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Mike Welch asks the question “what am I missing” in advocating the split of NCUA/NCUSIF (CU Times, Nov. 7). I would respond that he may have misplaced some very important lessons of the past along with a reasoned frame of reference on this issue. First, with perhaps the most knowledgeable and friendly NCUA Board and Chairman in decades, why do we now insist on poking a stick in the eye of folks who have listened to credit unions and made positive changes when appropriate, such as Reg-Flex? They have been given, by law, the task of deciding the allocation from the NCUSIF to NCUA for operating expense. I support encouraging NCUA to adopt a fair standard for identifying, substantiating and applying equitable cost sharing for these “insurance related costs”. NCUA has significantly improved their budgetary process and committed to real reductions in expenses that will benefit FISCUs and FCUs alike. They have listened to the arguments regarding the OTR, and have revised the overhead transfer rate lower, again indicating they are reasonable and can be reasoned with. Second, what is the logic of creating a second agency with all of the overlapping bureaucracy, staff and expenses. While it may serve to differentiate expenses, it also adds significant additional expense. Government agencies with modest initial purpose tend to take on a life of their own. This duplication of effort and expense would eventually strengthen the argument for the consolidation of federal deposit insurance agencies. Third, the threat of having our insurance fund being swept into FDIC’s Bank Insurance Fund (BIF) or Savings Association Insurance Fund (SAIF) is not idle. FSLIC is now FDIC’s SAIF. Do we really want to risk becoming a part of the bank and S&L risk pool? Premiums related to deposit growth may soon impact BIF participants, and other issues related to a different product mix including commercial and foreign lending may cause premium assessments in the future. We’re much better off covering our own risks with our own fund. Fourth, with the loss of the independent insurance fund, it would be logical to have the NCUA report to Treasury along with the Office of Thrift Supervision(OTS). The precursor to OTS was also independent. It’s clear that credit unions, as unique financial cooperatives, would get lost in the shuffle of a larger regulator. Indeed it may be central to our survival as credit unions that we continue to have an independent regulator. A few short years ago, some in our movement were prepared to accede to Treasury’s request to write-off our 1% NCUSIF deposit in return for preserving our independent regulator. Thankfully, that didn’t happen. Yet, today are we willing to disregard this very real possibility with reckless abandon by mucking about with a system that is unique, functional and has the support of key political constituencies? I hope that cooler heads will prevail. We should appreciate and celebrate the uniqueness and effectiveness of our shared regulatory and insurance systems instead of tearing it down. For the losers in these differences of opinion among regulators and credit unions will be our members and the very movement we are so proud of. Marcus Schaefer President & CEO Truliant FCU Winston-Salem, N.C.

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