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?
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. […]
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 […]
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 […]
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 […]
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