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<p>I’ve followed with great interest the debate on whether or not the repeal of CAP was an appropriate action on the part of the NCUA Board. I know that mainstream credit unions are pleased. I was pleased. Just for the record, I never felt that CAP was necessary. I argued long and hard with former NCUA Board member Yolanda Wheat when she was still writing the draft, trying to convince her that credit unions were doing the right things in their communities. Our problem was that we had no measurable proof of those right things being done. I tried to convince her that Project Differentiation was the answer. I still believe it could be, but for some reason, many credit unions have yet to come on board with it. We could see the handwriting on the wall. We knew that with the repeal of CAP, which, by the way, was a very mild regulation, not to be at all confused with the real CRA animal, would come a cry of outrage by consumer advocate groups everywhere. The fact is, credit unions are busy expanding their fields of membership every day. Some are moving into low-income communities. Most are not. Some are developing appropriate products and services for low-income folks and providing meaningful education and credit counseling. Most are not. Some are operating their credit unions in such a way that they would never have blinked at complying with CAP. Piece of cake stuff. Most are not. Some have taken on check cashing outlets and payday lenders with their own versions that are less pricey, more member friendly. Most are not. Bottom line here is that credit unions might need to do a little soul searching on this one. The last three or four seminars I’ve attended have pushed member profitability, investment services, and technology, but no one has mentioned serving that growing population of America known as the `have nots’. The great Digital Divide is beginning to look a lot like the Grand Canyon and many credit unions are only focusing on one side. Repealing CAP took guts. I wrote my letter; I supported the repeal. Now we’re paying the price. Sometimes I think about what we’ll look like as a movement in 10 or 15 years and wonder if we might have behaved differently today if we could see a clear picture of that future. Instead of living with CAP and doing its small requirements, we could find ourselves living with full-blown CRA, taxation, merged insurance funds, a single financial institution regulator, and God knows what else. As much as I disagreed with CAP, doing away with it may prove to have been even more harmful to us in the long run. You know what they say – hindsight’s 20/20. Mary Cunningham President/CEO USA Federal Credit Union San Diego, Calif.</p>

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