The “data collection issue” may very well be one of the most complex to ever hit the credit union industry, but you wouldn't know that from reading Paul Gentile's Feb. 22 column on the subject, which oversimplifies the factors we face in accurately measuring credit union service to members. The complexity of measuring 9,000 institutions is far beyond anything we have faced in our community. Consider that credit unions are all very different; each credit union has its own field of membership in a community with widely diverse asset sizes. All credit unions have unique, distinctive needs which stem from the diverse and sometimes very particular wants and needs of the dissimilar memberships of each credit union. Now try to apply a uniform data collection method to a random sample of credit unions of all charter types, all with different geographic and economic circumstances, and then attempt to come up with a single perspective on how credit unions are doing serving “people of modest means” (which, oh, by the way, is not yet defined). And that is just the beginning. I do agree with Paul that NCUA and the rest of the industry have heard Congress loud and clear, but we need to think data collection through. Even Ways and Means Chairman Bill Thomas understands that this will not be easy. It will take time to assess, properly document and produce proof of what we do, but I, for one, am very confident that credit unions can and will easily prove that what we do is worthy of our tax-exemption. It may very well be that each credit union, based on its charter and field of membership, will have to do its own assessment, and set its own standards based on the demographics of its own membership. Credit unions are not banks. For over 70 years, credit unions have been serving their members and developing their fields of membership. It is very possible that any attempts at coming up with a single answer to this problem will just not work; and when we do come up with data, what will we compare it to? Is there a standard that is set for what is acceptable? Would it apply across the board to all credit unions, regardless of their fields of membership? Paul feels that if data collection is successful, it will serve as a ready-made defense against banker attacks. The big question is will credit unions and the banks define success the same way? And what about Congress? How will it define success? We simply cannot ignore the fact that the credit unions are going to be held accountable for whatever the data shows. NAFCU is not saying “uh oh” and is not afraid of having to justify our tax-exemption-we have been addressing the need to justify the tax-exemption for a number of years. We also understand that this is a first step in the process. We look forward to continuing to work with NCUA because we want to get off on the right foot from the very beginning. This has to be done right, not just for credit unions, but for the 87 million credit union members who rely on us to continue to do what we do every day. Fred R. Becker Jr. President & CEO NAFCU Arlington, Va.