Wake Up and Take Action

The Independent Community Bankers of America and the nation's community banks are calling on policymakers and the public to “Wake Up” to the risky practices, costly tax subsidies, and irresponsibly lax oversight of the nation’s credit unions.

Learn how the tax-exempt status of credit unions affects your state with our state-by-reports and gain key messaging guidance through the Wake Up Messaging Playbook.

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ICBA continues fighting debt plan for largest credit unions

July 10, 2020

ICBA continued pushing back against a National Credit Union Administration proposal that would allow the largest and most complex credit unions to issue subordinated debt as an alternative form of capital.

In a comment letter, ICBA said increased leverage and lending inexperience amid a low-rate environment is a recipe for disaster for an industry that continues to push the envelope on acceptable business models with an out-of-control growth trajectory.

Under the proposed rule, which ICBA has called on the NCUA to withdraw, the subordinated debt instruments would count toward qualifying credit unions’ risk-based net-worth requirement. While low-income credit unions are currently permitted to issue subordinated debt, the proposal would add an additional 285 complex credit unions representing $730 billion in assets.

ICBA noted that the proposal itself describes credit unions previously using secondary capital irresponsibly, including poor due diligence, inadequate cost-benefit analysis, premature and excessive concentrations, and lack of responsiveness to mounting losses.

The NCUA voted in January to propose the plan after introducing an advance notice nearly three years prior. In a 2017 comment letter, ICBA said the plan would put the financial system and taxpayers at increased risk merely to expand the activities of credit unions beyond the limits justified by their tax exemption.

HOW CREDIT UNION'S TAX-EXEMPT STATUS AFFECTS YOUR STATE

These state-by-state reports show how credit unions have exceeded their original mandate and how that unchecked growth has negatively affected local communities across every state.

See the Report for All of the USA

Find your state

Charts

Credit unions in your state used their tax exemption to avoid paying

 

in federal income taxes.

House

In 2022, credit unions across your state held a grand total of

 

in tax-free assets.

People

In your state credit unions paid $0 in federal income tax. Meanwhile,

Nurses paid:

Cashiers paid:

Teachers paid:

Wake Up Messaging Playbook

Wake Up Messaging Playbook

Find out how community bankers can more effectively advocate for a level tax and regulatory playing field between tax-exempt credit unions and the community banking industry. Access your playbook today. You must be a member to access this content.

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