In a Corporate Credit Union Guidance Letter dated Feb. 8 signed by Scott A. Hunt, director of the Office of Corporate Credit Unions, the NCUA left no uncertainty about its intent to show the way forward for corporate CUs.

In the letter, the NCUA warns about the risks of too much consolidation. That might, wrote Hunt, "create an unacceptable 'too big to fail' scenario." The NCUA explicitly applies this warning both to a potentially very large corporate and also to a possible CUSO, supported by multiple credit unions.

The NCUA elaborated that were such very large institutions to fail, there would be consequences as a result of the failure per se but also because of interruption of service.

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