The Consumer Federation of America submitted comments urging increased resources for the National Credit Union Administration, and offering advice on strategies. Our advice was as follows:

Credit unions should be different than banks. In general, credit union leaders should seek to achieve goals that differ from those of for-profit banks. Their strategies should reflect this distinction. Credit unions should also not rely on overdraft and non-sufficient funds fees for a disproportionately large share of their revenues.

Finally, the NCUA deserves more resources to fulfill its mission. It should create a new position for a green climate officer, employ new staff to enforce consumer financial law violations, and should consider complementing its existing supervisory staff with new professionals with narrow subject-matter expertise.