NCUA Beefs Up Insurance Requirements with New Emergency Liquidity Rule
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 in assets: Establish a formal contingency funding plan (CFP) that clearly defines strategies for addressing liquidity shortfalls under adverse circumstances. The CFP must address, at a minimum, the following:
- The sufficiency of the institution’s liquidity sources to meet normal operating requirements as well as contingent events
- The identification of contingent liquidity sources
- Policies to manage a range of stress environments, identification of some possible stress events and identification of likely liquidity responses to such events
- Lines of responsibility within the institution to respond to liquidity events
- Management processes that include clear implementation and escalation procedures for liquidity events
- The frequency that the institution will test and update the plan
$100 million in assets: In addition to maintaining a CFP as described above, demonstrate access to at least one of the following three sources: becoming a member of the CLF, becoming a CLF member through a CLF agent, or establishing borrowing access at the Federal Reserve Discount Window.
Required For Federal Insurance
Perhaps more interesting to note is the placement of this proposed rule under Part 741 of the NCUA rules and regulations, which outlines requirements for Federal insurance. This is the same Part that was revised to require formal IRR programs/policies earlier this year.
Liquidity Contingency Planning
When approaching liquidity planning, c. myers provides its clients with no less than 2 “what-if” scenarios based on an actual liquidity forecast:
- What-if #1: What’s our bad-case liquidity environment? Consider heightened loan demand, increased competition for low-cost deposits and potential cuts in lines of credit in order to stress the credit union’s liquidity position
- What-if #2: How will we respond to our bad-case liquidity environment? When addressing the bad-case environment, consider triggers the credit union can pull to protect its liquidity position, including slowing down/stopping lending, selling investments, raising rates to attract “hot” money, etc.
Exploring these scenarios on a regular basis can help credit unions be prepared for potential liquidity risks—and in light of the new proposed rule—will also help satisfy regulatory requirements for federal insurance if the rule is realized.
