To the Editor:

In your March 10 issue, former FDIC Chairman William Isaac, now a consultant to financial institutions, takes the National Credit Union Administration to task for adopting its policy in 1982 allowing federal credit unions to serve more than one membership group ("NCUA-Not Ludwig-Is the Real 'Rogue Regulator,'" page 5).

Mr. Isaac calls the policy unfair to community banks that now must compete with larger credit unions. The fact that credit unions-large or small-are not-for-profit cooperatives and thus fundamentally different from banks goes unmentioned.

It's also odd that Mr. Isaac should attack the multiple-group policy now. Having served as FDIC chairman in 1982, he was part of the administration that encouraged this multiple-group policy, because it was in the best interest of credit unions and consumers. In fact, President Reagan in November 1982 wrote then-NCUA Chairman Edgar Callahan congratulating the agency on its deregulatory efforts.

Mr. Isaac, who worked closely with Mr. Callahan on the Depository Institutions Deregulation Committee, the Federal Financial Institutions Examination Council, and other venues, certainly was aware of the NCUA's rationale for the policy at the time and raised no objections during his tenure on the FDIC board.

But truly it is Mr. Isaac's vantage point that has changed, not the sound public policy reasons for the NCUA's action. We're confident Congress will also recognize that providing greater choice in the financial services marketplace may not please fee-hungry banks or their consultants but will serve consumers well.

Scott Sutherland

Senior VP, communications,

Credit Union National Association

Washington

If credit unions had remained "fundamentally different from banks," we wouldn't be having this debate. The credit unions want to offer-free of any meaningful common bond-all the services community banks provide. And they want to continue their exemption from taxation and bank-type regulation. That's a great deal for credit unions, but a lousy deal for their competitors and taxpayers.

As for Ed Callahan's actions in 1982, I had more than enough to say grace over at the FDIC. Mr. Callahan didn't ask for or receive any advice from me on how to regulate credit unions.

My firm serves as a consultant to all sorts of financial institutions, not just banks. I believe in free markets in which the best competitors prosper. The government has a responsibility to make sure its tax and regulatory policies don't distort the competitive playing field.

William M. Isaac

Chairman and chief executive officer,Secura GroupWashington

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