Wizard, so do you accept that the requirement that an officer have responsibility for compliance is reasonable? You seemed pretty adamant earlier that this was an oppressive requirement for organisations handling millions or tens of millions of the publics savings.
Thanks for the clarification. So your big idea is that CUs be allowed issue shares separately to savings and presumably pay the shareholders profits? This would be a complete departure from the current structure/ethos - I don't think it would be appropriate to call such an institution a credit union. And I fail to see how this would have saved the high profile CU collapses we've seen.
Regarding your objections to the reserve requirements, what level do you think would be appropriate? And would this level have saved this or other failed CUs? 10% does not seem onerous to me. Some counties are insisting on higher ratios than this for large retail banks.