To the Editor:

Norman D'Amours, chairman of the National Credit Union Administration, should be commended for calling attention to the social role that credit unions were created to fulfill. (See "Chief Credit Union Regulator Plans to Propose Own Version of Community Reinvestment," July 29, page 2.)

A variety of studies, some by the credit union industry itself, have shown that its membership base has become increasingly affluent over the years. The curious result has been that in many cases small taxpaying community banks with Community Reinvestment Act obligations serve a more financially modest population than the larger, nontaxpaying credit unions that they compete with and that have no CRA obligation.

By law, state-chartered credit unions in Massachusetts have CRA obligations, and their CRA exam results are made public. Though their CRA record is not equal to that of Massachusetts banks, the existence of a formal regulatory review is a step in the right direction. It is an acknowledgement that without a focus on those with limited means the rationale for credit unions' unique status begins to collapse.

When American Banker writes that Mr. D'Amours has been controversial for "his belief that (credit unions) care more about growth than serving the poor," the controversy he has caused serves a very meaningful purpose from a public policy perspective.

Daniel J. Forte

President

Massachusetts Bankers Association, Boston

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