
NCUA Board Member
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Dee Donald Crisp CEO, Government Employees FCU, Austin, Texas
We are looking at risk-based capital. NCUA needs to remember that credit unions have a system that is effective. The vast majority of losses during the financial crisis were due to corporate credit unions. RBC2 saw some improvements in the risk weightings, but there is a problem with a two-tiered system. We all are in the business of managing risk every day. No one wants to take on more risk than their credit union can handle.

Robert Hamer, president and CEO, Mobiloil FCU, Beaumont, Texas
I am not as concerned as others about the member business lending cap because of the low-income credit union exception we qualify because of the area we serve. What really bugs the heck out of me is the field of membership rule. It seems to be more of an accommodation to the banks than logical. If the MSA [Metropolitan Statistical Area] is San Diego, that is millions of people within a few square miles. But many of us work with areas that are big geographically but have a small population. If credit unions can show that their growth or service is constrained, they need to be able to expand to an adjacent MSA.
In today's world of electronic delivery, and in our case, with the people who work in the oil industry moving around all the time, there is no reason not to serve broader areas. We have members in 40 of 50 states, but we cannot put a branch in Houston to serve our members there. Why not let us?

Armando Martinez, president and CEO, Kingsville Community FCU, Kingsville, Texas
The risk-based capital regulation should not even be on the books. I manage a small credit union with $14 million in assets. I see a lot of mergers with small credit unions. My concern is the supervisory examiners are not handling examinations well and are causing us to be merged out. I do not know what the proper channels are to get my concern addressed. I see credit unions in my area being merged out without getting a chance to correct their supposed issues.

Jason Boesch, manager, Energize CU, Oklahoma City, Okla.
I think the list could be endless if you could name it, there is a regulation that needs to be relaxed. I also am concerned about what is still to come from CFPB. Who knows what they will think of next?
The Truth In Lending implementation has been monkeyed about so much in the last several years we virtually cannot do any open-ended lending any more. Lending now takes more paper, more time and is more difficult for the members.

Michele Douglas, accountant, DPS FCU, Oklahoma City, Okla.
I would like to see the CFPB demonstrate that it knows we are different from banks. That want to come down on credit unions, but they do not take into account we were not the problem that led to the financial crisis. The CFPB could exempt us, but they don't.










