c. myblog

May 15, 2014

Is a Fight for Deposits Heating Up?

We are seeing some financial institutions in pockets of the country raise money market and CD rates.  If you have not done so already, now may be a good time to proactively test the financial, liquidity and strategic impact of a fight for deposits, assuming rates don’t change.

May 9, 2014

Response to NCUA Proposed PCA Risk-Based Capital Rule

Since last week’s blog post, we have received many requests for our response to NCUA’s Risk-Based Capital Proposed Rule. As a result, we have made our final response readily available on our website. One of our objectives in writing this response is to point out that prudent risk management is too complex to be reduced […]

May 1, 2014

Risk-Based Capital Proposed Rule

The deadline for responses to the NCUA’s Risk-Based Capital Proposed Rule is quickly approaching and we are working hard on our response.  We have our draft response available – if you are interested in reading it, please contact us.

April 24, 2014

Thank Goodness the Proposed Risk-Based Capital Rule Doesn’t Affect Me!

If you’ve looked at NCUA’s calculator and determined that the rule won’t hurt you, go ahead and breathe a sigh of relief.  Then set aside some time to at least look at the table of risk weightings and some of the many analyses that have been done by various groups.  This is a cooperative industry […]

April 17, 2014

MBS and other Asset-Backed Investments in the Prompt Corrective Action—Risk-Based Capital Proposed Rule

The proposed rule promotes two options for determining the risk-weights of asset-backed investments, such as mortgage-backed securities (MBS) and collateralized mortgage obligations (CMOs). One uses the current weighted average life for mortgage-backed investments. The other assigns an arbitrary risk weighting of 1,250%. “Proposed §702.104(c)(2)(x) would require that credit unions assign a 1,250 percent risk-weight (8% […]

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