Page 16 - Membership Guide
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business lending had tripled between year-              real estate (CRE)
         end 2004 and year-end 2014
         •The 86 Colorado-headquartered credit                   Credit unions play by their own rules – and
         unions’ assets nearly tripled in the two                their regulator supports them ignoring
         decades from 1994 to 2014                               Federal law
                                                                 •CU regulators too often act as advocates for
         Colorado’s credit unions are not focused on             tax exemptions and special treatment
         low-income borrowers.                                   •Colorado’s largest credit unions cannot
                                                                 prove to be Community Reinvestment Act
         •92 percent of credit unions made no                    compliant
         mortgage loans to low-income Colorado                   •NCUA was under Congressional scrutiny in
         borrowers                                               2015 for lack of transparency
         •Of all the 2013 Home Mortgage Disclosure               •In February, NCUA ignored Congressional
         Act-reported mortgages originated by                    limits and finalized looser MBL limits
         credit unions in Colorado, 3.3% were made
         to lower-income borrowers, 17% were made                Colorado’s largest credit unions are like
         to moderate-income borrowers, 41.9% were                banks in nearly every way – they just don’t
         made to middle-income borrowers, and 37.7%              pay like them
         were made to upper-income borrowers
         •The wide-open fields of membership (FOM)               •The customer products and services offered
         as well as the highly-desirable upscale                 by Colorado credit unions are very similar
         commercial locations of their main offices              to those offered by Colorado’s banks.  The
         and of their branches, suggest the largest              larger the credit union, the more likely it
         Colorado credit unions have targeted                    is to offer many bank-like products and
         communities of moderate-income to upper-                services.
         income residents as desired members                     •All 86 Colorado-headquartered credit unions
         (customers)                                             it would have an estimated tax obligation of
         •The seven largest Colorado-headquartered               up to $64 million.
         credit unions did over 75% of the business
         lending done by all credit unions in 2014.
         Over 92% of those 2014 business loans made
         by the largest credit unions were for owner
         occupied or non-owner occupied commercial

















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