How is ESCUD already making progress?
Of course with political advocacy it is a *long* game, however - although we have only been around since July of 2025, we have already had some wins, thanks to some great partners who have listened to our unique needs, and who care about our survival. See the Linkedin Group for details, otherwise a recap of some of our victories or progress, is below.
If nobody asks, we certainly won't get anything. So we will ask, without apology.
Oliver Twist: "Please sir... may I have more?"
Schoolmaster: "MORE?!"
ESCUD: Yes. We want more.
Victories and Progress
Meeting NCUA Chairman (Sep 2025): President Doug met in-person with Chairman Hauptman, and shared our small CU challenges, and what the regulatory can do to help us survive and thrive.
NCUA Town Hall Panel Presenter (Sep 2025): Doug was a panel presenter at the NCUA Town Hall Zoom Meeting in September 2025 (sharing how they can help small CUs). ESCUD then provided a *concrete* list of small CU regulatory relief priorities with the NCUA. Chairman Hauptman later commented on Linked in that it was great that somebody was finally advocating for the smallest CUs. Also, according to NCUA Director Julie Cayse, this letter is circulating among the entire agency, and they are finding it valuable and helpful - allowing them to see their impact on small CU survival. Not long afterwards, they announced explicitly their policy of not regulating by enforcement, and likely extending exam cycles for well performing small CUs (coincidence, since those were in our letter)?
ACU Small CU Discount Increased (Oct 2025): We petitioned to America's Credit Unions to increase the "small CU discount" for conference registrations (it only counted up to $50M in assets). Well, they listened and agreed, and now their 50% discount applies to small CUs up to $100M in assets (they even sent refunds to other small CUs who had already paid)! Thank you, ACU!
Go West "Growth Accelerator" Program (Oct 2025): Although they haven't explicitly admitted it, the Go West Association, stepped up their small CU offerings after we organized ESCUD and started making noise. Now they offer a better bargain for training, counsels, and other resources for small CUs. Thank you, Go West! We also asked them for a better conference discount for small CUs, or discounted dues (only for under $25M?), and for greater representation on their board of directors... no progress on those yet, but will keep trying. Regarding national trade associations (ACU or DCUC), small CUs are proportionally represented on their boards, which is fantastic.
HMDA Exemption Progress (Oct 2025): ESCUD explained the burden of HMDA reporting to Greg Mesack of ACU, and he agreed to take up that torch for us, and then in October they followed through - sending a letter to the CFPB on behalf of small CUs, asking for exemption! ACU has some weight, thank you, ACU!
Recognition by DCUC & ACU (Oct 2025): At a recent CU Collaborate Zoom town hall, ESCUD (me) posed the question about maintaining the tax exemption if small CUs are allowed to go extinct. DCUC president Tony H. recognized our efforts, and emphasized that small CUs are the "heart and soul" of our movement, and we must be preserved. Both ACU and DCU are listening to ESCUD, and are working to prioritize small CU needs (whether it is proportionate board representation, capped dues, etc.). Thank you ACU and DCUC! See our tab for "League Advice" or read this: https://www.cutoday.info/THE-tude/Spock-Save-The-Small-Credit-Unions!
ACU Moving on Bond Signature Relief (Oct 2025): In that original letter to the NCUA I described the burdensome/annoying/pointless new bond signature renewal requirements (needing board signatures, appointees, etc.). I also gave a copy of that letter to ACU a couple months ago. ACU just told me they sent a letter requesting relief on this, with a nod towards the small credit union burden. So, ACU advocacy efforts are aligned with ESCUD again, and coming to us for feedback!
Recognition by Washington DFI (Oct 2025): Scott Prior has also visited with the Washington DFI, on behalf of ESCUD. They have also expressed willingness to work with us and hear the small CU perspective, directly. We don't have to wait and hope a regional association or league chooses to speak for on our behalf... we can speak for ourselves, on exactly what our needs and perspectives are.
NCUA Proposal for Regulatory Relief (Dec 2025): NCUA Chairman Hauptman confirmed (personally with Doug Wadsworth) that our ESCUD efforts were instrumental in prioritizing and advancing Supervisory Regulatory Relief proposals they made in December of 2025 here: https://www.federalregister.gov/documents/2025/12/11/2025-22488/supervisory-committee-audits-and-verifications That is a WIN for ESCUD and small CUs!
Highlighting the Small CU perspective (Dec 2025) to a collection of national and regional associations: Represented ESCUD small CU needs in a zoom meeting hosted by DCUC on 12/15/25, including nearly all the national trade associations and many league presidents. The concern was division in the industry, and I was asked to be the first speaker to present the small CU concerns. Outlined as follows: 1. I recognized that both ACU and DCUC for cap dues on big CUs and ensure proportionate representation from small CUs on their leadership boards. This helps ensure that our small CUs voices are drowned out by big ones, at the structural level. 2. Small CUs haven't spoken up enough in past years... we trusted our trade association dues were being spent to help our needs. We have abdicated our responsibility, and we are paying for it. Our small CUs have unique regulatory relief needs, that largely seem to have been ignored for many years, and most advocacy was just helping the giant CUs get even bigger. We are pushing to change the priorities of trade associations and leagues, to do more to save small CUs. 3. Small CUs aren't really concerned about losing the tax exemption, it isn't a priority for us because I don't think we will lose it, we would be exempt (but big CUs are likely at risk for losing theirs). We are also concerned that small CUs are on the path to extinction, which would end up dooming the tax exemption for the remaining big CUs down the road. 4. ESCUD is not a trade association per se, we are just gather endorsements and seeking to partner with trade associations, to encourage member-centric "giving back" and to push for the advancement of our unique small CU regulatory relief needs. 5. Although most big CUs are good (and expanding that footprint is good for consumers), there are some "bad actor" big CUs that seem to be targeting the members and loans of small, local CUs - which is a concern that can't be ignored (especially in light of the possible extinction of the small ones).
NCUA & Survey of Small CU Priorities (Jan 2026): After an ESCUD survey highlighted that small CUs are still very concerned about examiner over-compliance pressure, and general examination exhaustion, another letter was sent to the NCUA on 1/7/2026, highlighting our desire for continued progress in this area to help reduce pressure on small Credit Unions. A copy of this letter was also sent to the Washington State DFI (as an FYI).
Main Street Capital Access Act (Jan 2026): ESCUD also sent a letter on 1/8/2026 to the legislative sponsors of this new bill targeted at helping local main street financial institutions, requesting that *small* credit unions are explicitly listed.
DCUC 2026 Advocacy Priorities Adjusted (Jan 2026): With feedback from ESCUD, this national trade association added or list of specific small CU regulatory relief priorities, to be voted on by their CU members, as their priorities were being set. Thank you, DCUC!
ACU Small CU Advocacy Panel (Jan 2026): Perhaps as a side-effect of all the noise our small CUs have been making, our national trade association is kicking of this new group, to inform their advocacy priorities (and ESCUD President Doug has been appointed a seat on this council). Thank you, ACU!
Podcast Guest: Grow Your Credit Union (Feb 2026): Informing the industry of the small CU perspective. https://growyourcreditunion.com/we-want-you-to-tell-us-when-nothing-suspicious-is-happening/
NCUA: Don't Accelerate Mergers (Feb 2026): ESCUD noticed that a Feb 2026 deregulation proposal from the NCUA (708b on Mergers), would have actually reduced the public visibility and engagement of members comments regarding merger proposals, which is the opposite direction we are looking for. Heck, we want more scrutiny and engagement, to ensure members are well informed and about true benefits. ESCUD noticed this concerning proposal, and reached out to advocacy folks to express our concern over it, and ensure they could see our perspective. If our small CUs don't notice problematic proposals or legislation, and make sure our small CU perspective is shared... things like this can pass right through unnoticed, to the detriment of our survival. ESCUD is working to help ensure this doesn't advance any further.
NCUA Exam Doc Prep List (Feb 2026): I had a great chat with NCUA Director Julie Cayse at a Go West conference last year, and she asked for my feedback on shortening/simplifying the exam prep doc request list. I did so. Well, they just announced in the Feb 2026 NCUA Supervisory Webinar that they have successfully got it shortened, so I would imagine our ESCUD *specific & concrete* feedback helped (but difficult to verify).
NCUA Supervisory Priorities Webinar (& NCUA Feedback) Feb 2026: I attended this webinar and submitted a few questions in advance, and they raised it up front, as well as many others related to small CU relief. The answers left much to be desired (didn't answer the questions at all), so I submitted an "ESCUD Response" to the NCUA, clarifying the small CU perspective (again, concrete and specific examples). This NCUA feedback is also posted in the CU today online.
NCUA Chairman Visit (March 2026): We met privately with Chairman Hauptman, Sarah Bang and Larry Fazio, for an hour to discuss small CU regulatory relief needs, advocacy, and how we can work together to help small CUs survive and thrive. Small CU CEO representation included Doug Wadsworth, Sarah McNiel, Joshua Urbick and Andrew Crosby.
Hiking the Hill (March 2026): Doug and Sarah managed to visit with several legislative offices to discuss small CU unique regulatory relief needs, and the concerns of continued industry consolidation. Visits included: Murray, Cantwell, Baumgartner, Dexter, Glusenkamp Perez, Crapo and French Hill's Financial Services Committee. What impression did we get... how were we received? These offices are likewise concerned about industry consoliation leading to the dissapearance of our small CUs, they understand the small CU difference, and they have noticed that small CU voice has been absent from the table. They were eager for our perspective, and wanted to partner further in specifically helping our smallest institutions survie and thrive. Of course we stressed that we are aligned with great leagues and trade assocations (and we celebrate the CU movement regardless of size), but we also have unique regulatory relief needs that rarely reach legislators.