I read Sarah Snell Cooke's editorial on the NCUA's proposed ruleon home-based credit unions (“It's All About Location, Location,Location”, Jan. 8, 2014, Credit Union Times.) At first Ithought you wrote it with a tongue-in-cheek approach. For instance,I loved your following comment:

“Other less dramatic safety issues are of real concern formembers and examiners, such as rickety staircases or dog bites.Really, who wants to see a rabid examiner?”

On the other hand, rereading her editorial, I think I may havemisconstrued her intent. I really do think she believes “location,location, location” is paramount.

Well, maybe it is. My wife just retired from Citibank where sheworked for many years. They have great locations. But they wentbankrupt and the rest of us had to bail them out. We had stock withthem that fell in value precipitously.

On the other hand here in NYC we have a slew of credit unionsthat have been around for decades that are doing fine, working outof such “unprofessional” areas as the backs of churches or in acorner somewhere.

Nobody's having to bail them out. In fact, they took substantialhits to net worth because of the corporate credit union fiasco thatwas in part the NCUA's doing. Talk about professionalism.

The real problem is it may be hard for some of us to believe,but there are a lot of people out there in our country who've neverbeen into a bank nor want to go into one. For instance, I wasworking with Lac Courte Oreilles credit union in Wisconsin – it'son a reservation – and they were astounded at the number of 50+year old new members that had never seen a bank. (They used cashand money orders to get by.)

My posting here is more of a musing about how things havechanged, and lamenting NCUA's true colors showing, vis-à-vis tinycredit unions.

Yes, of course, credit unions need to grow and most of them needto be run from offices, and of course the consolidation of thenumber of credit unions will continue.

But, the NCUA's “kick them while they're down” approach is lessthan helpful. (The NCUA means well, I am sure, but the effect ofyet another rule/regulation is to “kick them while they'redown.”)

By the way, I am completing a strategic planning session at LoveGospel Assembly FCU in the Bronx. They started in 2005 with manualrecord keeping and only volunteers and only open on Sundays. Theynow have a professional office and help many, many people. Butwould they have been able to start with the new rule beingproposed? Maybe not.

By the way, I just got back from a six-month gig in Mongoliaworking with credit unions there. Talk about small! Wow! But theyare really important to the people there. It was fascinating.«Rural» is really rural there.

Brian Gately, CUDE

CEO

Credit Union Consulting Services

Brooklyn, N.Y.