Editor's Note: this letter was written in response to SAFE CU CEO Henry Wirz' letter to the editor that ran under the headline "Credit Union Testimony Was Delusional" in the Sept. 17 edition.
Call Me Delusional. I love when CEOs discuss issues from their perception and think the rest of us must be stupid unless we follow along or do not agree with them. Though I personally do not feel regulations are No. 1 on my list of concerns, I can at least see why others would have it on their list as No. 1. I can assure you it is in my top five.
Why?
* Credit Card Act-how many of you still have fixed-rate credit card portfolios?
* How many of you had to change due dates on your revolving loan products due to regulations?
* How many of you have to end open-end lending on auto and other loans?
* How many of you have lost income from regulations-overdraft income, interchange income?
* How many different forms have you changed in the last couple of years? Risk- based pricing notice, new mortgage disclosures (high-rate mortgages) credit card disclosures; increasing expenses plus hiring compliance people to handle all the changes.
* New proposed mortgage form-1099 pages of instructions?
* Possible rewrite of what is factored into an APR-requiring core systems and forms to be reprogrammed and designed to handle the new APR.
* Insane new disclosure requirements if you do more than 100 international remittances yearly.
* Possible regulation limiting the number of overdrafts on any account to as low as six per year.
This does cover of course US Patriot Act, BSA, Home Mortgage Disclosure Act (HMDA-Regulation C); Equal Opportunity Act (Regulation B); Fair Housing Act; Fair Credit Reporting Act; Truth in Lending (Regulation Z); Homeowner Protection Act (HOPA); Real Estate Settlement Procedures Act (RESPA); Fair Debt Collection Practices Act (FDCPA); Secure and Fair Enforcement for Mortgage Licensing (Safe Act) and, the FACT Act.
Plus all the new "stuff" the CFPB has in surprise for us.
So while I agree growth is important, is it possible that smaller credit unions cannot offer their members many of the products we offer, due to flood and complexity of all these regulations? So if I agree with some credit unions having this on the top of their list, especially smaller credit unions, then just call me delusional.
Michael Silvers, CEO
Valley Federal Credit Union
Billings, Mont.
