2. While you're in the vicinity, don't forget to meet with your federal regulators over in Alexandria, Va., or track them down in the halls at the caucus. Even though it is called Congressional Caucus, you aren't restricted to lawmakers. And right now, the NCUA has some of the most important regulations on the docket that it has had in a long time, which I will get to.

3. One of the things legislators are considering this fall is the Consumer Financial Protection Agency, though the original proposal has hit a few snags. NAFCU's caucus is perfectly timed to have your CU's point of view fresh in the minds of lawmakers as they head into the Sept. 30 hearing on the matter. Credit unions, generally speaking, shouldn't need this, and the NCUA is setting up its own consumer protection office. The CFPA will only wreak bureaucratic havoc.

4. This is a particularly crucial time. A draft of this legislation has not been made public, but it could include items like Carolyn Maloney's overdraft legislation, which could significantly affect credit unions' fee income.

Along these lines, it's despicable that credit unions median fee is $25 on overdraft protection yet it only costs $13 (see our story, page 1). I'm all for credit unions making money for viability but nearly doubling the cost seems outrageous within the CU philosophy. Borrowings are typically low-dollar and are often taken out of the next deposit made. Obviously, we've also learned that higher fees don't discourage use in the case of overdrafts either. Mike Moebs estimated 2,000 credit unions would shutter if Maloney's bill passed, which seems like a lot, but if it's even half that, it's horrible.

Additionally, an active opt-in program is a good consumer-friendly policy. If credit unions don't police themselves, they will be policed.

5. Mortgage cram-downs is another area that could come up in the CFPA discussions on the Hill. The industry was pretty well divided on this issue last time it came around. If your belief is not in line with the trade groups that send representatives up to Capitol Hill everyday, then you in particular need to meet with your members of Congress.

6. Also on the legislative front, credit unions need to make a very strong push to put into law a reversal of the 21-day notification prior to charging late fees or reporting to credit bureaus, as was included in the CARD Act. For some credit unions, the changes are extremely costly, especially when they weren't the bad actors to begin with. For others, it is literally impossible because their billing is more frequent than monthly at their members' request. This will require a legislative fix that credit unions must push for in Washington or with their members of Congress while they're home in their districts. The NCUA was steadfast in saying they cannot and will not encourage CUs to break the law as it stands.

7. Congress would do well to be as open minded as the NCUA officials appeared at its first town hall on the corporate regulatory proposal. Every time a concern was raised by a CU executive, the regulators agreed to at least consider it. One big issue the NCUA seemed interested in hearing more about was corporates' ability to raise the capital required in the proposal within the proposed time frame (see our story, page 1).

Be sure you make your voice heard at one of the upcoming town halls or a comment letter. If the five-year time frame is maintained, fees on natural person credit unions for corporate products would go through the roof, and that would harm liquidity and force the sale of the mortgage-backed securities at a huge loss.

8. Another issue raised at the town hall that has created regular angst between the regulator and the regulated is that the examiners in the field don't necessarily follow what the board and central office is saying is policy. Obviously some serious changes need to occur in communicating with and training those in the field.

9. One are where the NCUA has been dead wrong was its letter rebuking a credit union for using the agency's logo in a security breach test. How can a credit union thoroughly test its staff if the threat is hokey? The more real it looks, the better the test. This policy must be reverse for safer credit unions.

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