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COLORADO’S CREDIT UNIONS
R E P OR T B Y MA R V I N UMHO L T Z
Colorado’s Largest Credit Unions:Where rhetoric meets
reality and why credit unions must relinquish their unmerited
perquisites and prerogatives
P RODU C E D I N P A R T N E R S H I P
EXECUTIVE SUMMARY
Large multi-branch, full-service Colorado
credit unions have grown to be mainstream
federally insured depository institutions
that are indistinguishable from commercial
banks either by the products they provide,
or by whom they serve. Aside from their
tax-subsidized operations and separate
regulatory treatment, bank-like credit unions
are a significant competitive force in the
Colorado financial services marketplace.
Unlike some credit unions, which remain
committed to the traditional model of
serving a specific class of members
(customers), Colorado’s largest credit unions
no longer focus on employees of a particular
business, industry sector, or income level.
Despite statutes supposedly restricting
these credit unions to members who are in
their field of membership (FOM), they are
essentially available to anybody in the state,
regardless of where they work or how much
money they make.
KEY HIGHLIGHTS
Colorado credit unions don’t want
customers that share a common bond; they
want your customers. All of them.
•Nearly every Colorado citizen is eligible
to join one or more of Colorado’s 86 credit
unions headquartered in the state – and
many for out-of-state institutions
•Colorado-headquartered credit unions’
CBA STAFF
DON CHILDEARS
President/CEO
JENIFER WALLER
Senior Vice President
AMANDA AVERCH
Director of Communication
MIKE BINTNER
Director of Membership
LINDSAY MUNIZ
Executive Assistant
don@coloradobankers.org
jenifer@coloradobankers.org
averch@coloradobankers.org
mike@coloradobankers.org
lindsay@coloradobankers.org

usiness lending had tripled between yearend
2004 and year-end 2014
•The 86 Colorado-headquartered credit
unions’ assets nearly tripled in the two
decades from 1994 to 2014
Colorado’s credit unions are not focused on
low-income borrowers.
•92 percent of credit unions made no
mortgage loans to low-income Colorado
borrowers
•Of all the 2013 Home Mortgage Disclosure
Act-reported mortgages originated by
credit unions in Colorado, 3.3% were made
to lower-income borrowers, 17% were made
to moderate-income borrowers, 41.9% were
made to middle-income borrowers, and 37.7%
were made to upper-income borrowers
•The wide-open fields of membership (FOM)
as well as the highly-desirable upscale
commercial locations of their main offices
and of their branches, suggest the largest
Colorado credit unions have targeted
communities of moderate-income to upperincome
residents as desired members
(customers)
•The seven largest Colorado-headquartered
credit unions did over 75% of the business
lending done by all credit unions in 2014.
Over 92% of those 2014 business loans made
by the largest credit unions were for owner
occupied or non-owner occupied commercial
real estate (CRE)
Credit unions play by their own rules – and
their regulator supports them ignoring
Federal law
•CU regulators too often act as advocates for
tax exemptions and special treatment
•Colorado’s largest credit unions cannot
prove to be Community Reinvestment Act
compliant
•NCUA was under Congressional scrutiny in
2015 for lack of transparency
•In February, NCUA ignored Congressional
limits and finalized looser MBL limits
Colorado’s largest credit unions are like
banks in nearly every way – they just don’t
pay like them
•The customer products and services offered
by Colorado credit unions are very similar
to those offered by Colorado’s banks. The
larger the credit union, the more likely it
is to offer many bank-like products and
services.
•All 86 Colorado-headquartered credit unions
it would have an estimated tax obligation of
up to $64 million.
QUESTIONS? PLEASE CONTACT US TODAY.
Colorado Bankers Association
One Sherman Place, 140 East 19th Avenue, Suite 400, Denver, CO 80203
P 303.825.1575 | info@coloradobankers.org