ANPR comments include a complete corporate system overhaul recommended by a consortium of 12 large credit unions.

Lead by Chairperson Dennis Pierce, CEO of the $1.6 billion Community America Credit Union, the Corporate Credit Union Stabilization Partnership advocates only three corporate entities: one corporate that provides short-term investments and liquidity services, a broker/dealer that provides long-term investments, and a CUSO that handles long-term liquidity products like loan securitizations and participation loans.

The 105-page document claims the plan would save $250 million in annual expense savings. Additionally, the remaining stripped-down corporate would not only break even, it could generate net income as high as $164 million annually.