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COLORADO’S CREDIT UNIONS

               REPORT BY MARVIN UMHOLTZ

               Colorado’s Largest Credit Unions: Where rhetoric meets reality and why credit unions must relinquish
               their unmerited perquisites and prerogatives

               PRODUCED I N PARTNERSHIP







                EXECUTIVE SUMMARY
               Large multi -branch, full - service Colorado credit unions have grown to be mainstream federally insured
               depository institutions that are indistinguishable from commercial banks either by the product s they
               provide, or by whom they serve. As ide from their tax- subsidized operations and separate regulatory
               treatment, bank- like credit unions are a significant competitive force in the Colorado financial services
               marketplace.
               Unlike some credit unions, which remain committed to the traditional model of serving a specific class
               of members (customers), Colorado’s largest credit unions no longer focus on employees of a particular
               business, industry sector, or income level. Despite statutes supposedly restricting these credit unions to
               members who are in their field of membership (FOM), they are essentially available to anybody in the
               state, regardless of where they work or how much money they make.

               KEY HIGHLIGHTS Colorado credit unions don’t want customers that share a common bond; they want
               your customers. All of them. •Nearly every Colorado citizen is eligible to join one or more of Colorado’s
               86 credit unions headquartered in the state – and many for out -of - state institutions •Colorado-
               headquartered credit unions ‘business lending had tripled between year-end 2004 and year-end 2014
               •The 86 Colorado-headquartered credit unions’ assets nearly tripled in the two decades from 1994 to
               2014

               Colorado’s credit unions are not focused on low-income borrowers.
               •92 percent of credit unions made no mortgage loans to low-income Colorado borrowers
               •Of all the 2013 Home Mortgage Disclosure Act - reported mortgages originated by credit unions in
               Colorado, 3.3% were made to lower-income borrowers, 17% were made to moderate-income
               borrowers, 41.9% were made to middle-income borrowers, and 37.7% were made to upper-income
               borrowers
               •The wide-open fields of membership (FOM) as well as the highly-desirable upscale commercial
               locations of their main offices and of their branches, suggest the largest Colorado credit unions have
               targeted communities of moderate-income to upper-income residents as desired members (customers)
               •The seven largest Colorado-headquartered 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 real estate (CRE)
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