<p>WASHINGTON – The National Community Reinvestment Coalition (NCRC), the organization that has sued the NCUA over how the agency removed the CAP regulation, is not the oldest of the consumer groups, or the largest or the wealthiest, but the consensus among financial service reporters and analysts is that it may be among the most effective. "NCRC is almost an umbrella group. There is a sense that they represent a broad spectrum, albeit on a very focused agenda," said Keith Leggett, senior economist with the ABA. The organization has been around since 1990, when 16 different empowerment groups, activist organizations and individual activists rallied around the realization that access to capital for homes and small businesses served as economic lifelines for communities, particularly those traditionally understood as low income and with large minority populations. The organizers also wanted a structure they could use in the coming fight over regulatory requirements that would seek to insure financial institutions were accountable for how they dealt with low-income and minority residents. Since then the organization has grown from 16 to 800 dues paying institutional members, including a number of credit unions. Members range from large organizations like the U.S. Conference of Mayors to local fair housing groups to local governmental offices and non-profit and for profit lenders. "We have a pretty wide spectrum," said Joshua Silver, NCRC Vice President for Research and Policy. NCRC is proud to claim that it has members in every state and in every major city and in many smaller cities. Credit unions have become used to hearing about NCRC in connection with the organization's fight with the NCUA over CAP, but Silver stressed that NCRC is not "anti-credit union," or "anti-bank." "We are very focused on helping capital get into the hands of people who need it, particularly people who have been traditionally denied it," Silver said. The group looks at all financial institutions and all financial policies through that lens, he said. "We are not suing NCUA as an attack on credit unions, we are suing NCUA because of the way it has dispensed with what we believe should be a very important debate among credit unions and the communities they serve," he added. Credit unions and credit union organizations that are members of NCRC agreed with Silver's sentiment that credit unions were ill served by not having a fuller discussion of CAP before the agency abandoned the regulation. They also believed credit unions should drop their opposition to CAP which was, they argued, a "truly modest" regulation which attempted to do some very important things. Bill Myers, CEO of Alternatives Federal Credit Union, a $40 million dollar associational credit union in Ithaca, NY, says he has known the founders of NCRC for roughly eight years and supports the need to bring greater awareness and accountability of capital policies for all financial institutions, including credit unions. "The advent of HMDA (Home Mortgage Disclosure Act) data really changed everything," Myers said. "Previous to HMDA, a bank or thrift or credit union could make claims about how it was doing in serving underserved or low income areas and there was no data to support or contest those claims. Well, through HMDA there is data and it doesn't look as credit unions are doing that great," he said. "Credit unions always want to put ourselves in the white hat," he said. "We want to be seen as the good guy financial institutions – because we are, particularly in comparison to banks. But when you look at credit union data standing alone, I don't think credit unions can be happy with our performance so far." Myers pointed out that some credit unions have lived with field of membership restrictions for so they may have developed "a degree of cynicism." Myers reports that among his peers he has noticed a willingness to take advantage of eased field of membership regulations when it comes to low-income areas without necessarily making any commitment to market the credit union broadly in that area. "I think when we accept a lower-income field of membership we are obligated to try to serve that field of membership," he said. Clifford Rosenthal, Executive Director of the National Federation of Community Development Credit Unions (NFCDCU) said the Federation is a member of NCRC and backs the group's efforts in support of CRA, a regulation he credited with "leveraging tens of billions of dollars out of banks and into lower income areas." Rosenthal says the Federation was "extremely dismayed" by the way the NCUA reversed the CAP regulation and felt "taken aback" by then Board Member Geoff Bacino's introduction of it onto the NCUA Board agenda, though he admitted the criticism of the measure is widespread. "I think the credit union movement has been ill served by credit unions' vigorous opposition to such a mild regulation," Rosenthal said. He stressed that the Federation has no policy role in the NCRC and that Federation members are not necessarily NCRC members. Rosenthal said that while he generally supports NCRC goals and activity, he is also critical. "I felt frustrated with the recent NCRC study on credit unions and HMDA data," he noted, "It's too easy to look at that data and come up with simplistic answers. Credit unions need to use that study to help us ask better questions," he said. Rosenthal said a good outcome of the lawsuit would be for NCUA to be proactive and "repeal the repeal" of CAP and to use the regulation to help gather better data about how credit unions are doing serving lower income members. "We find it truly offensive the way some trumpet the addition of low income areas as fields of membership as though that settles anything," Rosenthall said. "Clearly just adding those fields of membership is not enough. Now let everyone know what you are doing to serve that community," he said.</p>