To the Editor:

Associate Professor Elizabeth R. Schiltz of Notre Dame Law School is correct in singling out credit union lobbyists as "the best of the best in 1998" in her Aug. 19 commentary.

However, under the guise of complimenting the credit union lobby for conducting "one of the most forceful and effective grassroots campaigns in history," Ms. Schiltz denigrates credit unions for not addressing credit unions' tax status and exemption from the Community Reinvestment Act, or CRA.

She writes: "Nowhere ... in most of the public rhetoric around this legislation, was there any mention made of the more controversial aspects of the proposed legislation: whether credit unions should retain their exemptions from paying taxes and complying with the Community Reinvestment Act."

I would remind Ms. Schiltz and your readers that the issue-following a course all the way to the Supreme Court, through Congress and to the President's desk-involved neither taxation nor CRA but rather restrictions on credit union fields of membership.

At no time did the legislation contain any provision for altering credit unions' tax status or applying CRA to credit unions.

Despite the best efforts of the banking industry to persuade Congress that tax and CRA exemptions were the issues, legislators saw right through this smoke screen. Congress registered its recognition and support of the true issues with its overwhelming votes in support of the Credit Union Membership Access Act (411 to 8 in the House of Representatives and 92 to 6 in the Senate).

Kenneth L. Robinson

President,National Association of Federal Credit UnionsWashington

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