Approved at NCUA’s July 24th board meeting, the proposed rule on maintaining access to emergency liquidity will require credit unions to create/maintain various levels of liquidity planning based on asset sizes. Under $10 million in assets: Maintain a written policy approved by the board with a list of contingent liquidity sources. $10 million or more […]
The National Credit Union Administration recently issued its final rule requiring “federally insured credit unions to develop and adopt a written policy on interest rate risk management and a program to effectively implement that policy, as part of their asset liability management responsibilities. The interest rate risk policy and implementation program will be among the […]
The CFPB is coming online and has begun proposing rules and examining financial institutions. While questions still abound on the bureau’s stance and operations, credit unions should consider the potential impact of new regulations. For example, most credit unions weathered overdraft protection regulations fairly well by getting members to opt-in. However, the CFPB is currently […]
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 […]
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 […]
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