Corporate Town Halls Coach Members on Reg Comments
Despite the NCUA-directed cancellation of Western Corporate Federal Credit Union's town hall meetings, wholesale credit unions not under conservatorship are moving full steam ahead assisting members as they prepare their comments regarding proposed corporate regulatory changes.
The $4 billion Mid-Atlantic Corporate Federal Credit Union is set to stage its fifth town hall meeting on the subject on Jan. 27 in King of Prussia, Pa., and has six more member meetings planned through Feb. 18. Senior Vice President of Marketing Leigh Philibosian said the Middletown-Pa.-based corporate scheduled the events in Pennsylvania, Delaware, New Jersey and Maryland to make it convenient for members to attend.
President/CEO Jay Murray will discuss proposed Part 704 regulations that concern Mid-Atlantic, like new volunteer and NEV modeling requirements. However, Philibosian said the town hall meetings will primarily focus on moving forward because Mid-Atlantic feels it could operate under the proposed regs as written.
"The whole point of our town hall meetings is to lay out our plan to members regarding how we will reach these higher capital levels," she said. Mid-Atlantic will ask members to convert member capital accounts to perpetual contributed capital. The corporate does not need any new money to meet the proposed 4% Tier One capital requirement if members agree to the conversion, Philibosian said.
Mid-Atlantic will also do away with correspondent-only and investment-only member relationships, requiring a capital contribution from new members.
The $1.3 billion Constitution Corporate Federal Credit Union is planning to facilitate four or five town hall meetings for members before the NCUA's March 9 comment submission deadline, said President/CEO Bob Nealon.
Nealon said his Wallingford, Conn.-based corporate is playing a "very extensive role" in helping members prepare their comments for the NCUA because the 252-page proposed rule is overwhelming.
"I think they're just looking for some guidance, so that's why we put together a nice summary that boils it down to about 12 pages," he said. Nealon said his corporate is most concerned about the "cost and time" required to comply with new NEV modeling requirements but said, based on conversations with NCUA staff who prepared the proposed rule, he's optimistic industry comments will be given serious consideration.
Constitution Corporate intends to provide members with a sample letter they can use as a cornerstone in preparing their comments for the NCUA. The corporate wrote a similar letter for members during the ANPR process, he said, and while some members took advantage of it, others "have their own perspective on things" and created their own letters from scratch.
Philibosian said Mid-Atlantic will not provide a sample letter to members but will post its own comment letter online for members to review, and it may also create and post online a document that "focuses on some key points that are of most concern to us."
WesCorp President/CEO Phil Perkins had written a sample letter for members but later removed the critical document from the corporate's Web site and told members in a Jan. 7 e-mail that WesCorp will henceforth "remain silent" regarding proposed regs.
"Given the fact that WesCorp is a conserved institution under NCUA control, we do not want to attempt to influence or even appear to influence the comment process in any way," Perkins wrote in the e-mail to members, which was obtained by Credit Union Times.
"The ability of WesCorp members and other industry participants to have a say in the form and content of the new regime is of paramount importance, and at this critical juncture, where opinions and input matter a great deal, WesCorp is particularly mindful of the need to avoid any activity that may negatively affect the process," he continued. WesCorp also cancelled town hall meetings it had scheduled on the topic.
Corporate One Federal Credit Union Vice President of Marketing and Communication Paul Hixon said his $3.6 billion corporate credit union probably won't stage any town hall meetings before the NCUA's March 9 comment deadline. However, that decision was made in part because President/CEO Lee Butke had just hosted member meetings in November and December to discuss the corporate's financial condition, and Butke discussed proposed corporate rule changes with members at that time.
Corporate One has provided members with information regarding the regulatory changes in its newsletter and will probably prepare a formal document for members in February regarding the corporate's official position. It will not create a sample comment letter for members, Hixon said.
"We haven't received a lot of questions from members preparing their comments," he said. "I don't know if that was due to the town hall meetings late last year or if members are satisfied with the information we've presented so far."
However, Corporate One will host town hall meetings after the final regulations are released, he said.