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As NCUA and CFPB consider raising their respective asset ceilings, CU executives are weighing in.

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In a letter to the editor, County City CU President Tom Pinnow expressed his belief that CUs with fewer than $50 million in assets are "besieged and seriously threatened" in an environment where the definition of "small" just keeps getting bigger. The letter, "If Small CUs Die Off, What Happens to the Movement?" sparked more comments on www.cujournal.com than any previous article, and they're still rolling in.

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Several CU Journal readers left comments supporting County City CU President Tom Pinnow's views. Not surprisingly, most were from other small credit unions in the $20 million-to-$40 million range, but at least one large CU, with assets of $374 million, weighed in, as well.

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Randall Smith, CEO of the $374 million T L C Community CU, Adrian, Mich., said, "Unfortunately I think the really big credit unions will eventually be the downfall of the entire movement — leading to taxation which will end the need for being a credit union. Small or large, we used to be able to easily differentiate ourselves from other FIs... not so easy anymore, and now we are thinking about director compensation?"

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Allan Ontai offered a unique perspective as the former executive of a $12 million CU who now works for a $70 billion bank: "I don't know the future of small credit unions but with the current generation (X, Y and Z), small money institutions are not even on their radar. How to change that??? That is the $$ future question.... Today's generation does not even recognize small credit unions as a viable [resource to solve] monetary problems that face Gen X, Y and Z. Small credit unions will have to come together and differentiate themselves from the large CUs and create their own message and strategic plans. I merged my small ($12M) CU into a medium ($350M) CU and am now working at a $70B bank. I see and hear the difference, and it is real!"

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Lynn Gray of $41 million Remington FCU, Ilion, N.Y. said, "I agree with every word you said, however I feel the small credit unions have to take up the fight for their life. If we don't, we will be gone within the next five to ten years, and those members on the lower incomes will be fee'd to death by the large credit unions and banks and will have no place left to go."

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Cookie Yoder, CEO of City Co FCU, Pittsburgh, urged CU leaders to support small CUs by keeping NCUA's threshold at $50 million. "I totally agree with this excellent article! Shame on our movement's leaders if we do not take a stand and allow this to happen. Small credit unions have a very important place and we need to support them. Our credit union is 20M and we provide excellent service to our members. I also feel that $50M is a good asset size to be considered small, not $100M."

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"The reality is $250 million is going to be the answer," said Greg Shaver, CEO of the $29.7 million Chino FCU in Silver City, N.M. "There are regional banks out there with $2 billion in assets that consider themselves small. The problem with small credit unions surviving is: will they be able to provide competitive products and services? If not, why are members going to continue to do business there? Economies of scale do exist and make it difficult to compete. I am all for small credit unions, but just like in any other business, you have to be able to satisfy the needs of your members (customers) or you will die. If small CUs can do that and stay competitive, then I'm all for it. Subsidies to help them will only delay the inevitable."

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Karen Griffo, CEO of $26 million Roswell Community FCU, Roswell, N.M., agreed that small CUs have a special place in the movement — and in the hearts of their members. "Great article, Tom. You're spot on when you said we are family to our members. I've worked in two small credit unions in my career of 24 years and can't imagine being anywhere else. No position could bring more satisfaction. We do make a difference in our members financial lives. We are tech savvy and offer most every electronic service available, we feel its securing our future. 26M and strong!"

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NCUA has issued a proposed rule that would raise the agency's definition of "small" from $50 million to $100 million. The vote was unanimous, but they expressed differing opinions on what the true definition should be. The lone Republican on the board, Mark McWatters, said raising it to $100 million doesn't go far enough, suggesting NCUA should adopt the same definition three bank regulators use: $550 million. Vice Chairman Rick Metsger agreed with raising it to $100 million but expressed concern that the move could put the smallest CUs at a disadvantage.

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NCUA officials considered a $250 million asset ceiling, but they opted for a lower figure after concluding credit unions with less than $100 million have significantly slower rates of deposit, membership and loan growth than their larger counterparts, according to John Worth, NCUA's chief economist. NCUA Chairman Debbie Matz joined her colleagues in voting for the $100 million threshold, noting the importance of small credit unions. The rule will go out for a 60-day comment period.

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Credit unions applauded introduction of a bill that would raise the asset threshold for direct supervision by the Consumer Financial Protection Bureau from $10 billion to $50 billion, but the measure's eventual fate remains uncertain.

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CU Journal Editor in Chief Lisa Freeman warns against allowing this issue to divide the credit union community and urges credit unions to file comments with NCUA — and post their thoughts on the subject at www.cujournal.com.

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