c. myblog

March 16, 2012

What Is Your Alternative To OTS For Prepayment Information?

With the OTS having been merged into the OCC, credit unions are looking for alternative sources for loan prepayment information to use when quantifying interest rate risk (IRR).  Unfortunately, there are a limited number of publicly available sources for this information.  The Securities Industry and Financial Markets Association (SIFMA) is one publicly available source that […]

July 28, 2011

Policy Limits And The Proposed Regulation For IRR

The following is an excerpt from our response to NCUA’s proposed regulation on IRR.  While the excerpt focuses on a potential issue with the proposed regulation, it also highlights a concern we have with the way certain policy limits are written that don’t look at the actual risk of an institution. Appropriate Policy Limits Another […]

June 24, 2011

The Rise In Checking Account Fees (Something To Consider)

Considering the rise in financial institutions charging fees for checking accounts in anticipation of interchange regulation, do you expect consumers to consolidate accounts?  How might that affect your credit union?

May 13, 2011

Proposed IRR Regulation Could Have Unintended Consequences

C. myers agrees with the objective that most institutions should have an effective interest rate risk (IRR) management policy supported by an effective IRR program.  However, we do not agree that it should be regulation. Keep in mind as you read our comments that our business is to provide asset/liability management services to financial institutions.  […]

April 29, 2011

Caution: NCUA’s Proposed Regulation On IRR Could Have Unintended Consequences

You think you are already doing everything required in the proposed Regulation.  You think your policy limits are appropriate for your strategy and business model—but will the examiner making the judgment as to whether your credit union is in compliance think the same? NCUA’s proposed shift from Advisory to Regulation is concerning. It raises several […]

Start typing and press Enter to search