Some credit union leaders assume the NCUA is either an adversary or an oracle. In reality, it’s an agency full of people paying attention—especially when feedback is specific and solutions-focused.
In this episode of Grow Your Credit Union, host Joshua Barclay and co-host Becky Reed are joined by guest Elizabeth Eurgubian, former Director of External Affairs and Policy Advisor to the chair of the NCUA to discuss what recent leadership shakeups at the agency really mean, how to make your voice heard in the regulatory process, and why this is the perfect time to reimagine how credit unions and regulators work together.
How to Make the NCUA Listen
For many credit union leaders, the NCUA can feel like a black box, especially when it comes to proposed rules and shifting priorities. But Elizabeth Eurgubian wants you to know it’s not as opaque as it seems.
She reveals that top officials, including Chairman Harper, actually read every comment letter, and the ones that resonate offer specific, constructive suggestions. “Don’t just say you hate the rule. Propose a solution,” she says. You don’t need to write a thesis. If one part of a rule stands out, speak to that and defer the rest to your trade group.
Becky reflects on her own advocacy evolution, from sending pre-written letters to actively engaging the board through her CUSO leadership. The takeaway? The NCUA is listening. You just need to be strategic, clear, and solution-oriented.
Gospel or Gossip?
Some leaders treat agency statements like gospel. Others ignore them altogether. But there’s a smarter way to interpret the regulator—and stay a step ahead.
Elizabeth recommends a proactive playbook: check NCUA.gov weekly, monitor press releases, read supervisory highlights like a test prep guide, and pay close attention to speeches. “They can’t tell you directly, but they’re telling you in code,” she explains. If a chair shifts their language, there’s usually a deeper reason.
Becky cautions against letting fear take over. She recalls the panic after the NCUA board shakeup and urges credit union leaders to focus on what they can control. Exams are still happening, the agency is still functioning, and smart leaders will continue to plan accordingly.
From Both Sides of the Aisle: Reimagining the Regulator
Having worked at both CUNA and the NCUA, Elizabeth brings a unique lens to what’s working and what’s not. And from her perspective, the recent staffing changes present an opening.
She warns that the agency’s shrinking headcount could put the Share Insurance Fund and overall oversight at risk if left unaddressed. But she also sees opportunity. Credit unions should push for a regulator that embraces technology, understands innovation, and evolves with the industry.
Becky doubles down, saying it’s time to stop thinking scale is the only path to tech adoption. “Speed is the new scale,” she argues. Smaller credit unions can be more nimble, implement fintech faster, and shape a future where partnership—not fear—defines the relationship with the regulator.
Top Takeaways from This Episode
- The NCUA reads your comment letters. Be brief, specific, and propose real solutions.
- One-person board quorums are legally murky, but operations continue thanks to delegated authority.
- Supervisory highlights and public speeches can help you read between the lines.
- Now is the time to reimagine your relationship with the regulator. Don’t wait.
- Small credit unions have an agility advantage. Speed, not size, is the future.
Contribute to the Conversation
Have a challenge, question, or topic you’d like us to cover? Whether it’s a merger dilemma, a lending roadblock, or something your board is wrestling with, we’d love to hear from you. Reach out on LinkedIn or email us at info@growyourcreditunion.com.
Full transcript
[Joshua Barclay] With recent shakeups at the NCUA, many of you have told us the future feels uncertain and maybe even a little scary. That’s why we invited onto the show, the former Director of External Affairs and Policy Advisor to the chair of the NCUA. She’s here to pull back the curtain on the NCUA, give you clarity, answers, and the confidence to navigate what’s ahead.
Let’s start the show. Welcome to Grow Your Credit Union, the podcast where credit union leaders gather, learn, and grow. I am your host Joshua Barclay, and with me is my co-host Becky Reed. Becky, what’s up?
[Becky Reed] Howdy y’all.
[Joshua Barclay] Becky, I just got back from a really, really nice hiking trip. And what’s dawned on me is I’ve never asked you what you like to do outside of work. I feel like you’re always traveling, you’re always doing something credit union-related and I have no idea if you’re a robot, if you actually spend your time doing something else.
Talk to me about your hobbies that are not credit union-related.
[Becky Reed] Well, I work probably 99% of the time, but when I’m not working, my husband and I actually like to go RV-ing, go camping. So we have a fifth wheel and we travel to state parks mostly. And sometimes we do go hiking, Josh.
[Joshua Barclay] What is your favorite state park?
[Becky Reed] Well, there are several. Any with a lake. As long as there’s a lake in the state park, then we love it.
[Joshua Barclay] Okay, Becky, I’ll let you slide on that one. Nondescript. Okay. Yeah, that’s fair. A lake can work. Alright, Becky, this is a pretty special episode. We’ve never done anything quite like this one. So today we welcome the former Director of External Affairs and Policy Advisor to the chair of the NCUA, Elizabeth Eurgubian. Elizabeth, welcome to the show.
[Elizabeth Eurgubian] It’s a pleasure to be here with you today.
[Joshua Barclay] For many credit union leaders, the NCUA can feel a little bit like a black box, especially when it comes to interpreting policy shifts or exam priorities. So Elizabeth, as the former Director of External Affairs, you saw how advocacy truly moves the needle inside the agency.
So what I’m wondering is, what should credit union leaders understand about how the NCUA actually responds to advocacy efforts?
[Elizabeth Eurgubian] Yeah, thanks. It’s a great question. A lot of times you get clues on the direction the agency’s gonna go. It almost always starts with the chair and the first several speeches a chair will give. They usually have three issues or three main things they wanna concentrate on during their tenure. You see it with Chairman Hauptman, where it’s de novo credit unions, AI, tech issues, some of those issues, and you saw the issues that former chairman Harper always spoke about: consumer protection, cybersecurity. So you kind of get the tone of where it’s going.
But then you do have times where there’s rulemakings that come out. Right now we’re in a bit of a pause on some of that, but there’s an opportunity for credit unions to participate in the process.
A couple things folks may not know that I discovered working there, ’cause I used to lobby the NCUA too. First of all, they do read the comment letters. They actually do read the comment letters up to the very top. Chairman Harper read every comment letter when I was there. It really helps in those types of feedback to limit hyperbole.
You don’t have to repeat that the credit union movement is the greatest thing since sliced bread. Everyone there is on board with that. But actually be as constructive as possible and provide possible solutions to any issues you see. Calling out an issue, saying, “Thank you for the rulemaking. This is the issue we’re finding that’s a problem.
Here’s how we think you could correct it.” Or, “This is an issue that you didn’t address in the proposed rule. You probably should address it because this is the issue it would solve.” Constructive, almost like a math problem. That’s the best feedback that resonates with the agency, and I would encourage credit unions to do that, both in their meetings with the higher-ups at the NCUA and also in their letters, because that’s what’s gonna resonate most.
[Joshua Barclay] Okay, so good news. The NCUA is listening. That’s number one, a really good thing.
[Elizabeth Eurgubian] They read everything. I’ll give you an example. I would say to Chairman Harper, “Hey, this one credit union raised a really interesting point we hadn’t thought about on X,” and he’s like, “Yes, the blah, blah, blah Credit Union. I know who that is.
That was a really good point.” That shows he’s reading everything. It’s not just him. Everyone really reads these things, so the more constructive, the better.
[Joshua Barclay] Becky, what is your experience when it comes to advocacy or lobbying? Have you taken part in advocacy activities, this type of game? Talk to me about it.
[Becky Reed] I wouldn’t say heavy, but as the board chairman and a board member of CUSO, the National Association of CUSOs, we engage regularly with the board at NCUA on a variety of topics because what affects credit unions definitely affects CUSOs and vice versa because credit unions own CUSOs.
So we have had many conversations. Of course, most of them happen at the GAC, and I would say that once I started engaging with the board at NCUA at that level, I was honestly surprised that they were as open as they were to hearing feedback from credit union folks and even to the point of seeking it out. Before, probably my advocacy efforts were limited to the response that she’s talking about, the feedback when they have rules that they want people to respond to.
The leagues and so forth would kind of send out form letters, say here, talk to your congressman, talk to the NCUA, send this information out based on talking points they wanted supported. Sometimes I just used those form letters.
I’m like, “Yeah, I agree with the league. Go ahead and send it.” But Elizabeth’s comment around the form letter probably not being the best way to communicate with the NCUA—it’s actually really refreshing to hear that they read those things because a lot of times you feel like they’ll go into a black hole.
[Elizabeth Eurgubian] Yeah, and that raises a very good point because some entities think they gotta write a book report. Like, “I gotta read this whole proposed notice and comment. I just don’t have the bandwidth to do that. I’m gonna let the trade association do it for me.” You don’t have to do a book report.
You could look at this thing for 5, 10, 15 minutes. If something pops out at you, put that issue in the letter and say, “Look, this issue popped out at us for these reasons. We want you to address it for these reasons, and here’s a solution.”
Then say, “We defer to the trade association on all other points,” and that’s how you get it in. So you still get that point in that you’re experiencing with the proposed rule without having to do a full analysis, which isn’t expected.
[Becky Reed] Well, and proposing a solution—I don’t think that I really thought about that. You can say, “Here’s the issue that I don’t like or disagree with,” but recommending a solution, I think that’s a novel approach.
[Elizabeth Eurgubian] Yep. Do the thinking for them. The more you can help with the thinking, the better.
[Joshua Barclay] When the NCUA releases public statements, I notice some credit union leaders treat them like gospel, and some tune them out altogether. But I’m hoping there’s a smarter, more strategic way to read between the lines and prepare for what’s coming. Elizabeth, please help us here.
How should credit unions interpret NCUA communication so they can stay ahead of potential regulatory shifts?
[Elizabeth Eurgubian] Great question. Things you’re gonna care about most as a credit union are regulatory changes because that’s gonna impact your day-to-day, and supervisory changes for examinations. I always encourage folks to go to the website as much as possible. NCUA has gotten acknowledgment for being really good with their website.
When I was there, we won recognition compared to other financial regulators. It’s very easy to navigate. Visit it at least once a week to look at updates, press releases, letters to credit unions, and sign up for email updates to see those in real-time. Look at the semi-annual regulatory agenda when it comes out, and supervisory highlights—they usually come out in January.
Here’s the trick: supervisory highlights are like when your teacher says, “This is what’s gonna be on the test.” Study that stuff. Really take a look at that document.
Also, speeches—when the chair makes a speech, see where their mind is and their priorities. I’ve heard Chairman Hauptman’s statements. If Chairman Hauptman suddenly started talking more about cybersecurity, extra diligence, that would tell me he’s been briefed on a national security issue and knows information the industry doesn’t.
They can’t directly tell you that because they have security clearances. I had a top-secret clearance when I was there, and I’d get nervous after those briefings. I’d make sure Chairman Harper had certain statements in his speeches.
Those statements aren’t arbitrary—they’re intentional communications to the industry about threats from other countries. Take that seriously.
[Joshua Barclay] Becky, that’s a very rational answer, but there’s a lot of chatter that’s emotional. I’m not expecting you to be the NCUA whisperer, but when you hear this noise—controversy and emotion stirred up—how are you interpreting it? Is it going in one ear and out the other, or are you taking it seriously?
[Becky Reed] Initially, after the terminations of two board members at NCUA—which happened at other agencies under the Trump administration, NCUA wasn’t unique—of course, Harper and Hood are suing the administration for wrongful termination, joining other agencies as well. Initially, what I heard was an outcry that we’re doomed, credit unions are gonna die, NCUA’s gonna merge into FDIC, and the sky is falling.
Josh, we talked about this the day it happened at the CUSO conference. We had our live podcast the next day, and people were still reeling. Guess what? The agency is still running. Yes, we have a single board member constituted as a quorum. Whether you agree or not, that’s how things are running. Elizabeth is right—probably not a ton of rulemaking happening, but the agency is running just fine.
Some people’s exams got canceled or postponed due to staffing shifts; this is just how things are across industries. We need to run our credit unions. We’re gonna have exams just like before. Work with your examiner, do things you’d always do. Just another day.
[Elizabeth Eurgubian] Absolutely control what you can control. Let them do them. You control what you can: read supervisory highlights, get ready for your exam, comment on rules you care about, and run your credit union. Help your members, and let them handle the administrative stuff. It’ll work itself out.
[Becky Reed] Amen.
[Joshua Barclay] That’s great advice. But Elizabeth, I do have to ask you ’cause it’s kind of juicy. It would be disappointing if I didn’t ask what your point of view is or your interpretation of the NCUA terminations, the board members in particular, because I’ve heard it from everyone’s perspective, but with your insider point of view, how did you interpret that? Did you take it as a sky-is-falling moment, or give me your sense of this.
[Elizabeth Eurgubian] No, I don’t take it as a sky-is-falling moment. I don’t agree with the interpretation. In reading the statute—I’m an attorney too—it’s up to a judge to ultimately decide. I don’t think the way the statute is written that one person is a quorum. The intent of the statute really highlights that you need three members, only one can be from the credit union industry, they’re staggered terms, only two could be from the same political party.
If the drafters were okay with a one-person quorum, they wouldn’t have gone through all these criteria for what a three-member board and two-member quorum would be. As an attorney looking at this, the other two members are not like backup dancers. They’re supposed to be a three-member board with a two-member quorum.
There’s a reason for that. Now, there’s an interpretation right now that this is okay, and we’ll see—a judge will decide that, and ultimately that’ll be the decision. But it’s not my reading of the statute.
Do I think the sky is falling? No. There’s a lot of delegated authorities. The nice thing about the NCUA is it’s an agency that delegates many authorities out to the directors. Even getting new charters, you can get that from the CURE office; it only becomes an issue if it’s appealed, and that would then go to a board.
There are many authorities delegated at the director level that keep the agency running. So I would just, again, do what you do daily—run your operation, follow directions, cross all your T’s, dot all your I’s, and let them sort out the administrative stuff. You don’t need to worry about that; it’ll work itself out.
[Joshua Barclay] Elizabeth, you have a really interesting perspective having worked at both CUNA and the NCUA. You’ve been on many different sides of the coin. Let’s tap into that so we can understand the pressures facing the credit union movement today.
From where you sit, what’s the current state of the industry and what should credit union leaders be paying close attention to?
[Elizabeth Eurgubian] Now, I’m gonna caveat a little bit what I just said because I agree that the agency is running as usual. You’ve got one board member running things, a lot of delegated authorities. Eventually, that’s gonna work itself out, knock on wood. However, one concern I have is an industry that’s set up to succeed, and you kind of need your regulator for that. The staffing cuts concern me a little bit.
I know at the recent board meeting, they said it’s maybe cuts of under 20% that have taken buyouts. The NCUA is going from over 1200 FTEs to something like under 1000, and many of those are in the central office. One thing I’d comment on is we want the agency set up for success because if they’re not, that’s a threat to the industry and the Share Insurance Fund, which most credit unions pay into.
I would push that they be set up to protect the credit union industry well.
In terms of credit unions in the future, they’re at a crossroads. There’s lots of changes happening—not just legislative and regulatory—but with technology, rapid development, competitors, mergers, credit unions getting larger, more centralized, maybe not as community-based, but still wanting to maintain that identity.
Credit unions need to have a come-to-Jesus moment and say internally, “What are we trying to accomplish? Let’s make a list—1, 2, 3, 4—these are the goals we’re trying to accomplish.” The environment is gonna be what it is. You may fail, you may not be here in five years, whatever, but figure out the best strategies to accomplish those goals and effectively serve your members and community.
Whatever ends up happening, at least you have a game plan to work from, and you can pivot based on the environment. Don’t just react—that leads to lack of focus, which is dangerous for your credit union and the financial industry overall.
[Joshua Barclay] So it’s getting back to your roots. Essentially, know who you’re there to serve, what you’re there to do for them. We’re coming back to the fundamentals, as you say, Elizabeth, being proactive, not reactive. Becky, if you had to piggyback onto what Elizabeth said, what could you share in terms of pressing issues? How do we have our come-to-Jesus moment, as Elizabeth said?
[Becky Reed] I have two, and I’ve written about them both. One is that this is a really opportune time for us to reimagine how NCUA supports credit unions. There isn’t a better time to rethink or reorganize how NCUA works with credit unions than now when disruption is already happening. Some of the people taking buyouts may have been barriers to needed changes.
Elizabeth is right—technology is advancing. NCUA should embrace new technologies available because there’s lots of data from the call report, and AI is a perfect opportunity to mine and analyze that data to provide greater insights quicker than any examiner can today. NCUA should double down on utilizing technology and the tech credit unions are implementing. For example, no one at NCUA is able to buy or sell cryptocurrency—that’s silly.
The Stablecoin Genius Act just came out in the House; that’s gonna become law. Our regulators don’t have an opportunity to interact with it? That’s silly. As an industry, we need to say we want our regulator to be a partner with us, not adversarial. Let’s work together.
Second thing: I believe speed is the new scale. Everyone in the credit union space and banking too is looking at getting bigger. There’s all this consolidation because we think we can’t afford technology without being giant. That is no longer true. To double down on our roots and serve our communities effectively, smaller, more nimble financial institutions are probably better. Small credit unions can make decisions quicker and enable FinTech faster than big ones. That’s how we win.
[Joshua Barclay] To double down on your point, Becky, very profound—you don’t need to be big to be technologically savvy or innovative quickly. As I’ve mentioned several times on the show, people are probably sick of hearing it, but the hackathon with three students—fueled by Red Bull and pizza, living on their parents’ bank accounts—they developed amazing tech in 30 hours. You can do it as a $200 million, $100 million, or even a $50 million credit union. It’s possible.
Especially now with AI tools—I read something last night, some AI companies have revenue per employee around $1.6 million. You’ll see giant companies with five people. So the notion that we have to be large to scale technology is not true. Becky, Elizabeth had a bomb point, and you threw another grenade on top—kudos to you.
Final thoughts, Elizabeth—based on our conversation today, what would you like to impart to our listeners?
[Elizabeth Eurgubian] I think Becky made great points, and I really agree we should look at this as an opportunity. Figure out clearly what your goals are as a credit union: how best to serve your communities and members, and what makes you happy as a credit union. Where is your energy wanting to be directed, and what tools can you use to enhance that? If there are tools you can’t use, talk to your regulators.
Now is the time for changes that could help your credit union. Talk to your legislators—if they’re starting to reimagine technology and financial services, you want to be part of that conversation. Don’t see this as a fearful moment. Ask, “How can this be good for us?”
There’s always a way to turn lemons into lemonade. I’m not saying ignore potential hazards—be prepared, I’m an attorney and trained for that—but always ask, “How can we capitalize on this and grow?” It’s a paradigm shift credit unions need to embrace. That’s my gospel.
[Joshua Barclay] I love it. Elizabeth, if listeners want to get in touch with you, what’s the best way?
[Elizabeth Eurgubian] I am a regulatory and legislative lobbyist. I also do speaking engagements and training on topics like cybersecurity, vendor negotiation, and lobbying effectively. You can reach me at elizabeth.eurgubian@atlasadvocacy.com, visit atlasadvocacy.com, connect on LinkedIn, or find me at the AEI Speakers Bureau.
[Joshua Barclay] Becky, final thoughts?
[Becky Reed] Now’s the time to lean into change. Recently I was at a conference talking to finance folks, and no one in the room had heard of the Genius Act. That’s concerning. Here we have something potentially revolutionary in financial services, starting with payments, and usually payments are under finance—yet no one even knew what the Genius Act was. As an industry, we need to pay more attention to what’s happening around us. Sometimes we stare at our belly button a bit too much. Look out there. It’s a big world with lots of opportunities if you open your eyes.
[Joshua Barclay] If listeners want to get in touch with you, how do they do that?
[Becky Reed] LinkedIn is the best way.
[Joshua Barclay] LinkedIn if you want to hit up Becky Reed. Listen everybody, I want to thank our guest, Elizabeth Eurgubian. I want to thank my co-host, Becky Reed, and I want to thank you, our listeners, for continuing to support and listen to another episode of Grow Your Credit Union.
If you like the show, please follow us on your podcast player of choice, share it, and if you want to be a guest or explore sponsorship opportunities, head to growyourcreditunion.com. Thank you for listening, and we will see you next time. Take care. Bye-bye.
