Location is important in nearlyall businesses for various reasons, whether it be accessibility orsecurity or tax treatment. It's a cost of doing business. At itsDecember meeting, the NCUABoard issued a proposed rule that would require federalcredit unions to operate out of commercial buildings zoned forretail use. The very fact that the agency has to issue a rule aboutthis is preposterous.

Running a credit union out of someone's home presents majorsafety concerns. Any mentally unbalanced or criminal member couldthreaten the manager with no one else around, or worse yet, withfamily present. Examiners could be attacked by managers with nowitnesses to what happened. Managers have challenged that examinershave no right to access home-based credit unions. While an extremecase that actually did occur in a commercial building,the TaupaLithuanian Credit Union scenario was a huge eye opener tothe safety issues examiners could face, and stockpiling a weaponsarsenal would be much more likely and potentially legal insomeone's home. Other less dramatic safety issues are of realconcern for members and examiners, such as rickety staircases ordog bites. Really, who wants to see a rabid examiner?

Privacy concerns are another obvious problem for a home-basedcredit union. It is difficult to ensure the credit unions' recordsare safely locked up and that precautions have been taken to avoidaccidental destruction by fire or flood in the manager's basement.Additionally, other members of the household might access thesedocuments, inadvertently or for nefarious reasons, in violation ofprivacy laws.