c. myblog

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 […]

April 26, 2011

Proposed Interest Rate Risk Regulation

Newly proposed regulations would require federally insured credit unions to not only have an effective interest rate risk management program, but also a written policy addressing interest rate risk management.  The NCUA has taken this step due to concerns about the level of interest rate risk being taken by many institutions, as material concentrations in […]

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