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Once again, the American Bankers Association asserts that regulatory relief for credit unions represents a threat to the $16.2 trillion banking industry, coining a new catchphrase – “unsanctioned growth” – to characterize the alleged hazards of the NCUA’s advance notice of proposed rulemaking on alternative capital. Yet the concept of “unsanctioned growth” is fiction, much like the banking trade’s interpretation of the Federal Credit Union Act. The recent comment letters by both the ABA and the Independent Community Bankers of America on the NCUA’s alternative capital ANPR are a shot across the bow, intended to sow uncertainty while masking the anti-competitive animus that inspires them to file lawsuits against the NCUA whenever they perceive the slightest bit of regulatory relief for credit unions coming from our bipartisan independent regulator.

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