Credit unions are speaking out against a rule proposed by theNCUA that would force credit unions out of homes and intocommercial offices.

CU Times reviewed each comment letter posted as ofTuesday on the NCUA's website. The following eight credit unionswere among the overwhelming majority opposing the proposal:

Also of Interest:

HomeOffice Ban Would Be Unconscionable: Letter to theEditor

Debate:Home-Based Credit Unions

The $371.5 million Abilene Teachers Federal Credit Unionin Abilene, Texas

“It seems rather odd that NCUA knows what's better for smallhome-based credit unions regarding their facilities than the actualcredit union Board of Directors and its members. Will we soon seean ambient temperature rating that we are required to keep for NCUAexaminers when they are onsite?” said President/CEO James Boyd in acomment letter on the proposed rule.

“In effect this rule will force some small home-based creditunions to no longer exist. Does that mean NCUA will reduce itsstaff and budget? This type of decision is one that the Board ofDirectors and the membership make, not NCUA,” Boyd added.

Read more: Rent would significantly increaseoperating expenses …

The $4 million Aldersgate Federal Credit Union inDanville, Ill.

“I am respectfully requesting the NCUA withdraw its proposedrule, as the requirements would paralyze this credit union andeffectively remove small home-based credit unions from thecollective credit union map,” said Manager Marilyn Sullins in hercomment letter.

“The rule, if passed, would significantly increase our operatingexpenses and consequently, negatively affect not only our 754members but also the financial health of the credit union,” sheadded.

Also of Interest:

Whythe 'No' Vote on NCUA Home-Based Rule

Editor's note: According to AFCU's Dec. 31, 2013 callreport, the credit union paid $473 in office occupancy expense lastyear.

Read more: No examiner complaints yet…

The $5 million B. I. Federal Credit Union in Pittsburgh,Pa.

“One advantage we have as a home-based credit union is minimalexpenses for fixed assets such as a building or lease expenses.Moving out of our current location into some type of retail orsimilar space will have a dramatic impact on our budget should thisrule be finalized,” said the credit union's board of directors in acomment letter.

The board's letter also said B. I. has a safe environment forexaminers.

“During examination cycles we have always maintained a clean,safe and healthy working environment for our own staff and forvisiting NCUA staff and have never received any complaints,” saidthe comment letter. “We have a dedicated phone and fax machineline, email address and website.”

Editor's note: According to BIFCU's Dec. 31, 2013 callreport, the credit union paid $3,600 in office occupancy expenselast year.

Read more: Neutral exam site wouldn't work…

The $11 million Cal Poly Federal Credit Union in Pomona,Calif.

“I believe the members of the credit union should decide if theyneed and can afford an office. I do not believe NCUA should mandateit,” said CEO Barbara Bean.

“I work in a small credit union and trying to hold ameeting/exam outside of our office would not work. The amount ofpaperwork that is examined is huge. To put that all together andcarry it back and forth to some alternative location on a dailybasis during an exam would simply not work … we are talking threeto four bankers boxes of files going back and forth on a dailybasis,” Bean also said.

Read more: Loss of home-based credit unions wouldspur identity crisis …

The $19 million Community Plus Federal Credit Union inRantoul, Ill.

“The symbolism of the home-based credit union is very importantto the identity of the credit union movement. What are the coredifferences between credit union and banks? Credit unions arecontrolled by volunteer members. Their mission is to serve thefinancial needs of their members, not make a profit forstockholders,” said President/Manager Michael Daugherty in hiscomment letter.

“Nowhere is this more apparent than in the home-based creditunion. It is true that the home-based model no longer fits theneeds of the vast majority of credit unions. Our world changes andcredit unions have changed with it. Yet, a small number of homebased credit unions cling to the original credit union model. Weshould cherish them and support them in whatever way we can.Instead, this proposed rule would effectively end them,” Daughertyadded.

Read more: Assets safeguarded in home…

The $341,887 Dallas IHC Federal Credit Union inColleyville, Texas

“The expense to provide an office would certainly cause ourexpenses to rise so much that it would create a hardship for us,”said President/CEO Fable Griffin.

“We currently have our records in a fireproof safe with a backupthere in the safe. All efforts are made currently to make theassets of the credit union safe. I do not support this proposalbecause it would so negatively affect the smaller credit unions,”Griffin also said in the letter.

Editor's note: According to DIHCFCU's Dec. 31, 2013 callreport, the credit union did not pay any office occupancy expenseslast year.

Read more; No pets on the premises…

The $521,016 Our Family Social Credit Union in Omaha,Neb.

“Regarding the safety concerns of the examiners, we have neverhad any issues with our examinations. In 63 years, our (home-basedcredit union) has never had any pets on the premises,” wrote LarryCain, correspondence secretary on the board of directors.

“Thus, we have never had any issues with violent pets orallergies related to pets. In 63 years, we have never had examinersclimb up or down steps in our homes. The visits have always beenconducted at the same dining room table we have our board ofdirector meetings and supervisory audits,” he added.

Cain also said the NCUA's examiners have never communicated anyconcerns with the credit union's accommodations.

Editor's note: According to OFSCU's Dec. 31, 2013 callreport, the credit union paid $9,300 in office occupancy expenselast year.

Read more: What about disaster recoverysites?

The $2 million Queen of Peace Arlington Federal CreditUnion in Arlington, Va.

“While the Queen of Peace Arlington FCU does not currentlyoperate from a residential address, we do use a residential addressas one short-term disaster recovery site,” said CEO DanielMorrisey.

“Such a residential site, for example, might be used for ashort-term transition period until the regular office space becameavailable or an alternate site could be arranged. The way I readthe proposed rule, any such use of a residential address would beabsolutely prohibited.”

Morrisey said prohibiting the use of a residentialaddress, even for a short period, would be costly forsmall credit unions.

“In fact, a number of years ago, during a several-month period,this credit union was based in our home because of an issue of ouruse of the sponsor's location,” he wrote. “Once that issue wasresolved, the credit union returned to the sponsor's property.During that period, had this rule been in effect, I seriously doubtthat we would have been able to continue the operation of thecredit union.”