A recent issue on NAFCU "Update" reported the NCUA Board's unanimous vote to maintain the federal credit usury ceiling at 18%. I have never seen a more spurious reasoning for a bad move. A provision citing a rising rate environment was quoted. Further proponents maintain an 18% rate promotes risk-based (subprime) lending. Rates on federal issues are at 40-year lows, CD rates have dropped perceptibly, returns on regular savings accounts are a joke, home mortgage rates are down dramatically, and discount financing on new cars abound. What rising rate environment? Promote risk-based lending. You cannot now, nor could you ever, justify subprime loans by charging a higher rate as banks, S&Ls, and a number of credit unions found out in the `80s. Eighteen percent rates are an abomination and are aptly labeled usurious. Obviously for 30 or more years, NCUA's decisions have been largely driven by the need to bail out the growth at any price mega credit unions. In this category of influence driven decisions, I would have to include NCUA's even considering expansion of investment avenues, to in essence allow them to put money in any type vehicle they are `competent' to evaluate. What a phrase, `competent.' By whose standards? Surely not NCUA's. Frankly I do not want the fox, even if he or she is the world's smartest fox guarding the hen house. John Barker CEO Hudson River Teachers FCU Cortlandt Manor, N.Y.