The April 9, 2012 article ("Post-Merger Issues Surface in Florida) about Space Coast Credit Union (SCCU) reported it recently made headlines in two areas: (1) Its $100-million claim against Wall Street banks and rating agencies on failed investments, and (2) The 2011 Florida Bank Complaint Analysis (FCB Analysis), which found it had a disproportionately high level of complaints.
Since the article emphasized SCCU's SVP-Marketing Meredith Gibson's criticism of the latter analysis and its author (me), it is necessary to set the record straight:
I have been analyzing financial institutions in Florida for over 40 years as an independent consultant and economist, rather than "someone who is supposed to be an expert," according to Ms. Gibson.
The FCB Analysis was conducted using actual customer complaint data from Florida's Division of Financial Institutions of the Office of Financial Regulation since 2008. There is no subjectivity involved in reporting these raw complaint data from the state. There is no way this analysis can be "mischaracterized," as it is simply reporting the facts.
The analysis calculates the Bank Complaint Index (BCI), which is the proportion of an institution's complaints divided by its deposit market share. The lower the BCI the better, and anything over 1.0 means a disproportionate high level of complaints. This was the case at two big banks (JPM Chase at 2.3 and Citibank at 1.2). However, none of the major financial institutions in Florida came anywhere close to SCCU's outlier BCI of 6.5 in 2011 and 6.8 in 2010. Contrary to Ms. Gibson's opinion, the analysis did not "take one outlier...and... ignore the rest of the obvious outliers, and draw such a simplistic conclusion." Rather, SCCU was the ONLY outlier in the analysis, and that was one of the conclusions.
The complete FCB Analysis was provided to both the reporter and Ms. Gibson, who had requested it both this year and last year. Thus, SCCU had more than a year to review it and point out anything they felt was "mischaracterized" or "simplistic," but, they remained silent until this article. (FYI, none of the other institutions mentioned in current or past analyses made any negative comments about the methodology or findings).
With all due respect to Ms. Gibson, she would be better off focusing her marketing efforts on bringing down SCCU's disproportionately high complaint level, one of the main messages of the FCB Analysis, rather than shooting the messenger.
Ken Thomas, Miami, Fla.
