I was compelled to offer some of my thoughts on Mike Welch's column asking the industry to take a closer look at credit unions converting to thrifts (CU Times, Sept. 5) The problem with the thrift conversion issue is that the CUs which have done so, know why they did it and the one's considering it know why they consider it an option, but the motivation isn't clear to most, including the press. Credit unions which want to grow the franchise and take the quality of their service offerings to more consumers, and do so in as competitive posture as possible, see regulatory oversight and regulations such as PCA to be a barrier. They may not know for sure, but they sense that the thrift regulator won't be an obstacle-they're right. A lot of the work I've done over the years at conferences and board meetings has focused on the way banks manage their growth and earnings stream versus CUs'. The simple point is this: CUs utilizing their brand equity which I define as the member loyalty they've garnered over the years, can leverage this "brand loyalty" into more marketshare by recognizing (like the banks have) that they can get by with less capital; invest to make more income; model their plans with and discuss them in board meetings….and grow safely and soundly. The regulator needs to step to the plate and relieve the burden. Credit unions can accomplish their goals and avoid risk pitfalls such as interest rate risk and capital risk. We should foster an environment of understanding and knowledge using practical rhetoric to provide the CUs with the information they need to compete, not brow beat them into inaction. Perhaps a symposium such as this will be helpful, along with continued coverage by the press. Credit unions which have converted or considering conversion, are probably doing so probably because they feel they have to, not because they want to. Peter Duffy SVP, investments First Empire Securities Albany, N.Y.