"I recognize that's a significant investment. But to put it in perspective, the value of the donated advertising time and space–including that electronic billboard in Times Square–has now exceeded $4 million," Matz argued in an April 2011 letter to Credit Union Times, calling its impact "a tremendous bang for the buck."

NAFCU General Counsel Carrie Hunt acknowledged that the agency has said that it would stop using Orman in promotional material for the NCUSIF in August of this year but said that NAFCU did not know why the agency could not stop using her material earlier.

Hunt also said the association knew she had publicly advised consumers to walk away from underwater mortgages on several occasions.

The agency has not yet commented directly on NAFCU's letter, but in an upcoming letter to the editor of the Credit Union Times, Matz said the agency's contract with Orman runs through August 2012 and argued that Orman's endorsement brought more members to credit unions.

"During the nine months when the campaign received the greatest visibility, credit union membership increased by nearly 1 million, from 90.5 million to 91.4 million," she wrote. "This extensive membership gain reversed the previous trend; membership had decreased by 300,000 during the prior quarter."

The campaign has always been controversial with credit unions as some executives questioned whether it represented a good use of agency funds, but Orman's stock with some credit unions took a hit after she announced the launch of her Approved decoupled debit card.

Touted by Orman as more consumer friendly than other prepaid card programs, the Approved card carries a lower fee profile than other similar cards along with consumer-oriented modifications and services.

These include zero-liability protection, free access to credit reports from TransUnion, identity theft protection from TrustedID and the ability to set up an emergency fund.

But critics have pointed out the Approved Card still carries fees. The card costs cardholders $3 per month and will charge cardholders $2 per ATM transaction if they use an ATM not affiliated with the AllPoint network or if they do not load at least $20 on the card each month. Additionally, if a cardholder gets cash back when making a purchase at a retail store, it will cost $2 and while the first call each month to a customer service representative will be free, any subsequent call that month will cost $2.

In addition, Orman has charged these fees even though the cards will generate interchange income every time a consumer uses them at a point of sale. A spokesman for Approved LLC defended the card's fees and interchange, saying,  "the Approved Card has unrivaled benefits, including free electronic bill pay, free TransUnion credit reports and scores, and free Identify Theft protection from TrustedID." There are expenses for all programs, and we have these additional benefits, which is why there is a monthly fee." 

The Approved card does have a fee structure that compares favorably with some credit unions' prepaid debit cards, which can charge fees as high as $9.95 per month. But Konrad Christensen, retail payments product manager for The Members Group, a payments CUSO that issues a prepaid debit card in partnership with credit unions, said the current payment model is much better for consumers.

He explained that the 50 credit unions that partner with TMG to issue the cards only charge $4.95 per month and do not charge that if cardholders use direct deposit to refill their card and draw them down each month. A cardholder that uses direct deposit to fill the card and draws their card down to only $1.95 by the end of the month, would only face a $1.95 fee.  If the cardholder drew the card balance down to  50 cents, the fee for that month would be 50 cents and if the card was drawn to zero there would be no fee at all.