During the Credit Union Campaign for Consumer Choice — the effort to pass the bill most frequently referred to in credit union land as HR 1151, but more formally known as the Credit Union Membership Access Act — the movement flexed its much lauded grass-roots muscle and generated scads of letters, emails and calls to congressional offices.
Indeed, members of Congress were getting so many calls and emails from concerned credit union activists, that one congressional staffer actually called me and said, "Please, I'm begging you, tell them to call off the dogs already!"
Of course, I also happened to be married to this congressional staffer, but that's a whole other story. But among the things I learned from being married to this Capitol Hill denizen were:
- Contacts from actual constituents are vital and, in some ways, more compelling than PAC dollars.
- Volume counts.
- Type of constituent contacts counts — a letter that has been carefully, individually written carries more weight than a bunch of form letters.
- And yes, they really do notice this stuff — they've got caller ID and know when a call is from a call center, rather than an individual's home, for example.
Not being married to anyone who has worked for NCUA, I can't say to what degree all of these things apply to the federal regulator when it receives comment letters on its pending regulation, but my educated guess is that they largely do.
Which is why, of course, much was made of the 2,056 comment letters the agency received on its first risk-based capital proposal — far and away breaking the previous record of about 1,300 that were filed when NCUA was looking to salvage corporate credit unions in the wake of the financial crisis.
Which is why, of course, hardly anyone was all that flabbergasted to see the revised RBC rule break that record just months later, drawing 2,167 comments.
When I started culling through those letters — and I don't envy the folks at NCUA who will be put to the task of reading through every single one of them — I saw a number of credit unions that filed multiple comments, as well as individuals not immediately associated with the running of a credit union.
In most cases, these comments were to the point and could basically be summed up as, "we really hate this rule." There were, of course, any number of well-written comments that offered up detailed suggestions of ways to improve the rule, as well.
But, as 1st Valley CU CEO Gregg Stockdale pointed out in a comment he posted on www.cujournal.com some time ago, NCUA is going to recognize "fill-in-the-blank" form letters, and it's far more valuable to offer up specific objections — and specific ways to resolve those objections — than it is to just say "we really hate this rule."
I don't believe NCUA will discount those "form letter" comments entirely — as I said before, volume does count for something. But if I noticed some last names among some of the individual comment letters coming from people who ostensibly are just run-of-the-mill credit union members that were suspiciously similar to the last names of certain credit union executives, I'd have to guess NCUA is going to notice, too.
None of this is to discourage credit unions from taking this form of advocacy and grassroots engagement seriously — the ability to generate this kind of a response is exactly the reason the credit union lobby is considered to be a force to be reckoned with on Capitol Hill.
But I do have to wonder at what point NCUA will just start tuning out the "we really hate this rule" message... if it hasn't already.
Editor in Chief Lisa Freeman can be reached at email@example.com.