Friday, January 29, 2016

FedComp Will Be a Gold Sponsor In Denver

Let's welcome FedComp as a Gold sponsor this year in Denver, CO. September 28 -October 1st, 2016.

Assisting “Small Entity” Credit Unions Keep their Doors Open

FedComp accepts the challenge once again to keep “small entity” Credit Unions from being swallowed up by the big boys and ceasing to exist.

Fairfax, VA. (22 January 2016) – Three years ago on January 17, 2013 Credit Union Times carried a story entitled “FedComp Keeps Light on for Small Credit Union”.

And now, again FedComp is showing “small entity” credit unions how to “keep their doors open” by providing a cost efficient solution to entry to the mobile financial age with its visionary Mobility Suite of Solutions.

This set of suites, from entry to advance, allows credit unions to choose the type of member services they wish to offer; from the “Mobile Data Solution” entry suite to the full range of the services found in the “Mobile Business Solution” suite.

The first two entry Suites, “Mobile Data” and “Mobile Banking”, includes security features that are “Best-In-Class” and will stand with the billion dollar financial institutions. FedComp’s data security even meets the new FFIEC requirements (November 10, 2015), which some larger financial institutions have yet to deploy.

In the 4th quarter of 2015, FedComp completed moving all of its hosted credit unions to OGO’s Community Cloud Platform (a CUSO). This has enabled FedComp to offer the Mobile Data Solutions as a cost effective data storage system utilizing the advantages of a cloud platform. FedComp is able to provide its hosted clients a full range of security services, including:
  • State-of-the-art IT resources with end-to-end security
  • Offsite data security
  • Data redundancy
  • Anywhere any time 24/7 disaster recovery
  • NCUA compliance reporting
When a credit union is hosted with FedComp they no longer need to be concerned about onsite hardware security, contingency, or NCUA audits as FedComp can provide fully compliant reports for each individual credit union.

FedComp’s new Mobility Suite of Solutions is scalable, offsite, and is auditable. Each individual credit union data set is isolated specific, either logically or virtually, within the cloud platform and is locked down to meet SSAE 16, SOS 2, NCUA and other data security standards.

Another benefit given to credit unions when they are users of FedComp’s Mobility Suite of Solutions offered by MoadBus is the ability to offer a Mobile Banking app to their members equal to apps by large Wall Street banks. FedComp’s mobile banking app, is an integrated part of its core data system, not an add-on. FedComp is offering its credit union “World-Class” security in its Mobile Banking app. The app incorporate advanced user authentication, devise and transaction verification (one-time password (OTP), voice, facial recognition and finger print) and provides end-to-end security using multi-layer encryption.

As noted by FedComp’s CEO, Mr. Duff, in 2013 “FedComp can help credit unions stay on the cutting edge of technology”. The Mobility Suite of Solutions is the application of today’s cutting edge cloud-hosted mobile technology to assist “small entity” credit unions in meeting the challengers of survival in the current environment of greater and greater competition and regulations. The Mobility Suites of Solutions was designed to allow the credit unions to “pay-as-needed” for the features they desire. It is intended to assist the credit union’s CEO to better utilize their limited resources by assigning certain tasks to FedComp rather than handling them in-house. When a credit union is relieved of regulatory and back-office administrative tasks they can provide better service to their members resulting in market growth, creating new revenues.

Once again as it has for the last 30 years, FedComp is supporting its 750 plus clients and the “small entity” credit unions in general to keep their lights on and doors open.

For more information reach out to;
Homer Fager
FedComp. Inc.
(800) 733-3266 x390

Wednesday, January 27, 2016

Dan Berger Featured at NCOFCU Annual Conference in September

“Update from The Hill”
Dan Berger - President & CEO National Association of Federal Credit Unions (NAFCU)

For 12 years, Dan Berger has been listed as one of the most influential lobbyists in Washington D.C. by The Hill newspaper. He has been a commentator on Fox News, CNBC and CNN, and is quoted regularly in the Wall Street Journal, The Washington Post and numerous financial services publications.  Dan’s presentation will give credit union leaders his view of the political environment; explore current legislative and regulatory issues; discuss the national economy and the overall state of the credit union industry. 

Friday, January 22, 2016


Horrible news out of Arkansas this morning where an East Pulaski County Firefighter has been killed in the Line of Duty-after being shot while he was helping a patient. It happened around 0500 hours this morning on Dortch Loop in North Little Rock. The suspected shooter is in custody. More to follow. Our condolences to ll those affected. RIP.
Take Care. Be careful. Pass It On.
The Secret List 1/22/2016-0830 Hours

As you know, an Arkansas Firefighter (Lt Jason Adams, 29) was shot and killed in the Line of Duty this morning. Even more tragic is that he was mistaken as being an intruder while inside to assist with a medical emergency this morning. Additionally, reports are that one of the first responding ALS providers was Lt Adam's own wife.

The shooting happened about 0500 hours on Dortch Loop in North Little Rock. Word is that Lt Adams responded to that medical emergency call at the house of Greg Pruitt, after Pruitt's wife called 911. Nearby Sherwood Fire Department officials say Adams, who lives about a half-mile away from the home he was responding to on Dortch Loop, was a 5 year member of Sherwood FD, but was responding as an East Pulaski VFD member.

Reports are that Pruitt was coming out of a seizure, when he mistook Lt. Adams for an intruder.
Pruitt then shot and killed Adams, who was reportedly standing in the doorway of that bedroom.
Cops are still investigating and crews are still processing the scene. No word yet on if any charges are expected to be filed. 
More to follow.
Take Care. Be Careful. Pass It On.
The Secret List 1/22/2016-1200 Hours

Wednesday, January 20, 2016

"You Just Never Know" Denver Fire Chief Stabbed

Denver (Colorado) Fire Chief Eric Tade was stabbed this afternoon when a some nut job jumped into the SUV he was driving. He was on duty, driving his DFD black SUV in the area of fire headquarters when an unnamed woman jumped into the SUV and stabbed Tade shortly after 1330 hours. He took himself to the nearby firehouse where he was treated before being taken to the hospital. He was listed in fair condition at Denver Health Center with wounds to his hand and leg. Cops say witnesses helped track down the suspect who has been arrested. One civilian was was walking through the intersection when he saw the chiefs black Ford Explorer rolling down Colfax with no one inside...and the chief walking to the firehouse. We wish him a quick recovery.
Take Care. Be Careful Pass It On.
The Secret List 1/19/2016-1630 Hours

Friday, January 15, 2016

Excessive Fee Lawsuits in Credit Union Land

Lakeland, FL — Credit unions are increasingly coming under fire for excessive overdraft fees, in the same way that major banks have been taken to task for misdeeds such as reorganizing transactions to maximize fees. In October plaintiff Martha Towner filed a Credit Union Excessive Overdraft Fees lawsuit alleging 1st MidAmerica Credit Union charged overdraft fees improperly.

But that’s just the tip of the iceberg, according to various media reports. Since September, at least a dozen credit unions have been hit with class-action Excessive Overdraft Fees lawsuits in nine states, with various pundits weighing in with the observation that this could be the tip of the iceberg.

Towner, in her class-action lawsuit (Towner et al v. MidAmerica Credit Union, and Does 1-100, case No. 3:15-cv-01162, filed October 20, 2015 in US District Court, Southern District of Illinois), claims that her credit union charged her overdraft fees on various transactions, even though there were sufficient funds in her checking account to cover those transactions.

Tracy Fry is another plaintiff who takes exception to the practices of credit unions. Fry asserts in her Credit Union Lawsuit filed in November that MidFlorida Credit Union based in Lakeland charged overdraft fees based on members’ available balances, rather than actual balances. Not only does Fry assert that such methodology is improper, but also constitutes a breach of MidFlorida’s opt-in agreement and was not consistent with disclosures issued to members.

 MidFlorida, it should be noted, serves 220,000 members and boasts $2.3 billion in assets.
 Plaintiffs assert that credit unions with such assets do not need to be nickel-and-diming their members in such fashion. Pundits and industry watchers, meanwhile, say that what we’re seeing is just the tip of an iceberg that will soon reveal itself.

Numerous Credit Union Excessive Overdraft Fees Lawsuits have alleged that credit unions altered the sequence of transactions to maximize fees. While in some cases this has yet to be proven, other lawsuits - such as those of Fry and Towner noted above - accuse the credit unions of misleading practices while basing fees on available balances, rather than actual balances. Industry watchers assert that such lawsuits are not necessarily alleging the credit union is doing anything blatantly improper, but rather is accusing the credit union of misleading conduct.

Attorneys representing the interests of credit unions are urging such organizations to review their disclosures to ensure everything is buttoned-down, thus avoiding any fee, debit or other activity that might be viewed as misleading.

Plaintiffs, on the other hand, aren’t waiting for credit unions to get their respective houses in order. If they have been misled or wronged with unnecessary fees, the credit union is going to hear about it through the plaintiff’s Excessive Overdraft Fees Lawsuit lawyer. 

To read more like this visit: 

Thursday, January 14, 2016

NAFCU responds to President Obama’s State of the Union Address

WASHINGTON, DC (January 13, 2016) — In response to President Obama’s State of the Union address, National Association of Federal Credit Unions (NAFCU) President and CEO Dan Berger issued the following statement.

“NAFCU and our members appreciate the president’s outlook that we are in a time of extraordinary change. NAFCU welcomes the prospect of working with the administration and Congress to move our country’s economy forward, particularly through several key issues that mirror our priorities for 2016 – including regulatory relief for credit unions and increased small business lending.

“We welcome President Obama’s recognition that a thriving private sector is the lifeblood of our economy. Our nation’s credit unions are uniquely qualified to help make this a reality by facilitating access to capital and financial services in communities throughout Main Street America. Unfortunately, they are restricted by an arbitrary member business lending cap on credit unions. Lifting this arbitrary lending cap could make more capital available to small businesses and help create valuable jobs.”

“President Obama’s call that we eliminate outdated regulations, as well as his acknowledgment of excessive red tape, echoes our concerns about the overwhelming impact of the compliance burden on credit unions. In particular, the impact of rulemaking as a result of the Dodd-Frank Act is evident as the number of credit unions continues to decline, dropping since the second quarter of 2010 by more than 17 percent (more than 1,280 institutions), 96 percent of which were smaller institutions with assets of less than $100 million.

“NAFCU looks forward to working with the administration, Congress and federal regulators on ways to ease Dodd-Frank burdens that were not intended for the credit union industry, relief from constraints on lending to member small businesses and enactment of national data security standards that ensure all stakeholders are doing all they can to protect consumers’ sensitive personal and financial data,” said Berger.

The National Association of Federal Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance.


Supervisory Priorities for 2016
1775 Duke Street, Alexandria, VA 22314
January 2016
Federally Insured Credit Unions
Supervisory Priorities for 2016
Page Content

Dear Board of Directors and Chief Executive Officer:
     This letter is intended to assist you in preparing for your next NCUA examination.  NCUA field staff will continue to use the streamlined small credit union exam program procedures for credit unions with assets up to $50 million and CAMEL ratings of 1, 2, or 3.  For all other credit unions, field staff will conduct risk-focused examinations, which concentrate on the areas of highest risk, new products and services, and compliance with federal regulations.
     Below are NCUA’s top areas of supervisory focus that are broadly applicable for credit unions in 2016.

Cybersecurity Assessment
     Cybersecurity threats continue to represent significant potential operational risks to financial institutions.  Cyberattacks are expected to increase in frequency and severity as worldwide interconnectedness grows and the capabilities to conduct cyberattacks become more sophisticated and easier for criminals or terrorists to obtain.  As in 2014 and 2015, NCUA will continue to carefully evaluate credit unions’ cybersecurity risk management.  
     In June 2015, NCUA released a Cybersecurity Assessment Tool jointly with the other member agencies of the Federal Financial Institutions Examination Council (FFIEC).  The tool provides a structured methodology for credit unions to manage information security and protect member information more effectively. 
The tool is designed to enhance cybersecurity oversight and management capabilities, and to identify any gaps in an institution’s risk-management practices.  Credit unions can use this tool to enhance their cybersecurity preparedness. 
     NCUA encourages all credit unions to use the FFIEC tool to manage cybersecurity risks.  NCUA also plans to begin incorporating the Cybersecurity Assessment Tool into our examination process in the second half of 2016.
     Throughout 2016, NCUA will continue to foster and facilitate sharing of best practices to strengthen credit unions’ existing cybersecurity programs.  For additional cybersecurity resources, please visit the Cybersecurity Resources Page on NCUA’s website.

Response Programs for Unauthorized Access to Member Information
     Incident response procedures are a key part of a credit union’s information security program.  In 2016 examinations, NCUA field staff will be reviewing credit unions’ incident response programs. 
     Appendix B to Part 748 of NCUA rules and regulations, Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice, outlines the minimum components of an incident response program that federally insured credit unions need to develop and implement.  An incident response program is needed to address unauthorized access to, or use of, member information that could result in substantial harm or inconvenience to a member. 

Bank Secrecy Act Compliance
NCUA remains vigilant in ensuring the credit union system is not used to launder money or finance criminal or terrorist activity.  All federally insured credit unions must perform certain recordkeeping and meet reporting requirements to detect this type of activity as required by the Bank Secrecy Act.  
     NCUA field staff are required to review credit unions’ compliance with the Bank Secrecy Act and to complete the related examination questionnaire at every examination.  In 2016, NCUA field staff will focus on credit unions’ relationships with money services businesses, also known as MSBs. 
     Credit unions can provide services to an MSB while meeting BSA requirements, but should be aware of the unique risk exposure MSBs can present and the corresponding need for commensurate expertise and monitoring systems.  In 2014, NCUA issued guidance to field staff and credit unions on Identifying and Mitigating Risks of Money Service Businesses.  The guidance describes the steps credit unions should take to mitigate any money-laundering risks posed by MSBs.
     If your credit union provides services to an MSB, field staff will verify that you meet the following minimum expectations established by NCUA and federal banking agencies:
  • Perform customer identification program procedures;
  • Ensure each MSB is registered with the Financial Crimes Enforcement Network (FinCEN) and is in compliance with state and local licensing requirements; and
  • Conduct a BSA/anti-money laundering risk assessment to document the level of risk associated with each MSB account and determine whether greater due diligence is necessary.
For compliance information and additional resources, see the Bank Secrecy Act page on NCUA’s website.

Interest Rate Risk
     Interest rate risk (IRR) remains a key supervisory focus as interest rates have begun to rise.  Rising rates may prove challenging for those credit unions that hold high concentrations of long-term assets funded with short-term liabilities.
     NCUA is in the process of updating interest rate risk management supervisory guidance, which will be published in 2016.  As part of this effort, NCUA field staff will transition to the updated IRR examination procedures over the course of 2016.  The new procedures will improve the efficiency of reviews by focusing field staff resources on those credit unions with elevated levels of IRR and streamlining related exam procedures.
     Field staff will receive specialized training on evaluating IRR at the national exam program training in April 2016 and throughout the remainder of the year during regularly scheduled group meetings and other customary training venues.  Field staff will evaluate credit unions’ compliance with NCUA’s interest rate risk rule, which requires federally insured credit unions with more than $50 million in assets to develop and adopt a written policy on IRR management, and establish a program to identify, measure, monitor, and control IRR.  
Credit union officials should be prepared to provide NCUA field staff with documentation supporting the credit union’s ability to successfully manage their IRR through changing market conditions, including rising rate environments.
     For the IRR rule and guidance, see 12 CFR Part 741, Requirements for Insurance and Appendix B to Part 741, Guidance for an Interest Rate Risk Policy and an Effective Program.

TILA-RESPA Integrated Disclosure Rule
     Credit unions that have accepted applications for real estate loans on or after October 3, 2015 (except for home equity lines of credit, reverse mortgages, and commercial loans) are required to comply with the TILA-RESPA integrated disclosure rule, which the Consumer Financial Protection Bureau adopted to help consumers better understand mortgage transactions.1 
The CFPB rule requires loan originators to provide consumers with two disclosures: 

Loan Estimate Disclosure – Combines the Truth in Lending Act disclosure and the Good Faith Estimate.  The loan estimate disclosure must be delivered or placed in the mail no later than the third business day after receiving a consumer’s mortgage application. 

Closing Disclosure – Combines the final TILA disclosure and the HUD-1 Settlement Statement.  The closing disclosure must be provided to the consumer at least three business days before the consummation of a mortgage.
     The TILA-RESPA integrated disclosure rule also imposes record retention requirements and restricts mortgage originators from imposing certain fees, providing estimates, or requiring consumers to verify information before providing a loan estimate to a consumer.  Field staff will be reviewing credit unions’ compliance with the relevant provisions.
For additional information, please visit the Consumer Compliance Regulatory Resources page on NCUA’s website.

CUSO Reporting
     Regulatory requirements associated with NCUA’s CUSO rule became effective June 30, 2014.2  One of the primary changes to the rule requires all federally insured credit unions that invest in or lend to a CUSO to enter into a written agreement requiring the CUSO to submit annual reports directly to NCUA and the state supervisory authority, if applicable.
     CUSOs will start providing their annual reports through the CUSO Registry in 2016.3  Once the deadline for CUSOs to register with NCUA has passed, field staff will check to ensure any CUSO a credit union has loaned to or invested in has registered with NCUA.  
More information on the CUSO Registry is forthcoming in a separate Letter to Federally Insured Credit Unions.

     NCUA remains committed to protecting the safety and soundness of America’s federally insured credit unions and their more than 102 million members.  Our examiners worked successfully with thousands of credit unions in 2015 to significantly reduce losses to the National Credit Union Share Insurance Fund.
Signature SC


Debbie Matz

Wednesday, January 13, 2016

Firefighters First Credit Union gives back over $1.6 Million to firefighters and their families.

Firefighters First Credit Union gives back over $1.6 Million
to firefighters and their families.

In the fire service, firefighters have an unconditional trust with each other. Similarly, firefighters trust this organization and have done so since its inception in 1935. Firefighters First was established during a time of financial need when firefighters pooled their funds together to help make ends meet. This commitment remains today and is demonstrated through strong financial management and keeping the best interests of our Fire Family in mind.

That’s why we return our profits directly back to our members in the form of Extraordinary Dividend Bonuses and Interest Refunds. With this year’s $1.6 Million payout, it brings the total amount we have paid back to our members to over $42 Million in the past 30 years.

“Extraordinary Dividend Bonuses and Interest Refunds are unique benefits of Credit Unions, and many have stopped them altogether. But at the discretion of our Board of Directors, we feel it is an important part of our tradition. Members agree. Payouts vary based on member relationships, but it’s not uncommon to see payouts of over $5,000,” explained Mike Mastro, Firefighters First CU President/CEO.

Payouts represent a rebate on the interest paid on loan accounts and a bonus dividend on the earnings on savings accounts.

What this means to members…
·         If you had $100,000 in a share certificate and it earned a 1.00% yield, or $1,000, based on the 2015 Extraordinary Dividend Bonus you received an extra $150.

·         If you paid $4,000 in interest for the year on a loan with us, based on the 2015 Interest Refund, you received a refund of $100.

In addition, we rewarded members with a bonus payout who leveraged additional services available through the Credit Union. Members who maintained an investment account, business account, insurance policy through Firefighter Insurance Services, or had a mortgage servicing loan, received an extra $30 for each of these services.

Payouts were posted on December 31, 2015, and varied on individual financial relationships; proving one thing – the more members bring to Firefighters First Credit Union, the more they receive in return!

To learn more about our 2015 Extraordinary Dividend Bonus and Interest Refund, please visit

Tuesday, January 12, 2016

Boston Firefighters CU Offers A+ credit rates on auto loans and personal consolidation loans to veterans

Looking into the credit profiles of the many veterans who were recently appointed to the Boston Fire Department, our credit union team we saw a common thread among many: bad credit and resulting high interest rates on loans. Several of these young men and women, who volunteered to fight for our freedom, had fallen into a pattern that negatively affected their credit scores. Low pay rates and creditors that prey on young servicemen and women while they are stateside are just two of the reasons many get into this situation. The problems are often compounded during deployments when bills and credit obligations are not the main priority (for obvious reasons). As a result, many of our brave troops return home with challenged credit, which leads to high interest rates on credit cards, personal loans, and auto loans and makes home ownership a virtual impossibility.

Boston Firefighters Credit Union answered this challenge by offering veterans A+ credit rates on auto loans (1.99 percent) and personal consolidation loans (7.99 percent). These loans are accompanied by credit counseling and plans to place borrowers on a path to home ownership. Most of our veteran members now have good-paying jobs as firefighters or police officers. However, debt consolidation would be far more difficult without the opportunity to borrow at low rates and the chance that they so richly deserve. At BFCU, this program is our way of saying thank you for the sacrifices these veterans have made.

Thursday, January 7, 2016

Dan Berger: Dodd-Frank is 'death by a thousand cuts' for small lenders

Dan Berger CEO NAFCU will b speaking at our 2016 Conference in Denver and I found this interview with him very interesting and thought I would pass it on.

In December, the Government Accountability Office (GAO) issued a report on the impact of the Dodd-Frank Wall Street Reform and Consumer Protection Act regulations on community banks and credit unions. While cautioning that it was too early to gauge the full impact of new rules, the GAO said surveys suggest the regulations have caused only “moderate to minimal initial reductions” in credit availability, adding that the data doesn't confirm a negative impact on mortgage lending. B. Dan Berger, president and chief executive officer of the National Association of Federal Credit Unions (NAFCU), said  the GAO report has greatly underestimated the burden of new rules on smaller institutions. He spoke with Scotsman Guide News about NAFCU's legislative agenda, and the prospects for regulatory relief and housing finance reform in 2016.

What is the place of credit unions in the mortgage market?

Dan BergerWe have the fastest growing mortgage portfolio of all the financial institutions. We are a not-for-profit financial institution, so we don’t have a profit motive like some others do, with shareholders and dealing with Wall Street analysts. We can be in communities. We can be employer-based. We are all across the country. My trade organization represents every state as well as the territories. Credit unions are absolutely everywhere, providing not just mortgages but credit cards. Some do business lending. There is a big financial education component with credit unions. We cover the gamut. 

Could you talk about how Dodd-Frank regulations have affected credit unions?

It is hard to pinpoint any specific mortgage [regulation] or any rules that have been promulgated by the Consumer Financial Protection Bureau (CFPB) or the National Credit Union Administration (NCUA). It is death by a thousand cuts. When Dodd-Frank came out, they were trying to address — and rightfully so — a problem with predatory lenders and the bad actors out there. You had some of the subprime lenders that were taking advantage of folks, payday lenders that were taking advantage of folks, and going after some of the people who were committing fraud on Wall Street with the bonds they were bundling and securitizing and selling. Community-based financial institutions didn’t cause the financial crisis. We didn’t do any of that subprime junk. We didn't do any of that fraudulent bundling. When they created the CFPB, they created an extremely powerful agency that is not accountable to anybody. They are promulgating rules where they may want to target large financial institutions, Wall Street banks, etc., but there is mission creep. Any rule that gets promulgated, no matter what your asset size, it affects you. It is just a costly financial burden. 

Why do you say that burden has been greater on smaller institutions?   

Those costs include systems and infrastructure changes, software changes, document changes. All that stuff costs money. If you are a multibillion-dollar, in some cases, a trillion-dollar financial institution, you can afford those kinds of changes. Each time there is a change or an upgrade that goes on, that is a lot of money [for] a $50 million dollar financial institution. They are living on very thin margins to keep the lights on. 

What are some changes that you would like to see?

We really wish that the CFPB would utilize [an exemption clause in Dodd-Frank]. They have an ability to exempt folks as necessary from various regulations. Credit unions and community banks shouldn’t even be part of some of these rules. We would like to see things along the lines of a commission [to oversee the CFPB] instead of a single director. I think [if the CFPB] was part of the appropriations process, it would be helpful. Again, it is more targeting the bad actors as opposed to a huge brush that affects everybody. 

Changing the subject a bit. There was a flurry of debate late last year over the prolonged conservatorship of the government-sponsored enterprises Fannie Mae and Freddie Mac? Does NAFCU have a position on the future role of Fannie and Freddie?

We need liquidity if we want to make new loans. [Credit unions] sell loans to Fannie and Freddie, so having access to the secondary market is extremely important to credit unions. They have to have access to it for liquidity purposes, for interest-rate management purposes. From a credit union standpoint, it is extremely important that there are GSEs out there, or at least a GSE out there that has a government guarantee, to continue to provide liquidity to the system. 

Do you expect any meaningful reforms or regulatory relief this year?

I don’t see anything on the horizon for GSEs. Being a presidential election year with the Senate in the balance, I think it is going to be really difficult for anything like that to happen. Fannie and Freddie will probably be OK this year. There are just so many stakeholders involved in housing finance that it makes it extremely difficult to get a large section of the stakeholders on board in order to make any reforms. I don’t think anything will happen this year, but I would be surprised if it is not approached aggressively in 2017. Other regulatory reforms, whether it is the CFPB or [NCUA], we have a small window. We are hopeful. We are pushing every day. My lobbyists on the Hill are working to try to get some things moving, but the trouble is that it is an election year, so there is a shortened calendar. The members of Congress have a lot of important things that need to get done before they have to go out and shake hands and kiss babies.