Tom Dorety's opinion column on credit union conversions in theApril 19 issue deserves some perspective. America's CommunityBankers proudly represents about 90% of all mutual community banksin the country, and Tom's observations on mutuality needcorrecting. Mutual savings banks are almost as old as our nation.They have thrived for nearly 200 years because they are known fortwo very special qualities – independence and community service.They have helped millions of families live the American dream byoriginating countless loans for homes, cars, education and smallbusinesses. To suggest, as Tom does, that, “the only former creditunions that retain or plan to retain mutual ownership are quitesmall . . . a large mutual thrift has become . . . difficult tolocate . . . . ” misses the point that mutuals thrive onself-determination. Please don't tell Third Federal S&L, amutual holding company in my hometown of Cleveland with $8 billionin assets, that it is “ difficult to locate.” And please don'tdeliver the message to my friends at Dollar Bank FSB in Pittsburgh,which has $5 billion in assets, that it is difficult to locate.Assets like that are hard to hide. Mutuals like Third Federal,Dollar Bank and many more are visibly serving their customers andbuilding their communities. Tom also notes that the “NCUA hasbecome the major target” of the banking industry. Now, how do yousuppose that happened? Let's take a look. The United States has thestrongest financial service system in the world because ofdiversity based on self-determination. Like the nation itself, ourfinancial system is based on freedom of choice. There is oneconstant in the financial services marketplace, and that constantis change. Institutions must be free to change – to changestrategies, to change business plans and to change charters ifnecessary to remain competitive and to fully serve their customersand communities. Institutions must be free to change from state tofederal charters, from mutual to stock, from savings banks tocommercial banks – as the need arises. Notably, the NCUA is theonly regulator that directly inserts itself into the conversionprocess to preclude change. Encouraged by allies, it alone adoptscampaign tactics, engages in rhetoric unbecoming of a regulator,and tries to stop a natural process that should ultimately bedecided by credit union members. Why does the NCUA presume that theonly reason for charter choice is greed? Why is it that thecapable, hardworking management of a credit union one day issuddenly portrayed as greedy and deceitful insiders the next daywhen they are helping their members understand the conversionprocess? We believe the role of the regulator is to protect theright to charter choice, not inhibit it, and certainly not tocampaign against it. The effect of NCUA's regulations and itsoperations mislead credit union members about conversion, and theyconflict with similar conversion rules established by other federalregulators. Credit union members under the leadership of theirmanagement and elected board have a right to seek the charter thatmeets their needs and that of their communities. A regulator's roleis to ensure that appropriate rules are followed, and that membersreceive full disclosure. That means credit union members must hearboth sides of the story – for conversion and against. Regulatorsshould not game the system in ways that prevent credit unionmembers from deciding for themselves what is in their bestinterest. As CU Financial Services president Alan D. Theriaultexplains. “Credit unions convert to a bank charter because of painor opportunity. Capital issues, product limits, and poor consumerawareness create pain. Expanding service to a growing community,filling voids left by banks and credit unions, and maximizingpersonnel and infrastructure potential provide opportunities.” Itis time for Congress to help the NCUA understand its role. In abipartisan approach last year, Congressmen Patrick McHenry (R-N.C.)and Ed Towns (D-N.Y.) introduced the Credit Union Charter ChoiceAct. H.R. 3206 which would make it possible for credit unions toconvert using the process Congress established. Their bill wouldbring certainty and fairness to the conversion process. And, mostimportant of all, it would protect the rights of credit unionmembers to charter choice, a fundamental and core value in the U.S.financial system. America's Community Bankers is committed tocharter choice for all depository institutions. We believe thatcredit union members should be free to choose for themselves whichcharter to follow, and to do so on the basis of full and completeinformation. And when all credit unions have the same opportunityfor choice that banks do, I will know that I have done my job andenjoyed doing it. As the old song says, “let freedom ring.” And letcredit union members enjoy the full measure of their freedom tochoose. Diane Casey-Landry President America's Community BankersWashington, D.C.