With regard to Editor-in-Chief Paul Gentile's Aug. 23 column about CUNA's position on modest means and NCUA's data collection effort, I would like to make several points in response.

As the national trade association, CUNA is looked to and valued for our political judgment. At the same time, it is incumbent upon us to listen to the views of our board and membership in recommending policy. And, in fact, the CUNA board as well as our Governmental Affairs Committee, the leagues, and members of the National Credit Union Roundtable, among others, have all made it absolutely clear that the raw data NCUA is collecting on credit union service to people of modest means should not simply be entered into the public record without proper context. Nor do they want the bankers to be the ones who establish this context, which is sure to occur if we allow the data to be released in a vacuum. If that happens, we will find ourselves arguing over the bankers' terms–talk about being "boxed in!" It should go without saying that we are contending with the modest means/data collection issues in this way at the direction of Congress. Those who argue Congress has no interest in the meaning of modest means seem to be forgetting recent events, not least of which is last November's House Ways and Means hearing. To assume Congress will be content to accept the data without seeking to establish some type of interpretive framework is counterintuitive and ignores the realities of the day. For that reason, I feel it would be not only shortsighted, but bordering on irresponsible if the data is not put in perspective. Lastly I would only add that I believe it is truly unfortunate for the credit union movement that we are forced to have this debate in the press right out in front of the bankers at this time. They certainly are not doing the same before credit unions, and are no doubt gloating as a result. Daniel A. Mica President and CEO Credit Union National Association Washington