We’ll explain those numbers in more detail in the Aug. 29 webinar, but in short, in its own version of voodoo economics, the NCUA staff argues that the NCUSIF is taking on more risk by absorbing the assets and liabilities of the TCCUSF.

Just being prudent, the staff argues. But it’s using the same modeling that resulted in billions of unnecessary premiums and excess reserves in the corporate bailout fund.

One example: the regulator is assuming that a moderate recession would cause the NCUSIF to suffer insurance losses over the next five years that would exceed the losses the share fund saw from bailing out natural-person credit unions in the past nine years, including during the banking crisis of the Great Recession.

In other words, there’s no connection to what the regulator is charging for anticipated losses to the fund and what’s really happening.

If a credit union did this kind of modeling in its own loan loss reserves, there’s not a CPA in the country that would approve those statements.

This also is the agency that touts its success in winning back $4.3 billion so far from the Wall Street bankers who sold the corporate credit unions the toxic securities that caused this whole mess. The problem here is two-fold: 1) those investments were made under the watchful eye of NCUA examiners, including in some cases examiners stationed in-house; 2) the NCUA’s expenditure of a billion dollars in legal fees was deemed so excessive as to catch congressional attention.

We have until Sept. 5 to tell the NCUA why we think the merger is a good idea but raising the Normal Operating Level isn’t.

Please attend the Aug. 29 webinar to learn more about how an ethical, responsible merger of these two funds could return the NCUSIF to its original intent: ensuring a safe harbor for credit union members’ capital as the backbone of a thriving, relevant cooperative financial services movement.

And then, make your opinions known.