Sailors are well-acquainted with "Iron Mike." The term is used to define the mechanical setting of a fixed course and speed for a vessel. It goes without saying that whatever happens once a ship is on Iron Mike, the vessel stays on the same course and speed absent human intervention.

One might say that the term Iron Mike could also be used to describe the NCUA's setting of the normal operating level for the NCUSIF. The fund's normal operating level has been at 1.3% of insured shares for as long as anyone can remember. Whether in good times or in bad, 1.3% has been the rule of the day. (The law permits the NCUA to set the operating level between 1.2% and 1.5%.)

Of course, there have been times when the industry has benefited from the NCUSIF equity ratio remaining close to the 1.3% operating level. For example, between 1995 and 2000, federally insured credit unions received a dividend each year, with a total refund over the period of about $620 million. We should also acknowledge that prior to enactment of S.896, the Helping Families Save Their Homes Act of 2009, if the NCUSIF equity ratio dipped below 1.2%, the NCUA had to assess federally insured credit unions and restore the equity ratio to its 1.2% statutory floor, not the 1.3% normal operating level.

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