IT'S been almost two years since I last sat down with Irish League of Credit Unions boss Kieron Brennan.
Back then, he admitted there were "huge challenges" facing the 400 or so credit unions under his wing, as they grappled with recession-induced loan losses and crisis-induced investment losses.
Those challenges seemed daunting at the time, but they are positively dwarfed by the tsunami that looms before the credit union movement today.
After spending much of his first year dealing with the banks, Financial Regulator Matthew Elderfield now has the credit union sector firmly in his sights.
His review into the area is still a work-in-progress, but early soundings suggest that credit unions fall about 40pc short of the regulator's standard for setting cash aside for bad debts.
Elderfield is believed to want this addressed urgently, potentially through a round of mergers that would forever change the face of the credit union movement.
The regulator also wants credit unions to start coughing up for the deposit guarantee scheme, with a payment of €24m believed to have been demanded towards the end of last year.
As well as grappling with looming regulatory demands, credit unions have also been horrified to find themselves captured by the recently-enacted Credit Institutions Stabilisation Act.
The Act was ostensibly designed to deal with the banking crisis, but also gives the Finance Minister unprecedented powers to force change on credit unions.
All the while, the original challenges identified by Brennan have come to pass.
The ILCU's members booked provisions of €480m against bad debts in 2009, another €120m hit was taken in the nine months to September 2010 and Brennan expects further charges for the last three months of 2010.
As provisions gobbled profits, some 60 credit unions didn't pay dividends last year. Brennan "suspects" that figure will go up in 2011, marking "possibly the worst year for dividends" in the movement's history.
The credit unions' figurehead readily acknowledges the many challenges facing Ireland's credit unions, but has the air of a man very much primed for a fight.
Elderfield's credit union review has gone down like a lead balloon amongst Brennan's members, and the ILCU is now actively opposing it.
Brennan takes issue with the regulator's decision to hire consultants Grant Thornton to carry out the review, with the "way credit unions were engaged with" and with the fact that the regulator got to oversee the review.
He's now pushing for a brand new Credit Unions Commission, including all stakeholders from the credit union groups to the regulator and the Department of Finance, which would carry out a fresh review.
Halting the almost-completed Grant Thornton review in its tracks and starting a new one would incur an obvious duplication of costs and would push credit union reform further down the pipeline, but that's a price Brennan seems willing to pay.
"Credit unions are the biggest social/financial movement in this country, they deserve to have the review done in an above-board manner," he says.
Credit unions are also clashing heads with the regulator on the issue of paying for the Government-guarantee scheme that protects up to €100,000 in deposits.
Brennan says credit unions aren't outright refusing to pay, they're just asking for the rate they pay to reflect the fact that credit union deposits are also secured by a €125m industry bailout fund.
Negotiations, which began in October, are ongoing.
Brennan also takes considerable issue with the regulator's already-expressed concerns about credit unions.
Back in October, Elderfield warned politicians about "systematic" under-provisioning at credit unions, which could snowball into a wider solvency issue if left unchecked.
Brennan hasn't yet seen the provisional results of Elderfield's review, but says the 40pc under-provisioning figure "doesn't sound right" and insists his credit unions are adequately placed to withstand a storm.
"We have a €6.2bn loan book; we already have €600m of provisions on that; we have €1.85bn in reserve; we have €3.2bn in liquidity, and we have a €125m bailout fund. Those are huge cushions."
The ILCU's 2010 membership haul suggests the public is equally convinced of the inherent stability of the credit unions movement.
Membership has just crossed the three million threshold, as another 40,000 signed on the dotted line last year making 2010 the biggest recruitment year in a decade.
Brennan acknowledges that there are individual credit unions that might have a "mismatch" of loans and deposits, but says that these can be helped under the League's €125m Savings Protection Scheme (SPS).
Mergers between weaker credit unions and stronger ones could also help buoy struggling credit unions, but Brennan seems horrified at the idea of the League, or worse still, the Regulator, playing matchmaker.
In any case, organic activity is already happening apace, as harsh financial realities prompt credit unions to see the benefits of cutting costs by pooling back office facilities.
Last year, six mergers actually took place. Brennan expects even more this year, reflecting the 30 plus credit unions that have already approached the League for advice on the topic.
While the regulator's overtures have dominated much of the credit union debate in recent months, the sector's quiet inclusion in the Credit Institutions Stabilisation Act may prove more significant.
Recent reports suggested that while credit unions are covered by the act, the credit union movement had been assured that the act would not be used against them.
The assurance doesn't make Brennan sleep any easier. "Irrespective of what anyone tells us, the legislation is on the statute book and it does apply to credit unions," he says.
"Our position is that we would like credit unions taken out of the act."
For Brennan, the situation is a symptom of a wider ill -- namely that our political elite and policymakers appear incapable of making a distinction between banks and credit unions.
In this spirit, the ILCU has begun an extensive lobbying campaign aimed at convincing the next Government that credit unions and banks are very different animals.
The charm offensive also extends to the Department of Finance and the omnipresent Elderfield -- a man Brennan believes could benefit from spending a week in a credit union since "it's very difficult for someone not from this country to understand the Irish credit union movement".
Brennan knows he has a mountain to climb, but he's optimistic about the chances of reaching a consensus on credit union regulation. Beyond that, the modern financial world beckons and the League is trying to get more of its members online, processing electronic transfers and issuing debit cards that could be used worldwide.
In two years time, Kieron Brennan and I may very well meet again. By then, he hopes to have a much brighter story to tell me.