Tell Congress & regulators to wake up

By Rebeca Romero Rainey

Rebeca Romero Rainey


The dominant issue in community banking these past months has of course been the Paycheck Protection Program and the economic impact of the coronavirus on your banks, customers, and communities.

Community bankers have emerged as the champions of small businesses and their employees, which have all too unfortunately been blindsided by an abrupt shutdown caused by the COVID-19 pandemic.

As we continue our relentless focus on customers in need, we must not let our guard down in continuing to urge Congress, the agencies, and the public to “wake up” to an overly-opportunistic credit union industry. Otherwise, we will emerge from this crisis with riskier and more emboldened credit unions all thanks to their captured, cheerleader regulator, the National Credit Union Administration (NCUA).

I appeal for your help in submitting comments to the NCUA on two recent proposed rules:

  • Subordinated debt. The NCUA has proposed to allow large credit unions to issue subordinated debt, which would fuel rapid growth and consolidation in an industry that is already growing too quickly. View ICBA's sample comment letter
  • Credit union-bank acquisitions. The NCUA has proposed a new rule on credit union acquisitions of other financial institutions. As you know, these acquisitions have become more frequent and are rapidly transforming the financial services market. They threaten to undermine the tax base in your states, which, following the economic shutdown, are more desperate than ever for revenues. The NCUA proposal would create more transparency and is a step in the right direction. Our objection is that it does not go far enough. We must not miss an opportunity to meaningfully regulate and curb acquisitions which abuse the credit union tax subsidy. View ICBA's sample comment letter

Follow the resource links above for suggested language, but as always, we encourage you to customize this language for greater impact.

It is critical that community banks make a strong grassroots showing, in quantity and quality of letters, to influence the rules and set down a marker against further powers expansion.

Thank you for all you do, community bankers! Your involvement and persistence is critical to our industry’s success.



Rebeca Romero Rainey
President and CEO/
Independent Community Bankers of America