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No offense to NCUA or any other regulators, but they are not usually leading edge. They are often reactors. Take new technologies. When NCUA was created it certainly didn’t have to worry about say audits of third-party tech providers to protect the insurance fund until online services started to flourish at credit unions. They didn’t have to start honing in on subprime lending until one company came in with great success and changed the marketplace. In other words, NCUA is going to be reactive on all sorts of things as the industry changes.

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