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FRBSF ECONOMIC LeTTer
2006-19

August 4, 2006

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Performance Divergence of Large and Small Credit Unions
James A. Wilcox
Diverging costs
Diverging earnings
W(h)ither small credit unions?
Summing up
References
By various measures, larger credit unions have recently had stronger financial performance than smaller
credit unions, indicating that these institutions face large and pervasive economies of scale (Wilcox
2005a). This Economic Letter uses data from the 1980-2004 period to show that this performance
difference is a long-running state of affairs. Moreover, these data reveal increasing performance
divergence over this period–that is, a widening in the gap in financial performance between large and
small credit unions. Thus, it is not surprising that the number of smaller institutions has been shrinking,
while the number of larger institutions has been rising. Specifically, between 1980 and 2004, the
number of small credit unions (less than $100 million in assets in 2004 dollars) shrank from 17,132 to
7,859, while the number of large credit unions (over $1 billion) grew from 2 to 98. If performance
divergence continues, it is likely to quicken the pace of consolidation in the credit union industry;
nonetheless, thousands of small credit unions may well survive for decades.
Diverging costs
One measure of the relative cost efficiency of a bank or a credit
union is lower noninterest expense, which consists of wages,
salaries and benefits, depreciation of equipment and buildings,
costs of supplies, marketing, office operations, and travel,
among others. As the string of negative readings in Figure 1
shows, noninterest expenses were consistently lower at large
credit unions than they were at small credit unions. In
particular, at large credit unions, the ratio of noninterest
expenses to assets was more than 100 basis points

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(1 percentage point) lower on average than that for small
credit unions. To put the size of this cost advantage in
perspective, note that, on average, noninterest expenses at
small credit unions are about one and a half times as large as
those for large credit unions. Expressed differently, if large
credit unions had noninterest costs in 2004 as high as those of
small credit unions, all else equal, the net income of large
credit unions as a group would be negative. Instead, large credit unions enjoyed a very profitable year.
Figure 1 also shows that the long-running cost advantage of large credit unions has increased from an
average of fewer than 100 basis points during the 1980s to more than 120 basis points over the past
dozen years. Diverging costs make it ever more difficult for small credit unions to offer financial services
and interest rates on loans and deposits that effectively compete with those of larger credit unions.
This sizable increase in the already large cost advantage of large credit unions might have several
sources. One might be the faster growth of large credit unions relative to smaller institutions, which
would allow them to achieve relatively more scale-related cost savings. In addition, recent legislation
may have imposed costs on banks and credit unions that weigh more heavily on small institutions. To
the extent that the costs of complying with the Bank Secrecy Act and anti-money laundering and other
regulations increased after our data end in 2004, the cost disadvantages of smaller institutions may
have worsened even further. Such cost divergence can further stimulate consolidation.
Diverging earnings
Figure 2 plots the annual differences in the ratios of net income
(or return on assets, ROA) and of interest expenses between
large and small credit unions (measured as a ratio to assets).
Credit unions are mutually owned by their members, not by
stockholders. Thus, all else equal, both higher ROA and higher
interest expenses (which are interest incomes to credit union
members) signal that credit unions are providing greater
benefits to their members. On average, larger credit unions
both earned more net income and paid more interest to their
members than small credit unions did. Because they have
substantially lower noninterest expenses than small credit
unions do, large credit unions have the wherewithal both to
pay higher interest rates and to generate higher earnings. In
addition, members of larger credit unions also benefit from
lower loan interest rates and a wider range of financial services
(Wilcox 2005b, CUNA 2006).
Figure 2 shows that the persistent reductions in noninterest expenses at large relative to small credit
unions tend to be mirrored by persistent upticks in the earnings of large relative to small credit unions.
While large and small credit unions had approximately equal average ROAs over the 1980s, the earnings

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of large and small credit unions steadily diverged since then, with the difference in their ROAs averaging
over 40 basis points since 2000.
In contrast to noninterest expenses and earnings, interest expenses at large and small credit unions
have shown no clear tendency to diverge. Large credit unions paid about 40 basis points more in
interest to their members than small credit unions, both on average since 1980, and in 2004.
W(h)ither small credit unions?
Since large credit unions have long been more efficient, earned more, and paid higher interest rates to
their members than small credit unions, why have small credit unions historically had so many members
and assets? Is the relative shifting of members and assets toward large credit unions likely to continue
and, if so, at what pace and with what repercussions?
The history, the unwinding, and the recent additions of financial regulation each helps answer these
questions. Just as banks faced stringent branching and ownership restrictions before the 1980s,
restrictions on fields of membership (FOMs) usually confined individual credit unions to serving the
employees of a single government agency or company, or even a single plant of a company. Thus,
millions of people were eligible to join only one, often-small, credit union, or to join none at all. Thus, as
for banks, the large numbers of small credit unions historically were partly an artifact of regulation.
Over the last 25 years, changes in regulation have greatly expanded FOMs; for example, sometimes
individual credit unions can serve all of the employees of a nationwide company, all of the local or state
government employees within a state, or all of the residents and employees within a local area (which
might encompass several counties or millions of residents). Larger FOMs have both allowed individual
credit unions to grow and thereby reap certain economies of scale and created more overlapping FOMs,
which permit individuals to choose among credit unions. To the extent that credit union members
migrate toward the (typically larger) credit unions that pay higher deposit rates, expanded FOMs
contributed to the decline in the share of total credit union assets in small credit unions from 69% in
1980 to 46% in 1990, to 29% in 2000, and to 21% in 2004.
While Figure 1 shows the average amounts by which the costs of small credit unions exceed those of
large ones, it does not reveal how much the cost disadvantages vary between small credit unions. In
2004, more than 4,000 small credit unions, which together held most of the assets of all small credit
unions, had noninterest expenses that exceeded the average for large credit unions by more than 100
basis points. For a time, many of these relatively inefficient credit unions will likely survive, if not thrive.
However, their earnings and interest rates are likely to preclude growth sufficient to reduce their
average costs significantly. As a result, these credit unions likely will constitute shrinking shares of an
otherwise sizable and sound industry. Further liberalization of FOMs or other changes that raise the
average sizes of credit unions would likely also further stimulate consolidation among credit unions.
Nonetheless, the credit union industry is unlikely to be dominated by a few nationwide institutions any
time soon. One reason is that legislation and regulation still restrict the expansion of the FOM for an
individual credit union at most to the employees of a profession or business or to a local area. Another
reason is that costs at many small credit unions are low enough to keep them competitive. In 2004, for
example, more than 1,500 small credit unions (accounting for 15% of assets in all small credit unions)
had noninterest expense ratios that were lower than the average ratio for large credit unions. While the
total number of credit unions has fallen from a peak of 23,866 in 1969 to 9,483 in 2004, the rate of
consolidation has slowed recently. Indeed, if the 1995-2004 rate of consolidation continued, for
example, the U.S. would still have over 5,000 credit unions in 2025.
Similarly, for commercial banks, the loosening of geographic and other restrictions contributed greatly to
the consolidation from a post-Great Depression peak of 14,482 banks in 1984 to 7,630 in 2004.
Nonetheless, in recent years, small banks have prospered, numerous new banks have been chartered,
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and the pace of consolidation has slowed. (Perhaps further testimony to the prospects for small credit
unions generally is the virtual absence of any new credit unions being formed over the past decade.)
Indeed, if the 1995-2004 rate of bank consolidation continued, the U.S. would still have about 4,000
commercial banks in 2025. Together, their current healthy performance and condition and the pace of
recent consolidation suggest that the U.S. may well have thousands of small credit unions and small
commercial banks for decades to come.
Summing up
The credit union industry’s responses to the deregulation, technological advances, and additional
regulations of the recent past suggest that it will be consolidating for many years to come. The
industry’s successes suggest that some small credit unions (like some small banks and some small
nonfinancial businesses) are sufficiently cost-efficient and attuned to the needs and circumstances of
their local deposit and loan customers that they will thrive.
Many other credit unions, however, will not thrive or even survive. Continuing performance divergence
will make it increasingly difficult for smaller credit unions to serve their members as effectively as larger
credit unions do and to meet standards for safety and soundness. In that event, less-efficient and lessprofitable credit unions will increasingly feel pressures to liquidate, merge, or convert to other charters.
The size and shape of the credit union industry will reflect which of these options are favored by credit
union members and managements and their regulators.
James A. Wilcox
Visiting Scholar, FRBSF, and
Professor, Haas School of Business, UC Berkeley
References
[URLs accessed August 2006.]
CUNA (Credit Union National Association). 2006. Credit Union Report Year-end 2005

. Madison, WI.

Wilcox, James A. 2005a. “Economies of Scale and the Continuing Consolidation of Credit Unions.” FRBSF
Economic Letter 2005-29 (November 4).
Wilcox, James A. 2005b. Failures and Insurance Losses of Federally-Insured Credit Unions: 1971-2004.
Madison, WI: Filene Research Institute.
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Opinions expressed in FRBSF Economic Letter
do not necessarily reflect the views of the
management of the Federal Reserve Bank of
San Francisco or of the Board of Governors of
the Federal Reserve System. This publication is
edited by Sam Zuckerman and Anita Todd.
Permission to reprint must be obtained in
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Federal Reserve Bank San Francisco | Performance Divergence of Large and Small Credit Unions |

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