This week, the NCUA and otherfinancial regulators will testify before the House FinancialServices Committee and discuss the impact of red tape on thecountry's consumers.

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While having the NCUA discuss credit union issues beforeCongress is certainly welcome, NAFCU is just as concerned with whatmay not be discussed.

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Transparency should not only be reserved for the positive. Andthere have been a lot of positives lately. The most recentannouncement from NCUA that credit unions may not have to pay anyfuture corporate assessments was certainly good news. The more than$1.75 billion in total recoveries from securities lawsuits isunbelievably positive. The share insurance fund continues toimprove as the number of CAMEL 4 and 5 credit unions decreases.

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But with all the fantastic news coming out of the NCUA, NAFCUstill believes the agency needs to do more. The NCUA is a stewardof credit union dollars, and credit unions need to know how all ofthe dollars they send the NCUA are applied. Yet each new piece ofgood news from the agency sometimes leaves us with morequestions.

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A case in point is the cost of lawsuits related to corporatecredit union losses. The 2013 audit report for the TemporaryCorporate Credit Union Stabilization Fund reports an aggregate $390million in professional fees, but it is unclear specifically whatthis amount covers. Unfortunately, this gives credit unions noinsight into any specific costs of litigation and whatever othercosts may be reflected in this total.

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Similarly, the details on management of legacy assets by theAsset Management and Assistance Center are also under-reported.Currently, only lump-sum figures tell the story of the legacyassets and the underlying NCUA Guaranteed Notes program. Thesefigures are based on the agency's current assumptions about thefuture performance of the assets.

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The NCUA, however, has not disclosed any details about theseassumptions, and it has provided no insight as to how the agencyreached these assumptions. While current assumptions point to noexpected assessments in the near future for the stabilization fund,it would be helpful for credit unions to know which factors andcircumstances figure in those assumptions.

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This insight would allow credit unions to incorporateappropriate safeguards to protect themselves should the assets andlitigation recoveries not perform in the manner NCUA expected.

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Additionally, we need more details about the NCUA's budgets.

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NAFCU believes these are very important questions that deserveanswers, not because we believe there is necessarily anything tohide, but because every NCUA dollar is a credit union dollar. Thisis why we have submitted several Freedom of Information Actrequests to learn the details of the expenses that are coming outof the Central Liquidity Facility, the National Credit Union ShareInsurance Fund, the NCUA operating budget and the TCCUSF.

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Because these funds are fully supported by credit union assets,credit unions are entitled to know how each is beingmanaged.

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NAFCU believes transparency should be part and parcel of NCUA'sdaily operation. We hope that we continue to see the positives, butwe want that whole picture to come to light. This could be ahallmark that the NCUA can be proud of.

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Dan Berger is president/CEO of NAFCU. He can be reachedat [email protected] or (703)522-4770.

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