The combination of the two, credit union executives and economists agreed, have effectively hobbled credit union growth by putting CUs into a straitjacket of capital standards that credit union history does not justify and does not give CU's any more efficient means of handling them.

Critics of the current capital rules argue that they both prevent credit unions from serving people Congress mandated that they serve and force them to adopt even more conservative policies towards innovation of new products and services.

When a credit union's only source of capital is retained earnings, the critics argue, each dollar of capital earned this way is perceived to have a value far greater than a dollar raised by other means, which may lead CUs to adopt new strategies, products and services more slowly than they might otherwise. This inertia will prove particularly costly for both credit unions and the American consumer, the critics further charged, because it will mean CUs will not be able to help as many unbanked or underserved consumers as they might otherwise as well as credit union members fighting hard economic times.

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