SECTION: IN THE NEWS

LENGTH: 5859 words

HEADLINE: PREPARED TESTIMONY OF
JOHN D. GARRISON
CHAIRMAN, PRESIDENT AND CEO
WALDEN SAVINGS BANK
BEFORE THE HOUSE BANKING AND FINANCIAL SERVICES COMMITTEE
FINANCIAL INSTITUTIONS AND CONSUMER CREDIT SUBCOMMITTEE
SUBJECT - IMPLEMENTATION OF THE CREDIT UNION
MEMBERSHIP ACCESS ACT

BODY:

BankAmerica's Community Bankers (ACB) believes the new regulations and field of membership chartering manual issued by the National Credit Union Administration (NCUA) clearly ignore the express intent of Congress when it enacted the Credit Union Membership Access Act (CUMAA). A primary objective of the CUMAA was to ensure credit union accessibility for groups of closely linked individuals of modest means. ACB's fundamental concern is the impact that the new regulations and field of membership chartering manual will have on community banks and smaller, more traditional credit unions. By permitting the expansion of credit unions either by allowing them to add more groups or by geographic extension, credit unions wishing to serve their original common bond and provide services at reasonable prices to their members are at a significant disadvantage. Another general comment relates to the lack of clarity throughout the rules. Many of the definitions include broad, all-inclusive categories which may cause inconsistencies in the charter approval process by giving the regulator an inordinate level of case-by-case discretion. The following areas in particular are in need of more specific detail.
- The economic advisability threshold is inconsistent with Congress' intent to encourage the formation of new, separately chartered credit unions for groups with less than 3,000 members.
- The definition of "immediate family members or household" is overly broad.
- The definition of a "well-defined local community, neighborhood, or rural district" will result in anything but an area that any reasonable person would think of as a well defined area.
The general theme in the regulations and chartering manual seems to be to assist the growth of larger credit unions to the detriment of their more traditional competitors. ACB does not want to deny credit unions their proper role in providing financial services, or to limit consumer choice. However, the NCUA's implementation of CU AA allows larger credit unions to expand beyond the boundaries of their original charter. At some point, large credit unions that draw from a wide geographic area and sell every financial product imaginable should have the same tax requirements as apply to banks and savings institutions. ACB highly recommends that Congress use its oversight powers to prevent the NCUA's overly broad regulations from taking effect.
Madame Chairwoman, and Members of the Subcommittee, my name is John Garrison. I am Chairman, President and Chief Executive Officer of Walden Savings Bank, a mutual institution in Walden, New York. Walden Savings Bank was established 127 years ago and has approximately $130 million in assets.
I am also on the Board of Directors of America's Community Bankers (ACB), serve as ACB's Chairman of the Coordinating Committee on Credit Unions and the Chairman of the Community Bankers Association of New York State's Coordinating Committee on Credit Unions. ACB is the national trade association for 2,000 savings and community financial institutions and related business firms. The industry has more than $1 trillion in assets, 253,000 employees and 14,500 offices. ACB members have diverse business strategies based on consumer financial services, housing finance and community development.
Madame Chairwoman, on behalf of ACB and its membership, I would like to commend you for holding this very important oversight hearing on the implementation of the "Credit Union Membership Access Act" (CUMAA) by the National Credit Union Administration (NCUA). We would also like to commend Congressman John LaFalce for his insightful comments on this issue. Summary of Position
The new regulations and field of membership chartering manual issued by the NCUA, which allow larger credit unions to expand beyond the boundaries of their original charter, clearly ignore the express intent of Congress when it passed the credit union bill.
While we believe that the traditional credit union industry, those smaller credit unions whose membership shares a common bond, should be permitted to maintain its traditional operations and services, the NCUA should not be allowed to circumvent the intent of Congress in favor of larger credit unions. This action not only makes a mockery of the new law, it also imposes harm on smaller credit unions and community banks.
Under the NCUA rule, .credit unions will get larger and larger at the expense of community banks. Smaller credit unions should, and increasingly do, feel equally threatened. I have had many personal conversations with small credit unions in my area about this very issue.
No one wants to deny credit unions their proper role in providing financial services, or to limit consumer choice. However, the NCUA's implementation of CUMAA poses a threat to the majority of community banks and credit unions.
Congress should use its oversight powers to prevent the NCUA's overly broad regulations from taking effect. I also highly recommend that Congress reexamine the billion dollar tax break that credit unions, particularly larger credit unions, enjoy at the expense of the American taxpayer. As a mutual institution, we operate much like a credit union. Everything we make goes back into the institution and to our customers. Unlike credit unions, however, we pay taxes and adhere to the Community Reinvestment Act.After briefly discussing the background of this issue, my testimony will cover the following areas of interest to you and the members of the Subcommittee: (1) the NCUA Board's duty to encourage the formation of new credit unions; (2) the NCUA's revision of the economic advisability threshold; (3) the NCUA's factors for determining whether a large group can be added to an existing credit union; (4) the NCUA's policy on overlapping fields of membership; (5) the NCUA's definition of "service facility" and "service area;" (6) the NCUA's safety and soundness obligation, if any, to place a group with an existing credit union that did not file an application; (7) the NCUA's definition of "family member" and "member of household;" and (8) the NCUA's final rule regarding credit union charters and expansion.
My testimony will also address Congress' oversight role in ensuring that the NCUA follows the legislative intent of the CUMAA and the credit union taxation issue.
Background In 1934, Congress created a federal charter for credit unions to serve as voluntary associations of closely-linked individuals with a well- defined common bond, such as being employees of the same company. In exchange for accepting the specific mission of serving consumers of modest needs, credit unions were given the privilege of tax exemption. It is important to underscore this very clear relationship between the tax exemption credit unions have enjoyed for 65 years and their specific mission of serving closely-linked individuals of modest means.


Over time, the NCUA has eroded the boundaries of that mission inappropriately - especially as they relate to credit union membership. For example, in 1982, the NCUA began to permit membership in a federal credit union for multi-occupational groups, even though the Federal Credit Union Act (FCUA) clearly limited membership to single-occupational or associational groups. This overly permissive regulatory approach has spawned a large-scale, expansionist movement by some opportunistic federal credit unions, which have grown in size and broadened their product lines to the point of mirroring those of banks and thrifts.
In its 1998 decision, National Credit Union Administration v. First National Bank & Trust Co. et al., the U.S. Supreme Court ruled that the NCUA misinterpreted a key component of the FCUA, holding that groups with unlike common bonds could not be joined to form a single occupational or associational credit union. In its ruling, the Supreme Court stated that the NCUA acted contrary to the unambiguously expressed intent of Congress under the FCUA.
In response to the Court's decision, Congress enacted the Credit Union Membership Access Act in August 1998. The legislation purported to prevent the divestiture of credit union members from the financial services institution of their choice, while promoting safety and soundness. The CUMAA broadly defined by statute several different types of fields of membership, including single common-bond credit unions, multiple common-bond credit unions, and community credit unions. Congress granted the NCUA the authority to issue regulations or guidance to implement these statutory definitions. A careful review of the legislative history shows the clear intent of Congress to preserve the original boundaries and responsibilities inherent in the credit union charter, such as providing access to people of modest means and limiting access to closely linked individuals with a well- defined common bond.
Nevertheless, even the legislative and judicial mandates described above have not deterred the NCUA's insistence in defying congressional intent. The NCUA has exceeded its regulatory authority by implementing overly broad, and subjective chartering and fields of membership regulations. Consequently, the NCUA's new chartering manual and field of membership regulations facilitate the ambitions of a few, large predatory credit unions - at the expense of all community banks and most credit unions.
That said, Madame Chair, ACB will now respond to the questions you posed in your invitation letter.
First, does the NCUA Board's duty to encourage the formation of new, separately chartered credit unions apply to the applications to add a group to a credit union's field of membership? While the CUMAA contains an explicit mandate to encourage the formation of separately chartered credit unions, the NCUA's regulations and chartering manual do just the opposite. By broadly interpreting the definition of many of the terms determining who may join a particular type of credit union, the NCUA's regulations and chartering manual will have a detrimental effect on smaller, more traditional credit unions and community banks. By giving credit unions the authority to expand either through adding more groups or by geographic extension, the NCUA's regulations discriminate against those credit unions wishing to serve their original common bond and provide services at reasonable prices to their members.
We find it significant that the NCUA's Chairman, Norman D'Amours, voted against the new rules. During the board meeting when the rules were approved, Mr. D'Amours claimed the new chartering provisions discriminate against smaller credit unions and seriously hinder their safety and soundness. Mr. D'Amours went on to say that the new provisions were in direct violation of the intent of Congress. We couldn't agree with him more. Even if the statute on its face did not unambiguously indicate a preference for establishing a greater number of smaller credit unions, rather than a fewer number of larger ones, the committee report accompanying the credit union bill left no doubt as to Congress' intent. The report clearly states that the NCUA shall encourage the formation of a separately chartered credit union instead of approving an additional group within the field of membership of an existing multiple common-bond or single common-bond credit union. The NCUA's clear preference for larger existing credit unions does not simply ignore the legislative intent of the CUMAA; it contradicts it totally.
Second, is the NCUA's revision of the economic advisability level consistent with Congress' intent to encourage the formation of new separately chartered credit unions for groups with less than 3,000 members? The answer is clearly no. The new NCUA chartering and field of membership manual establishes a threshold that the agency suggests is necessary for economic advisability for charter applicants. We believe the level is contrary to the objectives of the credit union movement. The industry's original goal was to serve, through a cooperative effort, the provident credit needs of a well-defined group of individuals of modest means. If a charter applicant does not have a proposed field of membership of at least 3,000 primary potential members, the applicant will be required to submit "significantly more support" for its application.
We appreciate that the economic advisability of charter applicants must be addressed by the - chartering authority for safety and soundness reasons, but we do not understand the logic in establishing a threshold that effectively requires applicants who do not have a specific number of potential primary members to become part of a multiple group credit union. Rather than encouraging a well-defined group to submit an application, the NCUA is helping established credit unions to grow, not by adding persons within a common bond, but rather by adding groups of potential primary members of up to 3,000 persons.
The definition of a multiple common bond group contained in the statute provides that a multiple common bond credit union is one that has more than one group, each of which has (within the group) a common bond of occupation or association and has a number of members that do not exceed 3,000.
The consequence of the interplay of these two provisions, one by statutory and one by regulatory fiat, is that smaller credit unions will not be chartered or supported and larger credit unions will be encouraged to grow exponentially. We suggested to the NCUA that the economic viability threshold be reduced so that small, well-defined groups will not be discouraged from chartering their own credit union and forced to join a multiple group organization. In the past, the NCUA informally suggested that the minimum threshold for a credit union's viability was 1,000 potential members. In fact, IRPS 94-1, the former chartering manual, sets a minimum size of 500 potential members.
It is important to note, as Rep. John LaFalce has done, that even the New York Credit Union League told the NCUA Board that 343 of New York's "fully functioning" credit unions could .never have been chartered under these "arbitrary" standards. (Statement of the Honorable John LaFalce on NCUA Approval of Credit Union Field of Membership Regulations, Dec. 18, 1998.)
Third, when determining whether a large group can be added to an existing credit union, is consideration of the group's "desire" by the NCUA consistent with congressional intent? In the CUMAA, Congress provided explicit instructions for the NCUA to encourage the formation of separately chartered credit unions whenever practical, not whenever a group desires. According to the CUMAA, a multiple common bond credit union may be chartered to serve multiple groups of distinct, definable single occupational and/or associational common bonds of 3,000 or fewer members. The statute provides exceptions for when multiple groups of more than 3,000 members can be added. It also instructs the NCUA to determine whether certain statutory criteria have been met before adding a group to an existing multiple common bond credit union. One statutory criteria is that the NCUA must determine that the formation of a separate credit union is not practical or does not meet the economic advisability criteria. The statute gives the NCUA some discretion in defining the elements for each criteria.
The NCUA exceeded its discretionary authority by adding a subjective factor that may not be a true measure of the goal they are supposed to achieve. According to the NCUA regulations, one factor it will look at in determining whether the formation of a separate credit union is practical is the "desire" of the group. If the group does not wish to form its own credit union, the NCUA may allow the group to join an existing credit union, regardless of the group's size.
To the extent possible, federal regulations should set clear and objective standards. Adding a subjective element such as the "desire" of the group increases the potential for inconsistent results.

Not only is "desire" a difficult concept to measure accurately, it is questionable whether the NCUA has the resources to devote to this task. Consumers may not truly understand the implications of joining an existing credit union versus starting a new one. Moreover there is a likelihood that larger, opportunistic credit unions could influence the "desire" of select groups to join their credit union. This type of influencing activity is not only contrary to the intent of the credit union movement, it is blatantly discriminatory.
Fourth, what impact does the NCUA's policy on overlapping fields of membership have on smaller credit unions? The NCUA's revised stance on issuing "overlaps" tends to favor the growth of larger credit unions at the expense of smaller, more traditional institutions. Generally, overlap protection is provided to single and multiple common bond chartered credit unions when the beneficial needs of the members of the group proposed to be included in the field clearly outweigh any adverse effect on the overlapped credit union. The chartering manual lists several subjective factors the NCUA Regional Director must consider in analyzing whether the members' beneficial needs outweigh the adverse effect on the overlapped credit union. Guidance referring to factors such as "the nature of the issue" or "efforts made to resolve the matter" is ineffective for preventing a large credit union from overlapping, and ultimately overwhelming a smaller credit union. It stands to reason that a large credit union has greater resources, giving it an unfair advantage over a smaller, member-driven and customer-focused credit union when fields of membership overlap.
Large community-chartered credit unions receive even greater preferential treatment than large credit unions of other charter types. According to the new chartering manual, no credit union will receive overlap protection from a community chartered credit union except for newly chartered credit unions. As I have already mentioned, a community chartered credit union could be as large or larger than an entire county with 300,000 or more inhabitants. Giving preference to a credit union of this size makes it easy for it to overwhelm a smaller credit union oriented to serving the provident credit needs of a well- defined group of individuals of modest means.
Fifth, does the NCUA's final rule implement congressional intent with respect to the reasonable geographic proximity requirements for adding to existing credit unions? In particular, please discuss the NCUA' s definitions of "service facility" and "service area."The NCUA has failed to explain the necessary terms to ensure consistent implementation of congressional intent. The statute permits groups to be added to a multiple common bond credit union only if the group is within "reasonable proximity to the location of the credit union." The responsibility for clarifying these terms was delegated to the NCUA.
However, the only assistance the NCUA's regulations provide in clarifying what the term "reasonable proximity" means is that it should be a geographic limitation. The NCUA's definition of a credit union's location is the credit union's service area - a term that is equally vague. According to the NCUA, a credit union's service area is the area that can reasonably be served by the service facilities accessible to the groups within the field of membership. The NCUA's definition for a service facility comprises nearly everything but an automated teller machine. Credit union-owned electronic facilities and mobile branches are specifically included.
The lack of precision in these definitions will most likely result in irregularities in adding member groups to credit unions. These definitions are overly expansive. For instance, electronic facilities and mobile branches lack permanence. They are too easy to remove or relocate, causing distortions in the way a credit union's service area is defined. This lack of permanence could also lead to gerrymandering on the part of credit unions wishing to include economically advantageous groups to their service area.
Sixth, does the NCUA have an obligation under CUMAA to place a group with the local credit union which would most benefit in terms of safety and soundness even if such credit union did not file the application? The statute does not specifically mandate the NCUA to place a group with the local credit union which would most benefit in terms of safety and soundness even if the credit union did not file the application. Rather, the CUMAA gives the NCUA broad discretion to establish the criteria that it will apply in determining whether to add a group to the field of membership of a credit union with a multiple common bond charter. The CUMAA's findings mention the importance of improved credit union safety and soundness provisions. This finding, coupled with the CUMAA provisions granting broad NCUA discretion, might be read to suggest that the NCUA may, for safety and soundness reasons, place a group with a credit union that did not file an application.
However, the NCUA should not be placed in the position of matchmaker for potential member groups. The NCUA should focus on circumstances where both the credit union and the member group to be added are willing participants to the transaction.
Seventh, what are your views regarding how the NCUA's final rule defines the terms "family member" and "member of household?" The statute limits the eligible members of an individual credit union by restricting the basis of the relationship of an individual to another person to immediate family or household member. The NCUA is given the authority to define those terms.The NCUA promulgated a proposed definition of "immediate family members" which would have made credit union membership available to those with even the remotest degree of kinship. For example, after a member's spouse becomes a member, the spouse's grandparents, parents and siblings become eligible members, regardless of whether they are in the same household. Then, if the spouse's grandparents, parents or siblings become members, membership eligibility expands to their "immediate family members," thus creating a domino effect whereby once one family member joins, even distant family members by blood or marriage become eligible to join.
The final regulations expanded the definition even further by segregating and defining separately the terms "immediate family member" and "household". The final regulations open up membership eligibility to anyone living in the same residence who participates in the maintenance of the household and demonstrates a degree of permanence. This includes roommates, and domestic partners - possibly even live-in butlers and cooks. The domino effect applies in this situation too because the immediate family member of each member of the household would become eligible for credit union membership. The Washington Times, in a December 18, 1998 article, noted that these rules open membership up to "just about anyone who wants to join a credit union."
Again, it is important to review a fundamental purpose for developing these new rules. The CUMAA specifically states that a meaningful affinity and well-understood sense of cohesion are essential to the fulfillment of the public mission of credit unions. I find it difficult to fathom how this standard could be interpreted to include a roommate or cook of a potential member.
The fact that the member eligibility definitions are overly broad leads to other complications besides the unfettered growth of credit union behemoths.. One complication is the area of compliance. After a careful reading of the regulation and chartering manual, I have not been able to discover any procedures for ensuring that credit unions are complying with the member eligibility definitions. Consequently, credit unions are free to extend membership to practically everyone. For example, many car dealerships have indirect lending programs established with various financial services institutions, including several large credit unions. The car dealer presents a potential buyer with a choice of several loan rates from these institutions. The car dealer then submits the necessary paperwork directly to whichever lender the buyer chooses. In the case of a credit union, this includes the membership application form. At no point during this transaction is the buyer's membership eligibility verified. It is self evident how a large credit union with a dedicated indirect lending department could easily amass the entire local market for car loans. Smaller credit unions do not have the resources to allocate to such programs, and small community banks are hobbled by relative regulatory and tax burdens when they attempt to compete.
Another counter-intuitive yet unseemly by-product of overly broad member eligibility and field of membership restrictions is that credit unions can actively exclude groups of undesirable members. The new rules allow credit unions to cherry-pick groups in their community and selectively choose only the "best" markets. I find this disturbing. As a mutual savings institution, my doors are open to the entire community. I comply with the Community Reinvestment Act and endorse its intent to ensure that all segments of the community are served. Large credit unions functioning like banks should be required to meet similar community investment standards.


Eighth, what are your views regarding the NCUA's final rule regarding community credit union charters and the geographic and population limits which the final rule places on community credit unions? One of the most egregious examples of the NCUA's capitulation to larger credit unions is in the chartering 'provisions for the community credit union charter. The statute provides for the creation of community credit unions that serve a well-defined local community, neighborhood, or rural district, and the NCUA is given the authority to define what these terms mean.
The NCUA's new regulations and chartering manual permit a credit union to accept as members all persons who live, work, worship, volunteer or go to school in a specified geographic area. The new regulations do not give a maximum permissible size for a community. Rather, the NCUA will grant a community credit union charter so long as the application includes documentation that it is a well-defined local community, neighborhood, or rural district. According to the preamble to the new chartering manual, indicia of a "local community, neighborhood or rural district" encompass several factors including interaction and/or common interests. The NCUA admits that the chartering manual does not precisely define interaction.
In determining interaction or common interests, the NCUA will look to factors such as whether the area has: (1) shared government facilities, (2) local festivals, (3) area newspapers, or (4) a single major trade area. More concrete factors are necessary to determine interaction or common interests. Granting a community charter to an applicant merely because of the existence of a local festival, for example, Ground Hog Day, would be irresponsible. Some local festivals bring disparate groups to a place with no real pretense that a "melting pot" or community of interests is created.
The new chartering manual offers a streamlined approval process for recognized single political jurisdictions with not more than 300,000 residents. Frankly, it strains the imagination to identify a well- defined local community as any jurisdiction under 300,000 people. It may be helpful to add some perspective to this assertion. Only two cities in my home state of New York - New York City and Buffalo - have more than 300,000 people, and Buffalo only has 310,000. How can every other city in the state qualify as a "well-defined local community?" Apparently, the NCUA disagrees with me on this issue. Even after reviewing the comment letters received in response to the proposed regulations, the NCUA felt it necessary to clarify in the preamble to the new chartering manual that a local community is not limited to a single political jurisdiction with a population of 300,000 or less.
In order to be granted a community charter, larger geographic areas with higher populations need only provide documentation that they represent a well-defined local community,neighborhood or rural district. The diversity in political subdivision boundaries and population densities makes it difficult to state categorically that a political subdivision is automatically a well-defined local community. Supporting documentation that an area is well-defined and local should be required for all applications.
The NCUA claims that a state or a congressional district would not qualify for a presumptive community. But the new rules do not prohibit an entire state, metropolitan city, or area covering multiple counties to be granted a community charter even if their population exceeds 300,000. The regulations clearly state that if an applicant provides sufficient documentation supporting that the area is a well-defined local community, a "community" charter would be approved. If the applicant is a state, metropolitan city or area covering multiple counties and provides sufficient documentation, conceivably, it would be granted community charter. It should be inherently impossible for a state, major metropolitan city, or multiple county area to be defined as a well-defined local community.
An alternative to establishing a population threshold would be that applicants for a community charter must satisfy certain criteria specified in regulation. Such criteria should not be subjectively based on questions of whether the geographic area or the population has a commonality of interests on the basis of a shared newspaper or local festival. For example, a local festival may draw persons with common interests to an area for only a short period of time each year. For instance, not all ground hog lovers live in Punxsutawney, Pennsylvania, but they may go there every February 2. The criteria should include economic and statistical data about employment, industry, stability of the economy, population shifts, and availability of other financial services. Establishing objective measures will result in the identification of a well-defined local community without diminishing the ability of a credit union to convert to a community charter.
Several other issues arise in the context of the community credit union charter. The proposal is silent as to whether merging community credit unions must have identical boundary/population requirements. It is conceivable that continued mergers of community credit unions could create massive credit unions with large, undefined, and clearly non- local communities. The NCUA should routinely identify the impact of mergers, if any, on the service areas of community credit unions. In addition, the NCUA should disclose how many such community-based charters it will grant for all or part of such an area. The new chartering manual permits businesses and other legal entities within the community boundaries to become members of a community chartered credit union. This could conceivably permit an international conglomerate to become a community credit union member, so long as a branch office is located in the community. A business' eligibility should be more clearly defined and appropriately constrained. For example, only businesses whose home offices are located in the community might be eligible to join a community credit union.
Let me reiterate that I do not wish to deny credit unions their proper role in providing financial services, or to limit consumer choice. Moreover, credit unions should be allowed to build their businesses. The Hudson Valley Federal Credit Union, with an office approximately six miles from my office, has $942 million in assets, compared with $130 million in my bank. Their products and services are no different from those of Walden Savings. But the key difference is that Hudson Valley wants to leverage their substantial advantages to grow at the expense of other community-oriented banks and credit unions. If larger credit union conglomerates want to keep their credit union charter but extend their membership reach or product lines, they should pay taxes and accept the responsibilities concomitant with extra privileges. Congress should extend to them the right to transform into conglomerate credit unions only if they elect to pay taxes.
Congressional Disapproval of Major Rule
By treating them as major rules, the CUMAA enables Congress to override the NCUA's definition of "immediate family member or household" and "well-defined local community, neighborhood or rural district." As I understand the statutory provisions that govern the implementation of a major rule, the NCUA must first submit to the House and Senate a report containing a cost benefit analysis and regulatory impact statement. The NCUA is exempt from this reporting requirement if it finds that their proposed rules will not have a significant impact on a substantial number of small entities.
The NCUA asserted that it is exempt from the reporting requirement because the proposed rules will not affect small credit unions. However, the term "small entities" is not limited to credit unions. It also includes small community banks. As I have mentioned on numerous occasions, the NCUA's rules will in fact adversely impact small traditional credit unions and community banks. Therefore, the NCUA must fulfill its statutory reporting obligations.
A major rule provides Congress with 60 days to review the rule before it takes effect. Congressional review begins by submitting a "joint resolution of disapproval" to both the House and Senate Banking Committees. If a joint resolution of approval is enacted, the proposed rule shall not take effect. At a minimum, Congress should submit a joint resolution of disapproval so that a proper review of these definitions can occur.
Conclusion
ACB opposes regulations which would allow a single credit union to encompass ever-expanding multiple-employer or community groups, in clear contradiction to the intent of Congress. The majority of credit unions still fulfill their original mission and deserve a continued tax subsidy. But at some point, large credit unions that draw from a wide geographic area and sell every financial product imaginable should have the same tax requirements as apply to banks and savings institutions. However, the regulations which purport to implement the CUMAA pose a threat to the majority of community banks and credit unions, on which a few behemoths, masquerading as community, single common bond, or multiple common-bond credit unions, are seeking to prey.
America's Community Bankers stands ready to assist in any way possible to address these issues. This concludes my prepared remarks. I will be happy to answer any questions you may have.
END


LOAD-DATE: February 4, 1999