Can we agree that NCUA's responsibility, per the Federal Credit Union Act, is to "form" safe and sound," single, multiple or community group credit unions? Can we agree this survey was mailed to all "existing" federal credit unions who passed these charter requirements "long ago"? Is it not true that once we were vested with the powers of the Federal Credit Union Act, that it became "our" responsibility to "select" the services we provide our group and "not" NCUA's? Is it not true that all of us serve a group or groups of individuals with a name or names? Notice the title of NCUA's survey, "Service to people of Modest Means." Do we provide "service" to a "group or groups of individuals" name "People of Modest Means?" Let's be sure by opening our existing charters to the field of membership (FOM) section. Can you find them in your FOM? Of course not! This is the beginning of yet another "historic move" by NCUA. This voluntary survey is the invitation soliciting an agreement to the NCUA's beliefs. Beware! We can be held accountable when considering the answering of this survey. Notice the bait and switch tactics of NCUA. The very first question invites us to define the group of individuals in the title "People of Modest Means" as the "lower income members" of our existing group. Then with questions 9 and 11, this definition advances from lower income members to include a lower income group or community. We should say "no" to all of these questions. Questions 3, 4, 5, 6, 7, 8 and 10 all refer to how we provide "services" to this group of People of Modest Means. Is it not true that we shall be violating the spirit of the FCU Act and the NCUA's rules and regulations if we serve anyone other than the group or groups of individuals named in our field of membership? Well then, the survey is complete and we truthfully answered "no" to each and every question. The outcome of completing this survey can be dangerous. Will the stated numerical parameters become the future rule of qualifications for each new group or groups of individuals? Can it lead to special requirements for who qualifies to sit on our boards? Can it lead to providing services that NCUA deems necessary? Each credit union must decide how the "truth" addresses these questions regarding the present and future actions of credit unions and NCUA? Can we now see how serious these issues are? Do you believe NCUA has moved beyond the limits of their authority? How will the choices we are about to make lead to our demise? Perhaps it is truly better to be safe than sorry. All of us should answer this call. The question is, how should we respond? How do we provide a unified out, address our true beliefs, defuse the political pressure that currently exists on the NCUA Board and preserve our past, present and future freedom to choose according to the existing FCU Act? Why not consider returning the survey blank and attach this statement as follows, "We oppose any initiative to define the phrase people of modest means including how we should service them." Perhaps it is the fundamental right of each individual to decide whether or not he or she is of modest means - not NCUA, credit unions or anyone else. Since this survey has yet to reach us, please consider my concerns. Will "The Truth" prevail? David Stien President Crane FCU
Will the truth prevail in NCUA's survey on "Service to people of Modest Means?
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