Using that information, the GAO stated, "Our analysis of the 2004 SCF indicated that 31 percent of households that only and primarily used credit unions were of modest means versus 41 percent for households that only and primarily used banks."

The NCUA took issue with both the data and the methodology used in the GAO report. So, in response to the same questions that launched the GAO review, it initiated its own pilot survey, including 14 million member account records from 448 randomly selected federal credit unions.

In it, the NCUA argued (even prior to the release of the GAO report) that the GAO report was inaccurate and flawed, and that its own pilot program showed that federal credit unions are serving those they were chartered to serve: "working individuals."

"Credit unions were built by and for working Americans, and they continue to be by and for working Americans," said Scott Simpson, president of the Utah League of Credit Unions. "We have an obligation, that's true, and I think it's proven if you look at our pilot study, it shows the income distributions of credit union members. I think we have much to be proud of.

"With regard to providing service to people of modest means, I think the GAO would like to see the term 'modest means' used to describe the poor. But I think the NCUA disagrees, I think we disagree, and I think that credit unions in general disagree. 'Modest' doesn't only mean poor. And in reality, you cannot have a credit union — or a bank — with just 'have nots.' You have to have deposits in order to make loans."

Even so, the NCUA pointed to the changes — acknowledged by the GAO — it has made to allow credit unions to branch into underserved communities.

Most of all, the NCUA argued, when attempting to compare banks with other financial institutions, it is important to keep firmly in mind that "the expressions by Congress about whom FCUs (federal credit unions) should serve are framed by an important, and often overriding, limitation about whom they can serve."

Field of membership requirements generally limit a credit union's services to those who are within a bounded area, and prescribe those who can be members. It's difficult comparing one credit union, which may limit its membership to employees of a certain company, for example, with another, which may have a community charter and serve a particular county. It's even harder to compare credit unions with banks.

"This is a desperate legislative attempt to make business for credit unions so difficult that they go away, become banks or something else like that," Simpson said. "That's what this modest means garbage is all about: It's to force an impact upon us. But what problem are they trying to solve? It doesn't exist."

Still, the banking industry seized upon the GAO's findings.