Progress and Victories

How is ESCUD already making progress?

Of course with political advocacy it is a *long* game, however - even though 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.

1. NCUA: President Doug met in-person with Chairman Hauptman and was a panel presenter at the NCUA Town Hall Zoom Meeting in August 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)?

2. ACU Small CU Discount Increased: 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!

3. Go West "Growth Accelerator" Program: Although they haven't explicitly admitted it, the Go West Association, stepped up on 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. 

4. HMDA Exemption Progress: 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!

5. Recognition by DCUC & ACU: 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!

6. ACU Moving on Bond Signature Relief: 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! 

7. Recognition by Washington DFI: 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.  

8.  NCUA Proposal for Regulatory Relief: NCUA Chairman Hauptman confirmed (personally with Doug Wadsworth) that our ESCUD efforts were instrumental in prioritizing and advancing  Supervisory Regulatory Relief proposals f 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!

9. Highlighting the Small CU perspective 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).

10. NCUA & Survey of Small CU Priorities: 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).

11. Main Street Capital Access Act: 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.

12. DCUC 2026 Advocacy Priorities Adjusted: 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!

13. ACU Strengthens Small CU Voices: With all the noise ESCUD has been making, this national trade association decided to kick off a new "small CU Advocacy panel" at the beginning of 2026to better inform their small CU regulatory relief priorities (and it sounds like President Doug has been appointed a seat on this council).  Thank you, ACU!