c. myblog

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 […]

March 31, 2011

Lower Earnings Or Increased Interest Rate Risk?

If there is one thing to be said infallibly about risk management, it is never black and white.  The historically-low rate environment coupled with mostly-anemic consumer loan demand has put increased pressure on credit union margins across the nation; moreover, many are reaching their floor with regard to lowering deposit rates.  In light of the […]

January 28, 2011

Threats To Interchange—More Than Just An Income Issue

The financial services industry is still holding its breath awaiting the repercussions of the Durbin Amendment reforming debit interchange.  The initial threat for which many are preparing is a material reduction in non-interest income.  Although the amendment exempts financial institutions with less than $10 billion in assets, opponents argue that merchants will (of course) coerce […]

January 14, 2011

Financial Literacy For Volunteers

Regulations from NCUA released last month are now putting more emphasis on a board of directors armed with enhanced understanding of finance and accounting concepts: Part 701.4 (3) Each Federal credit union director has the duty to… At the time of election or appointment, or within a reasonable time thereafter, not to exceed six months, […]

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