After reading Stuart Perlitsh's letter ("Questioning Cost of Small Credit Union Initiatives", CU Times, April 16, 2014), I can understand his stance on whether the OSCUI program is successful and the costs involved. But I feel his statement that the program appears to be failing based on the decline of credit unions since 2004, should not be laid at the feet of the OSCUI.

Quite frankly, it's nice to have a resource available, without product prejudice, to assist us in evaluating and developing a business plan that provides the potential to serve our members but also assures we do so in a safe manner. OSCUI-type expertise may be available other places, but at a substantial cost we couldn't afford. The NCUA saw the needs of small credit unions, and their difficulty, in going to another level of service or improving operations, and offers education specific to small credit union needs.

Seeing another wave of credit unions at risk in this e-commerce age, they have again stepped up to the plate to assure these credit union will have resources available to move upward. No other credit union or its organizations has stepped up to plate like the NCUA did.

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In the coming years, many credit unions (small, medium and large) may go out of existence, mostly due to the costs of e-commerce and changing memberships, but if the OSCUI can help some credit unions prepare for the future, why deny that possibility? Many will say we don't need small to mid-size credit unions, but who will you put before Congress when laws may adversely impact your credit union? The concept of "member-owned cooperative" is more deeply felt by members of small credit unions. Larger credit unions compete on services. When we just have a few large credit unions nationwide, you will no longer have a regulatory agency that understands your mission and unique ownership structure. The FDIC will then regulate credit unions.

In 2002 we became a low-income designated credit union and enlisted the assistance of John Dock, an OSCUI financial counselor. With his assistance we were able to develop processes for evaluating our credit union's services, understand our membership's needs through surveys, and develop processes for evaluating the impact of expanding services. Had we not had that valuable input, I dare say, our credit union probably would have listened to any and all vendors about their products and services, not understanding the impact to our credit union. We would not have survived the past five years.

Now in cost analysis, how many large credit unions benefited from the NCUA when they became conservators of credit unions until viable? How many large credit unions were able to expand by acquiring failing credit unions with stop-gap guarantees by the NCUA? The NCUA's purpose is to assure the safety of our members' money and take measures to assure the credit union system stays strong, regardless of credit union size. The OSCUI is just one of those tools.

Silvia Davis

CEO

St. Pat's Employees Federal Credit Union

Missoula, Mont.

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