In her column of April 16 ["See No Evil, Hear No Evil, Speak No Evil"], Sarah Snell Cooke makes some broad assertions about the inevitably of data collection and executive compensation disclosure–two proposals that are contained in the NCUA's recently released Outreach Task Force report. Neither of these recommendations, in our opinion, is a fait accompli. Moreover, no compelling case has been made for their adoption, and there has been no demonstration as to how they would improve credit union safety and soundness or help credit union members.

NAFCU-member credit unions tell me they are especially concerned about the impact salary disclosures could have on their employees and members and that they view compensation issues as their boards' responsibility. NAFCU also believes that requiring individual federal credit unions to disclose executive compensation will create a significant discrepancy between state-chartered and federally chartered credit unions.

Ms. Cooke also asserts that data collection will become a reality. NAFCU has steadfastly maintained that data collection to measure credit union service to members would necessitate additional regulatory requirements. We recognize that comprehensive, statistically valid data collection on credit union services is extremely difficult to achieve and that any data collected will reflect only a portion of the credit union community. In fact, there has been significant industry feedback demonstrating widespread opposition to further regulation and other continued data collection efforts. For all these reasons, NAFCU continues to object to any regulatory requirements to collect and publish membership profile and financial services data.