From the June 30, 2022 call reports, NCUA reported:
- 399 CUs opted into the Complex Credit Union Leverage Ratio (CCULR) framework with an average CCULR of 11.35%, or 26% higher than the 9% floor.
- 304 CUs reported under the Risk-Based Capital (RBC) framework with an average RBC ratio of 15.39%, or 54% higher than the 10% minimum.
The 500 page, RBC rule and its almost 100 ratio calculations became effective January 1, 2022. Just two weeks after NCUA board approval.
It was intended to provide greater insight about a credit union’s risk profile and capital adequacy. What can an analysis of the RBC adopters tell us from this initial implementation?
The Macro Totals
The 304 credit unions plus 4 ASI-insured who adopted RBC, manage $822.7 billion in assets. But the risk weighted assets total only $479 billion. That 58% ratio is the NCUA’s discounting of total assets total by assigning relative risk weights. For example some assets have zero “weight” (cash, treasuries) or negligible emphasis ( GSE’s 20%).
Compared to the traditional well-capitalized 7% of assets standard, this group holds $20.5 billion in excess capital above this ratio.
Using the minimum RBC ratio of 10%, this same group holds $26 billion in excess of the minimum. As shown above, their average RBC is 15.4%.
The bottom line is that this group of credit unions is well capitalized whether using the 7% traditional level or the new RBC 10%.
Other Initial Findings
One intriguing fact is that 149 of these credit unions, or almost half, have traditional net worth exceeding 9%. That suggests most could opt out of the RBC calculations as they exceed the CCULR 9% compliance minimum.
For example, one credit union with assets between five and ten billion dollars, reports standard net worth of 12.5% and an RBC ratio of 48.3%. Why did they report RBC versus CCULR?
One way CEO’s can use RBC is to show that even with a low traditional net worth they are still more than well-capitalized. A CEO holding 7.5% net worth may want to allocate future earnings for greater member value and avoid the 2% tax on net income to maintain the 9% CCULR minimum. Showing a high RBC to your board and members is a powerful defense of the lower traditional net worth measure.
A Look at Ratio Methodologies
However as shown by the banking example below, RBC captures very few risk factors. Its focus is solely on potential credit and/or principal losses on loans and investments.
One example: 250 of these 308 credit unions reported unrealized declines in the market value of investments that exceeded 25% of net worth. Four credit unions reported a decline greater than 50% of capital. This was before the five additional Federal Reserve’s rate increases through the end of the year. This situation is not recognized in RBC.
To compare peers and their capital performance is very confusing. RBC credit unions can choose four different ways of calculating the ratio’s denominator. Seventy two credit unions opted for a ratio that did not use June quarter ending assets. They chose one of three other options that results in a lower total asset amount, and therefore a higher RBC outcome.
RBC ratio comparisons are further complicated when 152 of the RBC credit unions had a combined risk weighting of less than 60% of total assets. In one case the risk weighted assets were just 24% of the total balance sheet.
Another difficulty in comparisons is that there are other options for capital creation than retained earnings. Seventy-six credit unions report that less than 95% of their “capital” came from their own earnings. Twenty-four reported subordinated debt as capital and the majority of the remaining group were from equity acquired in a merger.
As a result RBC net worth ratios reflect different capital strategies. There is a difference in operating capabilities between institutions who rely solely on retained earnings and those who purchase capital.
Performance Outliers
The RBC spread sheet easily identifies those near the 7% minimum requirement-one is below 7% and 12 between 7 and 7.5%.
Using the 10% minimum RBC net worth, eight credit unions fall below this ratio and 15 have 10.5% or lower, and are close to the minimum.
These screens would be one way of assigning exam priorities.
Initial Observations About RBC
From both the macro numbers and the micro analysis, RBC does very little to inform about safety and soundness.
- The calculation is a backward looking indicator of soundness. It is at a point in time and includes no dynamic ratios.
- Comparisons of peer capital adequacy using ratio analysis is virtually meaningless because of the range of calculations possible and distribution of risk weighted assets.
- No current, critical performance indicators are included. No delinquency, no expense ratios, no liquidity indicators, no IRR or ALM measures, and certainly no growth factors of any kind.
Ironically, is it possible that a very high RBC ratio indicates very poor value creation for members? The very opposite outcome for a credit union to sustain success? Are the 33 credit unions with RBCs in the 20%, 30% and 40% ranges really serving members as their below average loan/share ratios leads to higher reported RBC?
A Preliminary Look
The above analysis is as of June 30, 2022. I will revisit the RBC reporting credit unions at December 2022 to see if the numbers have significantly changed. For example, how many of the 148 above 9% net worth opt for CCULR? Credit unions will then have a full year’s and four quarters experience exploring the pros and cons of using RBC.
At this preliminary analysis, RBC looks like an exercise for credit unions to select their most favorable capital presentation. It may even create perverse regulatory incentives that undercut initiatives for enhanced member value.
A Case Study of RBC and Bank Reporting
The following is an excerpt of RBC analysis of a bank serving the crypto industry and its reported capital adequacy. This was written by Todd Baker, 1stSenior Fellow, Richman Center at Columbia University. (#capital #regulation)
Silvergate Bank has officially reported, and there is a big lesson there for regulators about the failure of risk-based capital standards to adequately address the risks of #banks serving the #cryptotrading gambling emulation of finance.
The wisdom of hard equity leverage capital requirements for banks is clearly demonstrated. They lost a billion dollars and their risk-based capital ratios increased! . .
Again, kudos to whomever managed the process of securities sales, reclassifications, borrowings, etc. at Silvergate. He/she did an amazing job bringing the plane onto the landing strip with one engine in flames and half the tail falling off while keeping the Tier 1 leverage ratio over the 5% “minimum” (which is actually way below the minimum in practice). . .But they still have the need to raise new capital, and fast, because their Tier 1 leverage ratio is way, way too low for the inherent risk from the business, as everyone now knows.
Despite losing a billion dollars (likely more than the company made cumulatively in it’s entire history) in the quarter, driving its holdco ratio of common equity to total assets down to 3.61%, from 8.84% at the end of 2021, and immolating half of the bank’s Tier 1 leverage capital, the bank’s risk-based capital ratios are actually higher (!) than they were at the end of the prior year.
Why? Most of Silvergate’s assets were and are still government securities that are treated as riskless (0% risk weighting) or GSE securites that carry a 20% risk-weighting. Riskless, that is, until you have to sell them in a rising rate environment…
Compare these two disclosures, from year-end 2022 and 2021:
“At December 31, 2022, the Bank had a tier 1 leverage ratio of 5.12%, common equity tier 1 capital ratio of 53.89%, tier 1 risk-based capital ratio of 53.89% and total risk-based capital ratio of 54.07%. These capital ratios each exceeded the “well capitalized” standards defined by federal banking regulations of 5.00% for tier 1 leverage ratio, 6.5% for common equity tier 1 capital ratio, 8.00% for tier 1 risk-based capital ratio and 10.00% for total risk-based capital ratio.” Versus,
“At December 31, 2021, the Bank had a tier 1 leverage ratio of 10.49%, common equity tier 1 capital ratio of 52.49%, tier 1 risk-based capital ratio of 52.49% and total risk-based capital ratio of 52.75%.”