For more than 25 years, Guy Messick has seen firsthand how CUSOs have generated and contributed millions of dollars of net capital per year to the credit union industry.

As an attorney, Messick represents CUSOs and credit unions and serves as general counsel for the National Association of Credit Union Service Organizations and principal in Messick & Lauer P.C. in Media, Pa. When the NCUA delivered what he called a one-two punch to CUSOs in November 2013 and January 2014 with the revised CUSO rule and the proposed risk-rated capital rule, he was more than concerned that the regulator had labeled CUSOs as a systemic risk to credit unions.

"NCUA's rules seem to encourage credit unions to do business with non-CUSO service providers where credit unions do not have to set aside risk based capital for CUSO investments," said Messick. "Based on NCUA's message, why would a credit union want to invest in a CUSO? The answer is that CUSOs have proven to be one of the most effective means to generate net capital and provide access to critical services."