TORONTO – NCUA Vice Chairman Rodney Hood and Board Member Gigi Hyland discussed the many challenges they have seen during their brief time on the NCUA Board in a talk-show style session at NAFCU's 39th Annual Conference.

Hyland commented, "Right now, I'm squarely on the fence" as to whether the agency should define "modest means." The argument for it, she outlined, would be to take up the task before someone else could. On the flip side, she wondered whether NCUA had been asked to do so, whether it had the jurisdiction, and how it could "encompass the beautiful diversity of credit unions." And finally, is that one step toward establishing a requirement?

A former Community Reinvestment Act officer at a bank, Hood stated he was opposed to a CRA requirement for credit unions. "Credit unions don't need legislation to do the right thing," he said.

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Also, speaking of doing the right thing, Hood said that credit unions converting to thrift charters must ensure the process is transparent and open. He pointed the finger at the credit union's board members, who "are responsible for making sure that those disclosures are thorough and complete." Credit union members must also begin asking the right questions, he said.

Bank Secrecy Act compliance will continue to be a challenge for credit unions, Hyland said, adding that it is a learning process for all involved. The best way to find a happy middle road in dealing with this issue is for credit unions, which generally know their members, to talk with their examiners and get a two-way education process going. Hood noted his personal challenge as a regulator "for me, is to give you all the regulatory flexibility and empowerment that you need to serve your members.You need a regulatory environment where you can respond at the speed of business." This must also be balanced with safety and soundness interests, he said. [email protected]

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