NCUA NEV Supervisory Test: Heads Up Now
June 1, 2022
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7 minute read –“Wait…What? My balance sheet structure really hasn’t changed in the last few months, yet the NCUA NEV Supervisory Test now shows that we went from low/moderate risk to high risk, teetering on extreme. Why is there such a dramatic shift in results?”
This is an example of recent conversations with credit union CFOs and CEOs. We are seeing this on a larger scale as well, our first glance at ALM results for March balance sheets* shows that on average the current NEV ratio (using NCUA deposit values) has declined roughly 1.60%, and the resulting NEV ratio in a shocked +300 is roughly 1.85% lower.
Meanwhile, all the credit unions in this data set made money in the first quarter, adding to their dollars of net worth.
Our recommendation to them is dig in right now and start messaging to other key stakeholders why there is such a dramatic difference in results.
There are several points that should be included when messaging to key stakeholders to provide background, education, and knowledge. The NEV Supervisory Test is a scoping tool to help examiners determine the scope of their exam. If the results show extreme risk, it turns from a scoping tool into an action tool. The NCUA will take action, refer to page 235 of this document to read more. Your actions and ability to articulate your unique situation can heavily influence their actions.
As a reminder, the Supervisory Test uses a combination of available information, credit union assumptions, and pre-set values to determine the economic value in the current and +300 bps environments. More specifically, the Supervisory Test:
- For institutions with assets >$500M, uses discounted cashflows based on the credit union’s assumptions for loans and available information on investments to represent the current economic value of your assets. Given where rates are today, many loan and investment portfolios show a value loss today.
Note: For institutions with assets <$500M, the Supervisory Test may assume current value of loans to be par, or use the credit union’s ALM modeling valuations if available and deemed to be reliable.
- Assigns a pre-set value for all your non-maturity deposits. As a reminder, the pre-set values for NMS is 1% for the current rate environment and an additional 4% value in the +300 bps shock.
Caution: Rates have increased, yet the NEV Supervisory Test still shows the pre-set value of NMS at 1%. This means that in today’s higher rate environment, your NEV Supervisory Test takes the hit for asset values declining, but does not get the benefit that was applied to NMS as rates were increasing in previous Supervisory Tests. Therefore, the starting point for the current NEV ratio is much lower in today’s higher rate environment than previous tests were showing. This is surprising to many key stakeholders, so it’s a critical point to be messaged to and understood by key stakeholders.
This also becomes a head scratcher for many when looking at the economic value of deposits in their non-Supervisory Test results. One CFO summed it up when saying:
“I don’t understand. My average rate for my NMS has not changed. It’s 18 bps, and 5-year borrowing rates are now over 3%, suggesting my deposits have more economic value, and yet the test does not give us any additional benefit for them. I am confused.”
It’s understandable that this is confusing. Yet, the reality is that the NEV Supervisory Test is likely to get increased attention, so you need to be prepared.
There are many ways to prepare:
- Understand the purpose and be able to clearly articulate why the ALM methodologies you use may show differing views as to the magnitude of risk, not to mention the direction. For example – most often, static balance sheet analyses show no risk in a rising rate environment – as a matter of fact, for many institutions, earnings increase at a pretty decent clip, especially in later years of the analysis. Read this if you need a review as to why this methodology would show this.
- Evaluate the profitability and potential exposure to net worth, keeping in mind that profitability and net worth can be very different than assumed value. A business model and plan, both strategic and financial, that demonstrate strong earnings across a range of rates and uncertainty can provide valuable insights on potential actions to consider.
- Recognize that most actions to improve Supervisory Test results will cost earnings, net worth, or both, especially if long-term rates don’t increase more, or reverse direction and go back down. Keep in mind that no one, not even the Fed, can accurately predict rates. Remember, the Fed is trying to influence consumer and business behaviors to tame inflation while also not causing a recession. Many are already bracing for a recession, which could cause rates to go back down, which can further exacerbate the cost of taking action today to address the Supervisory Test.
- Consider expanding your view of the Supervisory Test +400 bps/+500 bps to get an early warning if rates continue to go up.
- Collaborate with key stakeholders to reach consensus on the range of rates for which you want to prepare. Remind them that there is not one right path. Take the time to understand and discuss the implications of yield curve shifts. Make sure to discuss timeframe as well.
This conversation will help immensely in setting the foundation for decision-making and, ultimately, the financial levers you may want to pull. To inform your discussions, use the quantification of your longer-term risks to earnings and net worth, with a focus on how much contribution you may need from your new decisions to offset risk and continue to add value to your members and business members. Remember, they will need you to help them through these rough times.
- Run What-Ifs. No doubt your conversations will result in numerous possibilities, so prioritize. Run your options through your decision filters to help with prioritization. Then what-if the highest priorities to understand the potential financial impact. When you establish your decision filters, make sure to include discussing how to remain relevant to your members and your precious talent.
- Remember, most leaders and stakeholders have never faced the combination of external forces that are in play today. Hunkering down in this environment may not be the best move as the world continues to change at warp speed.
We realize there are many more considerations and questions than we have provided here. Please feel free to call us if you would like to have a more in-depth discussion.
*Results will change as more Balance Sheets come in.
