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In 1997, the Treasury Department performed a study aimed at improving credit unions. Many things have changed since the time of that report. For example, credit unions were required by law at Treasury’s recommendation to adopt a formal system of prompt corrective action, even though an informal policy similar to PCA was in place. I recall Dennis Dollar, who was then serving on the NCUA Board, justifying the change as something thrust upon the NCUA to enforce.

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