On Thursday, December 16, the NCUA board will meet to decide a slate of issues that will affect the credit union system for years to come, not just 2022.
The most consequential item is the proposal to approve and implement an entirely new RBC/CCULR capital regulation.
Tomorrow I will share one expert’s analysis of the capital adequacy of credit unions since 2008. All the numbers use NCUA and FDIC information.
The data, stress tests and bank comparisons demonstrate that credit unions created and maintained more than sufficient capital during the two most recent crisis, and the unprecedented growth in shares in 2020-2021.
The numbers are tested against actual data. They clearly document credit union’s superior loan loss record versus banks.
The analysis poses the core issue: How does changing a tried, tested and proven system of capital sufficiency improve safety and soundness? The rule provides no evidence that it would have in the past, or will in the future.
In fact the outcome is likely to be just the opposite.
If RBC/CCULR rule is implemented in any form, it will place a regulatory burden on credit unions that will be greater than any other rule ever passed. Every credit union over $400 million (approaching the $500 million complex threshold) and above will have to maintain two different capital calculations under CCULR/RBC. This occurs no matter which new standard a credit union might wish to follow. For it will have to constantly monitor which is most advantageous for its circumstances.
Cross industry comparisons will become at best confused and at worst completely useless. How do you compare a CCULR reporting credit union with one who has adopted the RBC approach with 8% net worth but a 19.5% RBC compliant ratio.
This new burden will fall directly on the members. Members across the board will lose value for a rule that has no objective validation.
Budgets: Approving Spending Years into the Future
NCUA’s budget has a procedural flaw. Estimates for the next year’s budgets are based on prior year’s budgets, not expenditures or what was actually needed. Therefore assumptions are carried forward, regardless of whether the circumstances justifying prior year’s requests still exist.
For example one of the budget explanations is a charge to the CLF as follows:
“total NCUA staffing includes five FTEs funded by the Central Liquidity Facility in 2022”
The CLF has not made a loan in over ten years. Why should there be a need for any full time staff for an organization that only manages a billion or more of credit union shares but has never developed a single program or made a loan to assist the credit union system for more than a decade?
Once a position is approved, it never goes away.
NCUA’s budget process is designed to justify spending rather than evaluate whether more resources are actually necessary to do the jobs at hand.
The major budget decisions include:
- Increasing millions in additional spending charged to three funds plus capital spending;
- Adding up to 48 new positions in addition to the seven approved at midyear;
- Approving an allocation of NCUA overhead to the NCUSIF. Will it be based on the percentage of insured savings in state charters or some arbitrary number adjusted year to year without objective validation?
- Setting the normal operating level (NOL) for the NCUSIF.
The question for the board is whether to direct staff to better manage the resources on hand or continue growing budgets unrelated to actual outcomes and efforts.
Each of these decisions will have significant impact in future years. Will the NCUA board stop practices that are disconnected from actual facts and analysis, or will it just kick the can down the road?