TALLAHASSEE, Fla.-A recent report from the Filene Research Institute examines corporate governance practices at CUs in the United States and Canada.

But some observers suggest such a comparison isn't fair, because of the vast differences between CU systems in the two nations. Dan Clark, a consultant in board governance and strategic planning, stressed that the comparison of U.S. to Canadian CUs isn't an apples-to-apples comparison. "I get the general feeling that Canadian CU governance practices are far more advanced," said Clark. "One contrast, for example, is that Canadian CU boards, more than (U.S.) CU boards, do self-examination. That's been a weakness among (American) CU boards."

While the study's authors attempted to survey CUs in both nations, they achieved only about a 35% response rate in Canada and Quebec, and a "significantly lower response" rate among American CUs, said Peter Goth, a co-author of the study.

Goth said that the report's findings may be somewhat distorted because Canada doesn't have nearly as many small CUs as the U.S. He noted that as of 2010, the five largest CUs in Canada (1.3% of all CUs) hold $46 billion in assets, about 36% of total assets in the country.

John Gregoire, a consultant with The ProCon Group in Madison, Wis., asserted that the low response rate from American CUs doesn't invalidate the study. But "what I would question is the transferability of the Canadian model to the U.S. The Desjardins model ... is a very top-down structure," Gregoire said. "Essentially their primary central credit union, if you will, sets the rates for the rest of the system."

"The second piece that can't be dismissed is that in Quebec the people are fiercely French," he added. "They really see the Desjardins system as their independent FI system that maintains their independence as a French-speaking people. So it's a very different culture than you see in the U.S."

Gregoire added that while American CUs would probably love to replicate the strong market share enjoyed by Canadian credit unions, the top-down authority and other elements make it a system that can't necessarily be transitioned to American markets.

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