In “Legislators,Regulators Seek Credit Union Oversight Secret Sauce,” Ms. Cookeputs forth a flawed notion that the size of the NCUA board can makethe difference between what is good policy vs. “cheap” policy.Frankly, that is not the issue, efficacy is.

What benefit would be derived from increasing the size of theboard? Improved governance is not guaranteed simply because thereis more debate or the size of the board increases. Greatertransparency and accountability do not necessarily require eitherof these. For this reason, NAFCU has been steadfast inopposing any unnecessary government actions that increase costs tocredit unions without providing any benefit or relief to theirmembers. This has included various past proposals to change theNCUA board from three to five members.

The fact is a move from three board members to five, andadditional support staff, would increase the board's expenses inthe range of 60%, with no clear benefit. Already, NCUA travel isone of the greatest expenses in the budget. Adding two new boardmembers would not only increase costs directly related to the twoadditional board members, but it would also add costs for the boardmembers' support staff, which would include additional advisers andassistants.

Adding more bureaucracy at a time when credit unions are alreadydisappearing at a rapid clip due largely to massive overregulationis counterproductive and counterintuitive. The added expensesthat would be incurred and underwritten by credit unions would onlyexacerbate the consolidation and disappearance of Main Street'scredit unions. Since the second quarter of 2010, we have lost1,499 federally insured credit unions – more than 20% of theindustry. The overwhelming majority, 96%, were smaller institutionswith less than $100 million in assets – those typically found inrural areas.

Ms. Cooke, in the same column, also promotes NCUA parity withother regulators on vendor oversight. The NCUA already isauthorized to thoroughly regulate credit unions and theirrelationships with third parties. Granting the NCUA directoversight of vendors would be costly and unnecessary and, would notnecessarily equate to better oversight of vendors or increasedsafety and soundness for the credit union industry.

Ultimately, bigger is not always better, and more bureaucracyfrom the NCUA is not better than simply having the NCUA exercisethe authority it already possesses. In the case of NCUA, theconsequences of too much bureaucracy is far more dire than too manycooks in the kitchen. Too much bureaucracy could very well threatenthe future prosperity of credit unions and, ultimately, squandercredit union members' hard-earned funds.

Carrie Hunt

Executive Vice President of Government Affairs and GeneralCounsel

NAFCU

Arlington, Va.