First and foremost, let's be clear: NAFCU listened to its members in 2009, and we listen to them now. We fight every day to make our members and the credit union movement stronger. As noted correctly in Ms. Anderson's April 16 column, NAFCU has always been steadfast in strongly opposing the CFPB's rulemaking authority over credit unions. At every possible opportunity, in hearings and in myriad letters to Congress, NAFCU has been unequivocal in its conviction.

Throughout the legislative negotiations in 2009, NAFCU strongly challenged the CFPB's authority over credit unions. Specifically, it was at the hearing before the House Committee on Small Business on Sep. 23, 2009, where Price Choppers Employees Federal Credit Union President and CEO Dawn Donovan, testifying on behalf of NAFCU, clearly stated our position. Notably, this was the only official hearing where credit union trade groups testified before Congress on financial reform, including the creation of the CFPB (earlier proposed as the CFPA). As Donovan pointed out: "NAFCU does not believe such an agency should be given authority over regulated, federally-insured depository institutions, and opposes extending this authority to credit unions.

"As the only not-for-profit institutions that would be subject to the CFPA, credit unions would stand to get lost in the enormity of the proposed agency. Giving the CFPA the authority to regulate, examine and supervise credit unions, already regulated by the NCUA, would add an additional regulatory burden and cost to credit unions."