package, because the disorganized package will almost certainly be incomplete.
The third response is the most efficient and produces the best results, including regulator good will. The NCUA has published good guidance about the necessary contents of a merger package. Translating NCUA's checklist into a spreadsheet, making assignments for document production, and managing the receipt of the information enables the production of a complete, well-organized merger package. Such a package enables the regulators to focus on the merger decision and render it quickly.
Carol Stryker is a long-time credit union veteran and consultant with SymbioticSolutions, Houston. She can be reached at 713.252.3361, or at CarolStryker@symbioticsols.com.
