KENNEWICK, Wash.–In a comment letter on NCUA’s proposed merger rule, the group Endangered Small Credit Union Defense (ESCUD) has expressed its opposition to the elimination of the member-to-member (MTM) comment posting requirement.
In response to what is formally known as “Mergers of Insured Credit Unions Into Other Credit Unions; Voluntary Termination or Conversion of Insured Status (NCUA-2026-0267-0001),” ESCUD’s leader, Doug Wadsworth, wrote, “On behalf of the Endangered Small Credit Union Defense (ESCUD), a 501(c)(4) nonprofit representing 27 formally endorsing small credit unions nationwide, we applaud the NCUA’s continued deregulation efforts! We also commend aspects of this proposal that provide modest relief, such as simplifying disclosure formatting under § 708b.206, which aligns with our calls for reducing over-prescriptive burdens on small CUs with limited resources.
What’s Really Needed
“However, we oppose the elimination of the member-to-member (MTM) comment posting requirement under § 708b.106(d)-(e),” continued Wadsworth, who is CEO of the $75-million Tri-Cities Community FCU in Washington State. “While the NCUA cites low usage (and while we appreciate the NCUA cost cutting perspective), this rarity underscores the need for better member education and engagement—not removal of the mechanism. Small CUs under $500 million already face existential threats from competitive pressures and mergers, and dropping MTM postings could streamline mergers at the expense of small CU survival, making it easier for larger institutions to absorb them without meaningful scrutiny.
“This risks accelerating the extinction of hyper-local CUs, which serve underserved communities and uphold the movement’s cooperative principles,” Wadsworth added.
One Response
Great perspective from Doug Wadsworth. We say credit unions are “member-owned”. If they are, why would NCUA take these rights away?