To forecast what lies ahead in 2010, one has to consider theenormous legislative and regulatory challenges of 2009. Work onlegislation to overhaul the regulatory restructuring of thefinancial services system and the conservatorship of the twolargest corporate credit unions were significant factors. At thesame time, share insurance and stabilization fund assessmentsburdened credit union balance sheets. NAFCU worked intensely tocounter regulatory reforms that would negatively impact creditunions and their members. Nevertheless, we fully expect that thestage has been set for what promises to be a tumultuous environmentfor our industry in 2010.

NAFCU took a very visible leadership role in ensuring the defeatof mortgage bankruptcy cram-down legislation. We have steadfastlymaintained that mortgage cram-downs should be limited to subprimeor nontraditional mortgages. We were successful in advancing ourcase by twice defeating efforts to pass legislation creating broadcram-down authority, first in the Senate and then in the House. Weare cautiously optimistic that Congress now recognizes that this isnot the way to remedy the foreclosure situation, but we will keep akeen eye on any developments in this front.

Another issue that impacts credit unions is the proposedcreation of a Consumer Financial Protection Agency to assume theconsumer protection responsibilities of all the current federalfinancial institution regulators, including the NCUA. NAFCUsuccessfully won a provision in the House-passed Wall Street Reformand Consumer Protection Act that effectively excludes all creditunions from paying into a dissolution fund for the wind-down oflarge firms. It also got a clarification by Rep. Gary Peters(D-Mich.) that another provision dealing with Troubled AssetsRelief Program shortfalls only affects institutions that pay intothat fund.

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