There are a variety of reasons that could play into the differences, such as the demographics of the field of membership. Additionally, generally speaking minorities make up a larger proportion of lower-income applicants so probability is in play as well. And, I'm not going to be na??ve about this either: part of the difference is plain old discrimination.

But would CRA fix the disparity? It hasn't among the banks and thrifts. They each have a 15-percentage-point spread between low-income white and minority applicants.

The credit union trade association lobbyists have taken the message to Capitol Hill that credit unions are not part of the problem in the subprime crisis, which one NAFCU lobbyist claimed has worked "fantastically." In fact, Frank went on the record last year stating at a credit union conference that if all lenders behaved as credit unions do, CRA might not be necessary.

On the other hand, Frank has also noted that state-chartered credit unions in his home state of Massachusetts are doing just fine under a CRA regulation modified to the unique nature of credit unions.

CUNA's lobbyists emphasized that the upcoming hearing Frank is holding on CRA Feb. 13 is commemorative in nature, though they did not deny the opening for bankers to put their two cents in. It's hard to imagine the bankers or some community advocacy organizations would pass up the opportunity to work credit unions into the conversation; from their perspective, it would be foolish not to bring up the subject.

However, this is expected to be just the first in a series of hearings that may or may not lead to legislation. Even if a bill is introduced, credit union political types have said that its application to credit unions would not muster enough support to pass the House.

Frank has frequently been referred to as a highly pragmatic legislator but my sources have told me a bill would very likely include everyone and that means credit unions.

Still, logically speaking, how could credit unions justify a carve-out in the potential legislation? By stating to lawmakers in person, on the phone, via e-mail, whatever, that they already work to serve their members, not to the lowest common denominator set by a congressional benchmark. By highlighting the HMDA data in relation to banks.

I stress that I'm not talking about leaving it up to the trade association lobbyists, who already wear out enough shoe leather in the marble halls of the congressional office buildings. Credit union executives and volunteers themselves need to make their presence known in large numbers–put a face with the entity.

I haven't made you nervous enough to get politically active on the matter yet? Consider this: a high-ranking, generally credit union-friendly member of the House Financial Services Committee has said that it would make sense for credit unions to be subject to CRA if they want the ability for all federal credit union types to adopt underserved areas, as is included in CURIA.

You may recall a year ago, the NCUA staff proposed to the board that federally insured credit unions continue the modest means data collection pilot on a broader basis, among other things. Since that time, NCUA Board Member Gigi Hyland has held a series of town hall meetings across the country to gather credit union input on the staff findings. Her task force's report is expected to be released in the not-too-distant future. The results will be interesting to see and also whether it will impact any legislative decisions.

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