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FASB ALLL Proposed Rule Change

FASB’s proposed rule change on how to account for credit losses has stirred up a lot of conversation, as well as concern, among many financial institutions, trade groups and agencies, including the NCUA. While not final, the rule would essentially change the current historically based method of calculating loan losses, and replace it with a forward looking expected loss model. The details of the proposed rule can be found by clicking here.

Whether or not you agree with the proposed rule, it’s never too early to begin considering how it could impact your credit union if implemented. Consider taking some time with your management or ALCO to think through some of the possible consequences this rule could have, and how your credit union might respond. For example, how might it impact future lending decisions? How will earnings and net worth be impacted once the rule is implemented?

Even if the rule is never implemented, the strategic thinking process is not a futile effort. Many credit unions find great value in taking the time to complete this kind of exercise. However, if the rule is in fact implemented down the road, your credit union will have a head start on understanding what the impacts might be and how to respond.

The Time To Comment Is NOW—Use Ours If Needed

Credit unions have a little more than a week left to submit comments for a Proposed Standards Update regarding liquidity risk and interest rate risk (click here to see our comments).   So far about 15 comments have been posted, but it is important for the Financial Accounting Standards Board (FASB) to know how this update may affect credit unions.  If you have not yet taken the opportunity, we encourage you to read the update and comment on it.  You may use some or all of our comments if you’d like.

The proposed update and the link to submit comments can be found here:   https://www.fafsurveys.org/se.ashx?s=4CA36E9200443005.

The deadline to submit comments is September 25.

For Your Radar: Proposed FASB Update On Liquidity And IRR

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From now until September 25, the Financial Accounting Standards Board (FASB) has a Proposed Standards Update open for comment regarding liquidity risk and interest rate risk. The proposed interest rate risk disclosures, if passed, would provide dangerous and misleading information about the safety and soundness of a financial institution, and therefore, the financial services industry. With an interest in how this document could potentially impact the credit union industry, c. myers drafted a response and will issue it to FASB shortly.

To view the current draft of our comments, please click here:  http://www.cmyers.com/cnotes/cmyersdraftfasbresponse.pdf

Click here to view the proposed update on the FASB website.