We at Bauer are very protective of the men and women who serve to protect us. Any hint that they may be being mistreated, particularly by those who should be helping them, is enough to make our blood boil. That's why we took a deep-dive into the accusations against Navy FCU.

What we found: over 2,500 credit unions have higher fees per member than Navy FCU and over 2,100 have higher fees as a percent of net worth than Navy.

From what we see, it does okay by its members. Read more to see if you agree.

Navy Federal Credit Union Off the Hook 

5-Star Navy Federal Credit Union, Vienna, VA (5536), the largest credit union in the nation, boasts more than $190 billion in assets and has more than 14.5 million members. The second largest credit union, 4-Star State Employees’ CU, Raleigh, NC (66310), is only about one-quarter the size of Navy FCU.

It makes perfect sense that Navy FCU would bring in more fee revenue than any other credit union,  and it does. Navy FCU’s first quarter 2025 fee income was indeed the highest at $152 million. The second highest, however, was not State Employees’ CU, but 5-Star Mountain America FCU, Sandy, UT (24692).

With $21.2 billion in assets and 1.4 million members, Mountain America is the 7th largest credit union, but is only one-tenth the size of Navy. Because of the overwhelming range in the size of U.S. credit unions, it’s better to measure fees as a percent of another measure.

For example, as large as total fee income is at Navy FCU, it averaged less than $10.50 per member in the first quarter. Mountain America’s $44.880 million of first quarter fee income calculates to over $33 per member. Fee income per member at State Employees was just $4. (The average was between $16 and $17.)

Last November, the Consumer Financial Protection Bureau (CFPB) ordered Navy FCU to pay $80 million in refunds back to its members and another $15 million in penalties related to  alleged “illegal” overdraft fees (JRN 42:08).

Navy FCU never admitted to any wrongdoing but was going to comply with the order (in spite of its fee income per member coming in well below the national average). It turned out, it didn’t have to. On Monday, June 30, 2025, Russell Vought, Acting Director of the CFPB, terminated that order.

We at Bauer are very protective of the men and women who serve to protect us. Any hint that they may be being mistreated, particularly by those who should be helping them, is enough to make our blood boil. In this instance, however, we don’t see any evidence of that.

What we do see, is a credit union that offers several tools intended to help its members avoid fees - from savings account transfers to a checking account line of credit to an optional overdraft protection service (OOPS). The line of credit does charge interest (13.9% to 17.9%) but this is what Navy uses in lieu of payday alternative loans (PALs).

Mountain America, in addition to having higher than average fee income per member, offers PALs at an interest rate of 28%. PALs are exclusive to Federal Credit Unions, and the interest rates range from 6.5% to 32.31% (based on first quarter 2025 call report data). The most common rate, 28%, was reported by 178 FCUs, followed by 18%, reported by 83 FCUs. The average interest rate charged by all 463 FCUs that reported PALs on their March Call Report was 24%. Navy’s line of credit interest rates of 13.9% to 17.9%, are right in line.

On page 5, we have two sets of credit unions. The first contains the five credit unions that brought in the most fee income in the first quarter. These five are all among the largest 11 credit unions in the nation.

Then, we have all credit unions that brought in first quarter fee income in excess of 5% of their respective net worths (not fee income per member). Choosing to use net worth allows us to see if the credit union’s high fees were an attempt to “rescue” it. For example, both Zero-Star 1st Choice CU, Atlanta, GA (67505) and Zero-Star Eastern Kentucky FCU, Prestonburg, KY (19280) are Critically Undercapitalized.

Without significant improvement, their days are numbered. In fact, Eastern Kentucky  FCU has already ceased to exist. On April 30th, it was acquired by 5-Star Commonwealth FCU, Frankfort, KY (24970). 1st Choice CU is still holding on by a thread.

We also show net income in the chart. Many of the credit unions listed lost money in the first quarter in spite of high fee income; others would have posted a loss, if not for having that fee income. About a dozen CUs listed would also have made the cut had we used fee income per member as our criteria, including 2-Star North Bay CU, CA (63373).

North Bay CU, whose mission is “to help our members prosper through affordable banking and local financing”, earned $1.344 million in fees during the first quarter. That is about three times more than the next highest and calculates to over $450 per member.

Another charging more than $100 in fees  per member during Q1 was 4-Star Bluestone FCU, Sioux Falls, SD (2874) with $1.155 million in fee income spread among 11,383 members. With total net worth of $16.942 million at March 31st, Bluestone makes this list however you slice it.

The fact is, over 2,500 credit unions have higher fees per member than Navy FCU and over 2,100 have higher fees as a percent of net worth than Navy.

Navy FCU is open to all branches of the military, as well as employees of the Department of Defense, Veterans and the families of all above. From what we see, it does okay by its members. Some of the loan rates Navy charges compared to other CUs:

Loan Type	Interest Rate	Industry Range
First Mortgage Home Loan	6.88%	1.16%-12.50%
New Vehicle Loan	4.79%	1.40%-18.00%
Used Vehicle Loan	10.89%	1.90%-26.74%
Unsecured Credit Card	18.00%	0.67%-29.00%