Are Credit Unions  Moving Beyond NCUA ?

In yesterday’s post on the recent borrowing trends in credit unions, every lender had stepped up to meet the 300%, $90  billion increase in external funding since June  of 2022.  Except one.

While the FHLB system and Fed  Reserve were the dominate providers, all sources from corporates (102%), to  sub debt (24%)  and even  other credit unions  (3,800%) increased their outstanding loans.

The only credit union provider that showed no borrowings was the credit union funded Central Liquidity Facility.   The last  CLF loan origination was in 2009.

CLF’s August 2023 Financial Condition

At August 31, 2023, the  CLF  Financial Statement reports  assets of $875million all invested in US Treasuries.  This was funded by $800 million from 390  credit unions’ capital stock purchases and another $17 million in deposits.  There were no corporate agent members. Retained earnings were $40.4 million.

Year-to-date operating expenses  are $1.3  million, up 86% from the prior year. Dividends on the credit union capital shares are paid quarterly.  The posted rates  would appear to trail the overnight Fed funds return by about 50 basis points.

The Facility’s borrowing authority-lending capacity was $19.7 billion.   And there were no loans.

Why Is There No CLF Lending?

The facility’s funding authority is large enough to  meet significant loan demand.   Its lending parameters mirror those of the Federal Reserve  which  had $30 billion outstanding to credit unions  at June 2023.   Moreover $20 billion of this total was advanced in the June quarter in the aftermath of  market uncertainty due to multiple banking failures.

How are all these other sources growing their portfolios  but the public-private  CLF partnership has no activity?

I have seen no effort by the CLF to promote its services to its own members.   It would be helpful to analyze how many of these 390 CLF shareholders had borrowings elsewhere.  However NCUA will not release the  members’ names so no one can check this possibility.

CLF the Missing  Player

The primary reference to the CLF by the three NCUA board members has been to urge congress to reinstate the special lending/agent membership options passed during the pandemic which expired at the end of 2022.

However today, the CLF lacks neither financial resources nor authority to offer loans that could meet member needs now–as all other lending institutions are  doing.   That is how these firms, public or private survive.

One might  speculate about why there is no CLF effort.   Does it have the operational capability and professional  skills to make loans?   For example, can credit unions even preposition collateral?

In prior lending activity the CLF  partnered with the corporate network which did the underwriting  and disbursements but drew on CLF funding. This operational  capability was lost when the NCUA ended this option by closing U. S. Central.

The  last CLF loans were $5 million each to the conserved WesCorp  and US Central in 2009.

Those two loans were an extension of the NCUSIF’s support.    No other corporates were offered CLF loans even though several had similar exposures to  underwater securities.

In  short, the  CLF  loans were just an extension of NCUA’s supervisory actions, not a liquidity lifeline .

My Thought on Why the  CLF is no Longer Relevant

In addition to its operational incapacity,  I believe credit unions have realized that, unlike other options, the CLF is not an actual  public-private partnership.   Its lending response  is at the whim of NCUA supervisory priorities, not credit union need.

Credit unions do not view the CLF as a reliable partner in times of balance sheet stress.

Therefore, they have moved beyond the CLF for the more proven reliabilities from the multiple options now available–both debt and subdebt.

In short,  credit unions  no longer need the CLF.  They have plenty of tested alternatives.  Ones that don’t impose supervisory judgments on top of collateral values.

For credit unions the CLF is a vestigial  organ, still within the body but not serving any system purpose.   It  continues tp accumulate  retained earnings but has no balance sheet risk.   The income  pays an increasing expense load (up 86% so far in 2023) even with no operational activity.   The regular members shares are subsidizing the  facility  which pays  a  below market quarterly dividend.

The challenges are not a lack  of institutional or member need— just look at the expanding FHLB lending programs.   Rather the challenge is leadership.

This  is  not a situation requiring  a congressional legislative fix.   What’s missing is NCUA’s ability to partner with the members who fund the CLF and develop collaborative solutions to  benefit the cooperative system and their members.

It’s  been done before.   It is being done now by multiple organizations and firms (see examples below).   Credit unions have seen these more reliable options and have decided to move on from an impotent NCUA-CLF.

This situation also raises  a broader issue than the future of the CLF. When might this liquidity experience cause some credit unions  to consider moving even further away from the coop system  altogether.

NOTE: Examples of Proactive Efforts to Serve Credit Union’s Current Liquidity Needs

The following are  examples of  lenders and institutions with outreach to credit unions in this critical liquidity period in 2023.

First,  is the announcement of the  Federal Reserves’ new Bank Term Funding Program (BTFP) on March 12, 2023 for which credit unions were eligible.

The following is from from a  promotion highlighting CD  options:

Inclusiv/Capital and Primary Financial will host a webinar to discuss deposit strategies and resources to support your credit union’s impact lending and liquidity management strategies.

Primary Financial is a credit union service organization (CUSO) owned jointly by 10 corporate credit unions nationwide. This unique ownership structure gives Primary Financial potential relationships  with credit unions across America.

Examples of FHLB special programs and assistance are in numerous press stories:

Ken Bauer, EVP & CLO, OneAZ Credit Union:

“Particularly in Arizona, more of a person’s monthly wages are going to housing than ever before,” Bauer says. “We asked ourselves how we could help members navigate this market and bridge that gap to homeownership.”

To provide members with down payment assistance, the credit union is working with two grant programs offered through the Federal Home Loan Bank (FHLB).

In  Wisconsin:

Summit Credit Union of Madison, Wis. ($6.6 billion in assets, 248,245 members as of June 30) announced Thursday that it was able to help 70 borrowers through the $700,000 in grants it was provided this year by the Federal Home Loan Bank of Chicago. Buyers must earn no more than 80% of the area’s median income.

The grants reduce down payments, closing costs or pre-paid expenses by $10,000 for each of the 70 borrowers who benefitted from January to August 2023.

This is  Ryan  Donovan President and Chief Executive Officer, Council of Federal Home Loan Bank promoting the system’s “private-public” partnerships:

The Federal Home Loan Bank system is a terrific example of a private-public partnership that works, providing tremendous benefit to #homebuyers. Through our members and their activity, we help save homebuyers more than $13 billion each year in interest payments; we facilitate an additional 16% of #mortgage originations; we help make the 30-year fixed rate mortgage an opportunity for many homebuyers; we support community financial institutions across the country; and, we’re one of the largest private-sector contributors to affordable housing efforts.

One can also list numerous financial consultants, ALM  advisory firms,  and brokers seeking to assist credit union liquidity needs, for a fee.  But there is no CLF outreach.


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