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Credit Union and Cooperative Patronage Refunds - Filene ...

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on share deposits is not a patronage refund, because it is paid on the<br />

basis of investment in Wright-Patt in contrast to use based on borrowings<br />

from the credit union.<br />

This is not to criticize Wright-Patt’s program but only to highlight<br />

that in a report about patronage refunds, we must pay attention to<br />

whether the payment was made on a patronage basis or the member’s<br />

use of the credit union. In fact, Wright-Patt’s program highlights<br />

the advantage of paying patronage refunds under 501(c)(14) rather<br />

than, for example, Subchapter T. Under 501(c)(14), Wright-Patt is<br />

allowed to be more creative in how it distributes its patronage payments<br />

to members. Subchapter T would force a far narrower concept<br />

of patronage on Wright-Patt because a patronage tax deduction is<br />

allowed only for payments made on the basis of each member’s proportional<br />

use of Wright-Patt.<br />

Mislansky says that patronage refunds are a differentiator that distinguishes<br />

Wright-Patt from IOF banks that compete in the credit<br />

union’s market. Mislansky says that Wright-Patt’s membership grows<br />

substantially each year after its patronage refunds are announced <strong>and</strong><br />

paid. The idea that patronage refunds are a differentiator resonates<br />

with us, but on more levels than just whether patronage refunds are<br />

good ideas as rebates. As we said earlier, we believe that patronage<br />

refunds highlight the philosophical gulf that separates co-ops from<br />

IOFs.<br />

48

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