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It’s a question that’s been on the minds of financial service regulators, credit union executives, trade association leaders and even some credit union members over the past few months: Should credit unions define the term “modest means”?

As Paul Gentile pointed out in his very astute Aug. 23 column, the question has yet to receive a unanimous answer. While the NCUA has not said whether it favors a definition, Mr. Gentile noted that some in the credit union industry have already expressed support for defining the term. Meanwhile, Mr. Gentile himself listed numerous reasons why defining modest means is not appropriate.

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