(-13%), CUs $10-$100 million (-5.5%), CUs $100-$500 million (-1.69%) and CUs over $500 million (11.49%).

- Membership: Credit unions under $10 million

(-12%), CUs $10-$100 million (-5.25%), CUs $100-$500 million (-2.13%) and CUs over $500 million (10.31%).

None of these numbers bode well for small credit unions. The increased compliance burdens and intense competition credit unions are facing is especially tough on small CUs that can't muster the resources larger CUs can.

However, small CUs do have a much higher percentage of capital than larger CUs and it begs the question of whether small CUs should be putting more money in play to try and grow. Credit unions under $10 million have over 16% capital compared to 10.6% for the $500 million and over club. Credit unions with $10-$100 million have almost 12.97% capital compared to 11.65% of CUs $100 to $500 million. This could indicate small CUs don't know where to put new dollars. It also shows why small CUs are still so valuable in mergers–they have capital and likely a lot of members using only one or two products.

Small credit unions certainly can't do everything that the big boys can, but they can pick a niche and utilize the many industry collaborative efforts out there to make it happen. Whether it's mortgages or member business lending, there are CU-owned options.

Probably the most disturbing statistic for small credit unions comes with operating expenses. Despite offering fewer products and services than larger CUs, it costs more money to run a small CU:

- Operating Expense/Average Assets: Credit unions under $10 million (4.02%), CUs $10-$100 million (4.07%), CUs $100-$500 million (3.81%) and CUs over $500 million (2.9%).

This highlights the old economies of scale argument. In fact, the 300 CUs over $500 million in assets have more assets than the 8,000-plus CUs that have less than $500 million. Talk about an increasingly top-heavy industry.

Moving on to lending. With the many calls from some credit union leaders for credit unions to get more into mortgages in an effort to become a member's primary financial institution, let's not forget that mortgages currently make up the biggest chunk of the industry's loan portfolio at over 50%. Despite all the subprime issues, first mortgage growth blew away any other loan category in growth from Jan. 1 to September at 5.72%. Credit unions have to keep up the mortgage push, but as it begins to dominate the portfolio they'll need to be savvy about asset/liability management and assessing risk. The bad construction loans at Lake Huron, Norlarco and New Horizons may come back to hurt all CUs if it causes a hit to the National Credit Union Share Insurance Fund. Credit unions must be vigilant in mortgage underwriting.

On the investment side, funds in long-term vehicles (one year or more) are on the rise. Long-term investments have increased almost 6% to the tune of $5 billion year over year. That is helping CUs deal with the squeeze. While the cost of funds is as high as it's been in five years (2.69%) investment return is also at a five-year high at 4.66%. Still, net interest margins have tightened by four basis points from Jan. to June.

Return on assets no longer approaches the heady days of 1%. In fact, even at CUs over $500 million, ROA is just 0.84%. It's over 20 basis points lower for everyone else. Last year NCUA took some luster out of the tried and true 1% traditional ROA benchmark by saying it wasn't something examiners would be expecting.

Finally, here are three numbers I am very thankful CO-OP Financial Services is letting consumers know about: $3, as in Bank of America's inflated foreign ATM fee; 2,000, as in the number of CO-OP member CUs consumers can join to get access to CO-OP's surcharge-free ATMs; and 25,000 as in the number of CO-OP ATMs.

The CO-OP, thankfully, ran an ad in the Oct. 10 USA Today (see page 12) to remind consumers that there is an alternative to banks. Fortunately, the credit union alternative brings with it the weight of a national surcharge-free ATM network. These are the types of things credit union groups have to do a better job in getting the word out to consumers. CO-OP piggybacked on the negative story of BofA's increased fees and used it to tout its own network–nothing wrong with that.

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