2026-09-25 11:08:48 -06:00
7 changed files with 98 additions and 5 deletions
@@ -58,7 +58,7 @@ The board can propose changes to the lending standards, with published reasons.

 A hostile board has two ways to make co-ops look like failures without breaking any rule openly. The reviewers check for both.

- **Turning away good applicants.** Every year, the reviewers audit a sample of rejected applications against the filed standards and publish the rejection rate for applications that met them. If too few co-ops get funded because applicants didn't show up, that's a real result, as [the pilot](pilot-spec.md#why-about-400-co-ops) says. If too few get funded because the bank turned away applicants who met its own standards, the final verdict says so: **"not tested,"** not "failed."
+- **Turning away good applicants.** Every year, the reviewers audit a sample of rejected applications against the filed standards and publish the rejection rate for applications that met them. If too few co-ops get funded because applicants didn't show up, that's a real result, as [the pilot](pilot-spec.md#why-about-400-co-ops) says. If too few get funded because the bank turned away applicants who met its own standards, the final verdict says so: **"not tested,"** not "failed." The audit also covers co-ops in lower-paid work separately, so the bank can't quietly drift toward the safest co-ops ([Who the Bank Lends To](who-gets-loans.md)).
 - **Making bad loans on purpose.** If the [emergency stop](pilot-spec.md#the-decision-rule) fires, the reviewers check whether the losses come mainly from loans that broke the filed standards. If they do, it's treated like fraud, not like a verdict on co-ops. Lending restarts under the original standards, and those loans are reported separately.

 **This isn't a way to keep the bank alive.** "Not tested" means exactly what "failed" means for the bank: no new loans, the wind-down, and no second round of money. It only changes what the record says about co-ops. Nothing on this page extends the timeline either. The latest the final review can happen is year 15, which is the pilot's existing rule for when good applications are scarce.
@@ -17,7 +17,7 @@ This model doesn't buy, seize or convert anyone's company. Instead it builds new
 - **A small public bank lends to worker co-ops.** It charges market rates, so it only succeeds if co-ops can really compete. Its whole job is to be willing to lend to a kind of company other banks won't. Spain, Italy and the US have all tried versions of this, and the pilot is built around what went right and wrong. [The Bank](the-bank.md) and [Has This Been Tried?](precedents.md)
 - **Owners who want to sell to their workers can.** The bank lends for these sales on a separate track, with its own $100 million and its own test. Only healthy firms qualify, there's no new tax break, the price is capped at an independent appraisal, the seller shares the risk, and the whole workforce votes. [When an Owner Wants to Sell to the Workers](buyouts.md)
 - **Co-ops funded this way stay co-ops forever.** They can't be sold to conventional owners, and members can't vote to cash out what earlier members built. An independent lock-holder can veto any attempt, including selling the business off piece by piece. If a co-op goes bankrupt, only another co-op can buy it whole, and its workers get a real chance to be that buyer. That needs an amendment to federal bankruptcy law, drafted here. [The Lock](the-lock.md), [When a Locked Co-op Goes Bankrupt](bankruptcy.md)
- **It runs as an honest experiment.** A one-time $350 million pilot aims to fund about 400 new co-ops. The success measures are published before the first loan. If, after twelve years, co-ops stay open about as well as similar conventional firms while paying their members fairly, and the bank earned at least what Treasury bonds would have, Congress votes on growing it. If not, it shuts down automatically. It's built so that a hostile government can't quietly freeze it or rig the result, though Congress can always repeal it. It also tests, by lottery, whether serious help before launch gets more co-ops started. The pilot can't show whether co-ops lift pay at other employers. Even after a pass, a sector big enough for that is decades away nationally. So growth comes in capped stages, and that effect gets its own test in a few local markets. [The Test](the-test.md), [The Pilot, in Numbers](pilot-spec.md), [Help Before the First Loan](before-launch.md), [After a Pass: How Big, How Fast](scale.md) and [Making It Last](durability.md)
+- **It runs as an honest experiment.** A one-time $350 million pilot aims to fund about 400 new co-ops. The success measures are published before the first loan. If, after twelve years, co-ops stay open about as well as similar conventional firms while paying their members fairly, and the bank earned at least what Treasury bonds would have, Congress votes on growing it. If not, it shuts down automatically. It's built so that a hostile government can't quietly freeze it or rig the result, though Congress can always repeal it. It also tests, by lottery, whether serious help before launch gets more co-ops started. Part of the loan money is set aside for co-ops in lower-paid work, so the bank can't drift toward only the safest co-ops, and the verdict has to say which kinds of co-ops it covers. The pilot can't show whether co-ops lift pay at other employers. Even after a pass, a sector big enough for that is decades away nationally. So growth comes in capped stages, and that effect gets its own test in a few local markets. [The Test](the-test.md), [The Pilot, in Numbers](pilot-spec.md), [Help Before the First Loan](before-launch.md), [Who the Bank Lends To](who-gets-loans.md), [After a Pass: How Big, How Fast](scale.md) and [Making It Last](durability.md)
 - **Co-ops back each other up.** They pool part of their profits into a shared fund. If one fails, its workers are moved into others instead of being left with nothing. [The Federation](federation.md)
 - **Nobody is left behind by low-margin work.** Owning a company doesn't help much when there's barely any profit to own, so a strong floor covers the rest. A fixed formula, not lobbyists, decides which low-paid work gets public help. [Ownership and the Floor](the-floor.md) and [Who Decides What's Essential](essential-work.md)

@@ -29,6 +29,8 @@ An honest list of what the model hasn't solved yet, most dangerous first.

 10. **The pilot's own weak points.** [The pilot](pilot-spec.md) puts the burden of proof on the co-ops, which means roughly a 1-in-10 chance of shutting down a pilot that was actually working. It tests individual co-ops, not the [federation](federation.md) support network Mondragon relied on. Its lotteries test help after the loan and, since the pre-launch lottery was added, help before it ([Help Before the First Loan](before-launch.md)), but only among groups that come forward, not outreach to workers who never think of starting a co-op. Founders now put in a small stake they can pay in unpaid work, but founders who can't afford months of unpaid work still face a barrier. Its comparison group (small businesses with government-backed loans) is biased in directions that partly cancel out, by amounts nobody knows. And market-rate lending based on collateral may mostly reach founders who already have some wealth. Approval rates by race, gender and wealth are published so that shows up, but publishing a gap doesn't close it.

+14. **Drift toward the safest co-ops.** *(Partly answered.)* A bank that lends only to co-ops can still lend mostly to the safe ones, like consultancies started by people with savings, as America's co-op bank did. [Who the Bank Lends To](who-gets-loans.md) sets aside $90 million of the loan money for co-ops in lower-paid work, which goes back to the general pool only if the reviewers certify the bank handled those applications fairly. Results are reported for that group and for first-time owners without much wealth, and the verdict has to say which kinds of co-ops it covers. Still open: the set-aside makes money available but can't make groups apply; it can be used mostly on work just under the average wage; first-time owners without wealth get reporting, not money; and in work whose prices are set by Medicaid or contractors, a failure may say more about the price than about co-ops.
+
 11. **Federal or state?** *(Mostly answered.)* The test stays federal, because one bank with one plan makes one clean experiment. Any state can copy the bank under the same published rules, reported separately, and a model state law protects the lock ([Making It Last](durability.md#federal-test-state-copies)). Still open: whether a few state lenders sharing one plan would have been the stronger experiment after all, since the most durable public bank in America, North Dakota's, is a state bank.

 12. **Voluntary buyouts: in or out?** *(Answered.)* In, on a separate track: $100 million of its own, healthy firms only, a willing seller, no new tax break, a capped price the seller shares the risk on, a vote of the whole workforce, and its own test of money and pay, so it can't flatter the startup result ([When an Owner Wants to Sell to the Workers](buyouts.md)). Still open: whether a price set by the market is fair to workers who pay it out of their own future work, and whether about 60 deals can show more than that the loans get repaid.
@@ -69,7 +69,7 @@ That also means a roughly 10% chance of shutting down a pilot that was actually

 That creates exactly the pressure that sank Venezuela: an institution with a target lowers its standards to hit it. So:

- **No lending targets.** Nobody is paid, promoted or judged on loan volume.
+- **No lending targets.** Nobody is paid, promoted or judged on loan volume. Part of the loan money is set aside for co-ops in lower-paid work, but that's money made available, not a target ([Who the Bank Lends To](who-gets-loans.md)).
 - **If good applications fall short, the lending window stretches** (up to year 8) instead of standards dropping. The final review moves back by the same amount. That rule is fixed now.
 - **A shortfall is itself a result.** If good co-op applicants don't show up even when financing is available, that's evidence for the "co-ops are rare because they're hard, not because they're unfunded" explanation, and it gets reported that way.

@@ -117,7 +117,7 @@ A useful yardstick: among the SBA's mature loan groups from 1992 to 2004, loans

 **Measures that are published but don't decide:** jobs created (with growth compared with matched firms, spin-offs, and expansions members voted down; see [When Growing Means Sharing](growth.md#5-measuring-it)), wages at the bottom and top and the gap between them, the share of pay above the going rate, how often higher-paid members leave, pay gaps by gender and race within the same job ([Who Sets the Pay](pay.md)), revenue per worker (a rough measure of productivity) and value added per hour worked, followed as co-ops grow ([Does Sharing the Profit Mean Less Effort?](free-riding.md#measuring-it)), how long members stay, injury rates, and the bank's default and recovery rates. Also:

- **Who got loans.** Approval rates and loan terms by the founders' race, gender and personal wealth. If collateral-based lending quietly shuts out the people co-ops mostly serve, it should show.
+- **Who got loans.** Approval rates and loan terms by the founders' race, gender and personal wealth. If collateral-based lending quietly shuts out the people co-ops mostly serve, it should show. Results are also reported for co-ops in lower-paid work and for first-time owners without much wealth ([Who the Bank Lends To](who-gets-loans.md)).
 - **Who gets the profits inside each co-op.** Profit shares, founding shares and membership approvals by race and gender, so that an in-group of early members can't quietly take most of the pool.
 - **Who founded them.** Founders' previous earnings and work histories, using linked government records where they're available, compared with the founders of the matched firms. If the strongest founders stay away ([The Founder Problem](founder-problem.md)), this is where it shows.
 - **Investment.** Spending on equipment, buildings and development per worker, how much of each year's profit is kept in the business, and the return those investments earn, compared with the matched firms. If co-ops starve themselves of capital, as economists have long predicted ([Investing for the Long Run](the-long-run.md)), this is where it shows.
@@ -56,6 +56,7 @@ If the pilot passes, the charter sends Congress a fast-track vote on more capita
 - **Capped growth.** No stage can more than double the bank's capital. A bank that suddenly has to find ten times as many borrowers will lower its standards without meaning to.
 - **Demand can't be starved, either.** Applications and approval rates are published against the pilot's own. A hostile administration can't cut outreach, tighten what counts as "good," and then claim nobody wants to borrow, because the reviewers already check a sample of rejected applications every year and publish how many met the standards anyway ([Making It Last](durability.md)).
 - **The same rules at every stage.** Market rates, the same underwriting, the same limits by industry and county, and no federal guarantee on anything the bank borrows.
+- **Growth follows the evidence for each kind of work.** Lending to co-ops in lower-paid work is sized from that group's own result. If the pilot had too few of them to tell, that lending can't grow faster than the rest ([Who the Bank Lends To](who-gets-loans.md#results-by-group)).
 - **The same measures, published for every new group of co-ops.** Each later round of capital is its own vote in Congress, so every Congress sees how the newest co-ops are doing, not just the pilot's. A passed test shows that co-ops funded one way, at one size, could compete. It doesn't show the same is true at a larger volume, when the bank has to reach further for borrowers.
 - **The full public cost, every year.** The bank publishes its all-in cost to taxpayers per co-op job: losses, running costs, all business help, and what the public's capital could have earned in Treasury bonds instead.

@@ -15,7 +15,7 @@ Mondragon's history supports the first half of the premise. For decades, apart f

 **Design:**

- **Charter:** lends only to firms that meet the [co-op definition](worker-ownership.md) and accept [the lock](the-lock.md). The bank can't widen its own charter. Mondragon's bank drifted into ordinary lending after a change in the law, and America's co-op bank drifted toward the safest co-ops once nothing held it to its target (see [Has This Been Tried?](precedents.md)). A charter can't stop Congress from changing it, but the fixed measures and deadline in [The Test](the-test.md) mean a mission change can't happen quietly.
+- **Charter:** lends only to firms that meet the [co-op definition](worker-ownership.md) and accept [the lock](the-lock.md). The bank can't widen its own charter. Mondragon's bank drifted into ordinary lending after a change in the law, and America's co-op bank drifted toward the safest co-ops once nothing held it to its target (see [Has This Been Tried?](precedents.md)). A charter can't stop Congress from changing it, but the fixed measures and deadline in [The Test](the-test.md) mean a mission change can't happen quietly. Drift inside the charter, toward the safest co-ops, is handled by money set aside for co-ops in lower-paid work and results published by group ([Who the Bank Lends To](who-gets-loans.md)).
 - **Priced at market rates.** This is deliberate. The bank's edge must be *willingness* to underwrite a firm structure other lenders refuse, not *cheap money*. If it lends below market, every result is unfalsifiable: success gets dismissed as "free state money," failure gets dismissed as "hobbled by the lock." At market rates, survival and returns mean something.
 - **Professional, insulated underwriting.** Loan officers are bankers, not appointees. Lending decisions are walled off from legislators the way monetary policy is walled off from Congress. A bank that funds whichever co-op has the best-connected sponsor fails the experiment and deserves to. Since 2026 the Supreme Court has made clear that any president can replace a board like this one at will, so the protection lives in what the board can't change, not in who sits on it (see [Making It Last](durability.md)).
 - **Self-sustaining by design.** One-time capitalization, then it lives on its loan book. Losses are public and published. A permanent appropriation would turn it into a subsidy line, and subsidy lines get captured.
@@ -0,0 +1,90 @@
+---
+title: Who the Bank Lends To
+section: Growing the Sector
+order: 66
+summary: A bank that lends only to co-ops can still drift toward the safest ones, so part of the loan money is set aside for co-ops in lower-paid work, lending is published by group, and the final verdict has to say which kinds of co-ops it covers.
+---
+
+# Who the Bank Lends To
+
+The bank's charter says it lends only to worker co-ops. That stops it from turning into an ordinary bank. It doesn't stop a quieter kind of drift: lending mostly to the co-ops that were always the safest bets, like consultancies and software shops started by people with savings, and seldom to the home care, cleaning and food co-ops where many co-op members work today.
+
+That drift matters for two reasons. It would make the test less useful, because a pass earned by consultancies says little about the work most people do. And it's the drift the founding plan predicts. A public lender judged on its losses has every reason to fund the safe bets. The plan calls that "risk-aversion under political accountability."
+
+## What we know
+
+- **It has happened here.** The law that created America's co-op bank in 1978 told its board to use its "best efforts" to keep at least 35% of its loans going to co-ops of low-income people. Nothing happened when it missed, and the bank drifted toward borrowers that could have borrowed anywhere ([Has This Been Tried?](precedents.md#americas-co-op-bank-the-national-consumer-cooperative-bank)). Lending to safer borrowers may also be part of why it survived. That's the trade this page has to manage.
+- **It isn't automatic.** A study of rated microfinance lenders in many countries over 11 years found that, across the industry, average loan size didn't grow and lending didn't shift toward cities. But lenders whose costs rose tended to make bigger loans, because small loans cost more to make per dollar lent ([Mersland and Strøm, *World Development*, 2010](https://doi.org/10.1016/j.worlddev.2009.05.006); [free copy](https://zenodo.org/records/16910149)). The pressure to drift is real, and it comes through costs.
+- **The sector may already be moving.** The 2025 survey of US worker co-ops found that the fastest-growing industry was business consulting ([US Federation of Worker Cooperatives, 2025](https://www.usworker.coop/blog/the-2025-state-of-the-sector-report-is-here/)). Only 242 co-ops answered the survey ([survey page](https://www.usworker.coop/census/)), so that's a signal, not a measurement.
+- **Enforced floors exist.** To stay certified, a US community development lender has to direct at least 60% of both the number and the dollar amount of its loans to the low-income places or people it's certified to serve. It's checked every year from loan-by-loan data, with no rounding: 59.9% fails. A lender that misses in one year can still pass on its three-year record ([CDFI Fund](https://www.cdfifund.gov/node/1030631); [Dechert, 2024](https://www.dechert.com/knowledge/onpoint/2024/3/department-of-the-treasury-s-community-development-financial-ins0.html)). Those lenders exist to serve that market, though. This bank exists to run a test, so it copies the idea of a checked, published share, not the 60%.
+
+## Two groups, fixed in advance
+
+Before the first loan, the pilot's filed plan defines two groups the results are reported on. The reviewers, not the bank, decide which group a co-op falls in when it applies.
+
+- **Co-ops in lower-paid work.** In the co-op's industry, the average wage in its county is below the county's average for all private-sector jobs. The figures come from the federal count of employment and wages (the Quarterly Census of Employment and Wages), which covers nearly every employer, rural counties included. Where the county figure is withheld for privacy, the state figure is used, then the national one, and the report says how often that happened. The industry is the one the co-op registers under for its payroll taxes, so it can be checked against government records.
+- **First-time owners without much wealth.** Most founding members, counted by their hours of work, have never owned a business, and their household wealth is below the median for people their age in the Federal Reserve's household wealth survey. Founders report their wealth in bands, sign it under penalty for false statements, and it's checked against their tax records with their consent. Founders count only if they work at least a set number of hours in the co-op's first year.
+
+A co-op can be in both groups, one or neither.
+
+## Money set aside
+
+**About a third of the loan money, $90 million, is set aside for co-ops in lower-paid work.** Other co-ops can't borrow it. Nobody waits in line. Co-ops outside the group borrow from the rest of the money, the same as before. That's a first guess, sized so the set-aside could fund a large share of the co-ops at the smaller loans this kind of work usually needs.
+
+**The standards don't change.** Each loan is still judged on its own numbers by the same filed standards ([Guarding the Pilot](pilot-safeguards.md)), and the limits on any one industry and county still apply. If the set-aside and the 25% cap on one industry ever clash, the cap wins.
+
+**Unused money goes back, but only after a check.** At the end of year 4, any money not yet lent goes back to the general pool, but only if the reviewers certify two things:
+
+1. The bank decided applications from lower-paid co-ops as fast as others, measured from a complete application, within a time limit filed in advance.
+2. An extra-large audit of rejected lower-paid applications found that the bank applied its own standards.
+
+If they can't certify both, the money stays set aside until the lending window closes. The verdict for lower-paid work is then **"not tested,"** not "failed," unless the reviewers show that good applications really were scarce.
+
+**A shortfall with a clean audit is a finding.** If good applications from lower-paid work don't come even when the money is there and the bank handled them fairly, that's evidence about where co-ops can work. It's reported that way, the same rule the pilot uses when applicants are scarce ([The Pilot, in Numbers](pilot-spec.md#why-about-400-co-ops)).
+
+**What counts.** Only new money to a co-op counts, and loans to related co-ops are added together, so splitting one loan into pieces can't pad the numbers. If the reviewers later find a co-op was put in the wrong group, its loan is moved to its real group, and the set-aside figures are recalculated. A co-op that misstated its industry on purpose is treated like any other false statement to the bank, under the rules against sham co-ops.
+
+This isn't a lending target. Nobody at the bank is paid or judged on how much it lends, to any group.
+
+## Priced like any other loan
+
+Market rate means the whole cost of the loan, including the cost of making and servicing it, as a conventional lender would charge ([What "market rate" means](pilot-spec.md#what-market-rate-means)). Small loans cost more to make per dollar, so they carry a higher rate or a fee, as they would anywhere. The yearly rate audit checks that too. The bank can match repayments to a co-op's cash flow, with longer terms or a slow start, as long as the price for the risk stays the same.
+
+So the set-aside isn't a subsidy, and it can't excuse a result. The money test is judged on the whole loan book, with no adjustment for the set-aside, whichever way it comes out.
+
+## Published by group
+
+Every year the bank publishes, for each group: applications, approvals, rejections, offers the co-op turned down, withdrawals, rates, collateral, loan sizes, time to a decision, and how the loans are doing. It also publishes the same figures by industry, by rural or urban county (using the federal government's standard rural codes), and by the founders' wealth band.
+
+To protect small businesses, every published table needs at least 10 co-ops in each cell, counting every combination of details shown. Whether individual loans are behind on payments is published only in totals. Loan-by-loan data goes only to vetted researchers under a data-use agreement.
+
+## Results by group
+
+The pilot still passes or fails on the whole portfolio, using the two measures filed in advance ([The decision rule](pilot-spec.md#the-decision-rule)). Adding group results to the decision would make it easier to find one that looks good.
+
+But the final report gives both measures, survival with fair pay and the bank's money, for each group. Because the groups are much smaller than the whole pilot, the plan files in advance the smallest difference each group could reliably show. For groups of a couple of hundred co-ops, "too few to tell" is the likely answer. When it is, the report says so, with the range of possible results and no single headline number.
+
+Differences between groups are claimed only if a test of the difference itself, filed in advance, finds one. The verdict says which kinds of co-ops it covers. "Passed, with too few lower-paid co-ops to tell" is a different result from "passed across the board," and nobody gets to quote the first as the second.
+
+The reviewers, not the bank, work out the bank's return for each group, using a method filed in advance for splitting shared costs. They report it with and without shared overhead, so the split can't be rigged to make one group look expensive.
+
+If the pilot passes, any larger program's lending to lower-paid work is sized from that group's own result. If that result is "too few to tell," that lending can't grow faster than the rest ([After a Pass](scale.md)).
+
+## Treated the same
+
+The yearly audit of rejected applications ([Making It Last](durability.md#rigging-the-result)) now also looks at the two groups, in three ways.
+
+- **Same numbers, same answer?** It compares approvals, rates and collateral across the groups for applications with similar numbers, and checks samples of approvals in both groups against the filed standards.
+- **Are the numbers themselves fair?** It checks each part of the bank's scoring, like collateral, credit history and founders' own money, to see whether it counts against a group more than it predicts repayment. Then it publishes whether a different scoring would predict repayment as well with less of that effect.
+- **Is the bar too high?** If approved co-ops in one group repay better than the rest, the bank was demanding too much of that group. The lottery among borderline applicants ([The Pilot, in Numbers](pilot-spec.md#who-co-ops-are-compared-against)) is the cleanest place to check.
+
+The audit also reports by the founders' gender and race, as the pilot already does, collected separately from the loan file so underwriters don't see it.
+
+## What this doesn't solve
+
+- **It can't make people apply.** The set-aside makes money available. It can't make groups come forward. The [founding lottery](before-launch.md) and sponsors like unions and worker centers do that, and the pilot can only measure how well.
+- **The lower-paid group is wide.** It runs from the lowest-paid work to work just under the average. The bank could meet it mostly at the top. The results are also published by fifths of the local wage scale, so that shows, but nothing requires lending at the bottom.
+- **Market prices aren't neutral.** In home care and cleaning, prices are largely set by whoever buys the work, like Medicaid or a contractor, not by how well the business is run. A co-op that fails there may be failing the price, not the co-op form. Comparing co-ops with conventional firms in the same industry catches some of that, not all.
+- **Industry is a rough stand-in.** A co-op in a low-wage industry can still pay well, and the reverse. Industry is used because it can be checked. The pilot publishes members' actual pay too.
+- **Wealth is hard to check.** Tax records show income, not savings. Some founders will understate their wealth.
+- **The numbers are guesses.** $90 million and year 4 are first guesses. The pilot publishes how much of the set-aside was used, so the next design can do better.