Category: NCUSIF

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Inflation, Interest Rates and Managing the NCUSIF’s $21 Billion Portfolio

Last week the Federal Reserve began its long-publicized tightening of monetary policy.  The Board raised the overnight fed funds target rate to .25-.50% .  Six more raises are planned which would take this rate at year end to around 2%.

The consensus of economists is the Fed’s  plan may be a day late and dollar short.  From MSNBC columnist Kelly Evans right after the announcement:

The Fed published a crucial update in its projections yesterday that showed members now expect the short-term Fed funds rate to hit 2.8% by the end of next year–up from only 1.6% in their December projections. In just three months’ time, in other words, as inflation has shot way higher than anyone at the Fed expected, the committee is signaling the need for almost ten rate hikes by late next year, roughly twice as many as they previously thought necessary. 

In his March 21st speech to National Association of Business Economists (NABE) Fed Chairman Jerome Powell unveiled an even more hawkish view.  Increases could be in .50% increments if needed to counter inflation.

Interest rate rises have substantial consequences for the management of the NCUSIF.   All planned revenue for the NCUSIF is from earnings on its investment portfolio of Treasury securities.  The portfolio will be almost $22 billion by 2022 yearend as credit unions keep sending in 1% of the increase in their share deposits.

Robotic Investing

As the public concern about inflation grew in 2021, the NCUSIF’s investment committee  continued using a “ladder” approach.  The resulting multiple investments  had average durations of 5-6 years and average yields of less than 1%.   This was done at an historically low point in the interest rate cycle.

Despite Board questioning, the staff defended their decisions by saying they don’t try to “time the market.”  Whereas the record shows that the staff has substantially modified the portfolio’s average duration over the past seven years from 1,815 days in 2015 to as low as 901 days in 2018.

One consequence of the Board’s questions  is  NCUA has now published its NCUSIF investment policy.   It can be found here with a last modified date of February 23, 2022. The substance appears unchanged from the previous February 2013 policy.

While NCUA did not formally request input, it is in the industry’s self-interest, even duty, to look at this document to suggest how the management of this $22 billion portfolio could be improved at this point in the  market.

The NCUSIF’s Financial status as of January 2022

 

The most recent NCUSIF financials are at January 31, 2022.    They show the $20.4 billion portfolio is $265 million underwater (market value less than book); the  yield is 1.20% with an   average weighted duration of 1,244 days or 3.5 years.

January’s total income was  $21 million and expenses $17.4 million (up 20% from January 2021). Monthly net income is  $3.6 million with no loss reserve expense or recoveries.

The portfolio is divided into identical  $2.8 billion dollar maturity “buckets” spread over seven years through 2028.  Just $431 million is held overnight.

One year ago, January 2021, the portfolio was $17.8 billion, with a 1.29% yield, weighted average maturity of 1,184 days or 3.3 years.  The portfolio reported a gain in market value of $459 million.

In January 2020, two months before the COVID national economic shutdown and plunge in rates, the NCUSIF reported an average yield of 1.88% and a weighted average life of 2.9 years.  Interest revenue was $25.5  million and operating expense of $16.9 million resulting in a bottom line of $9.5 million, or three times the January 2022  outcome.

The fund’s portfolio maturity extensions during COVID’s low rate  stimulus environment have put the NCUSIF into a financial hole.  Revenue is much less on a portfolio that is 25%  larger  ($ 5 billion) than two years ago; the portfolio has lost $724 million in market value due to its below market return and maturity extensions at the bottom of the interest rate cycle.

These circumstances  suggest an urgent need for a review of NCUSIF portfolio management and reporting. The current policy implementation is not a positive outcome for NCUA or credit unions.

 Changes to Enhance Transparency and Performance

There is investment expertise aplenty in credit unions.   Some areas for commenting on the newly published policy might include:

  1. How can investment return goals be better integrated with projected income and budgeted expense so that target for investment yield can be set objectively? For example a 2% portfolio yield and today’s fund size would cover all budgeted expenses and still leave over $200 million to grow equity or cover any new reserve expense.
  2. How should the objective of paying a dividend to credit unions be incorporated in the fund’s policy objectives?
  3. How can the fund’s investment decisions be more transparent especially the assumptions used when making decisions and changes to portfolio’s duration?
  4. What additional information should be in the monthly reports posted and provided to the board to evaluate investment performance? For example shock tests?
  5. What financial models does the fund use when making decisions? Can these be made public so that credit unions can comment on the projections and assumptions used?

There are  many potential insights to this critical NCUA board policy that could lead to more effective oversight and performance.  The critical success factor is sending these suggestions to NCUA  to be evaluated for updating the policy.

Auspicious Timing

While there has been no formal request for comments, one approach would be to send suggestions to the investment committee’s new Chair which is the Director of E & I. Kelly Lay was just appointed to this position.  This gives her an excellent opportunity to bring credit union experience to the investment process.  Her email is klay@NCUA.gov.

The timing is also critical because rates will be rising, how fast and how far is anyone’s guess.  Both domestic inflation and international events will create ongoing uncertainty.  But the direction is certainly set.

To continue the robotic ladder when it is known rates will in all likelihood continue to rise, is folly.  It brings no credit to the committee’s work and the board’s oversight.

Yesterday’s treasury coupon yields for 25 weeks was .95% and for one year, 1.31%.    These are higher rates than any of the investment decisions made in 2021.  A portfolio return increase of only 1% would double the fund’s annual revenue.

To decide when to extend out the yield curve should be based on analysis of  what breakeven yield is needed to cover costs and equity growth and any loss reserves.   Whether that is 2% or some other number, the goal should be to optimize yield taking into context the operating needs and sending excess earning back to credit unions.

Circumstances have given credit unions and NCUA a valuable moment to improve the management of this important, ever-growing industry asset.   Will credit unions and NCUA take this opportunity?

 

 

 

 

 

 

 

 

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A Fee that Credit Unions Should Review for Appropriateness

Increasing attention is being given to all financial institution’s overdraft/courtesy-pay/nsf fee structures.   An excellent summary of many of the issues is in this article from CUSO magazine.

After the reassessments of these fees, there is another one that credit unions may want to proactively review.

The Unclaimed Property/Inactive Account Fee

A member recently told the story about learning of this fee the hard way.   She had been a loyal credit union member for over two decades and had left a small balance of $500 in case a family member needed to borrow.

The regular savings account paid interest of .05%, offered only online statements and had no activity for over two years.  When checking her 2021 yearend balance online she discovered that the amount had fallen by 20%.

The explanation: a $3 per month inactive account fee was being assessed.  She knew nothing about the fee or how long it had been in place.  In essence she felt the credit union had effectively free use of her money and was charging her on top of that!

When contacted, the credit union explained the fee and offered to refund the money for the last two years, which was as far back as their system would go.

Credit Union’s Responsibility for Inactive Accounts

When Ed, Bucky and I went to NCUA in 1981, I can remember credit unions approaching the agency about charging inactive account fees, which in essence was the step prior to forwarding these accounts to the states as unclaimed property.

In Illinois the Department of Financial Institutions was responsible for administering the unclaimed property act and ensuring funds were properly reported, returned to the state after five years of inactivity so the owners’ names could be publicly listed to  reclaim their funds.

My colleagues believed charging a fee during this inactive period was counter to both the spirit of the act and for a cooperative financial institution.

Credit unions claimed  the accounts were costing them money: maintaining the account, mailing monthly or quarterly statements and plus interest.  Even as they tried to reactivate them, they wanted to be reimbursed for the operational “costs” of the accounts.

For others, the not so hidden motive was to fee the account to $0, especially smaller balances,  close out the member, and not worry about reporting it as unclaimed property.

Others asserted that the fee was in fact an incentive for members to reactivate their accounts.

Inactive accounts come in all flavors:  parents opening accounts for their children, now long gone; accounts left when members move out of the area; the account opened for an indirect loan member, etc.

The common characteristics are there is no member-initiated account activity, the relationship is static, and there is high probability the owner is unaware of any fees being charged.   Therefore it is an easy fee to assess as it is mostly invisible to the account holder.

Other Credit Union Examples

One CEO I talked with said they charge $3 a month on about 500 accounts generating $1,500 in revenue.   At any point in time about 40% of the accounts will be sent to the state.

Another CEO said the credit union charges $10 per quarter.   In both cases the fee had not been evaluated for decades.

Both recognized that in an era of virtual accounts, minimal interest on savings and near zero marginal operating costs, the credit union should focus on contacting members, not seeing the issue as a revenue item.

I would urge credit unions to look at their current inactive account policy and fees.   It may not be as consequential as overdrafts, but if a class action attorney situation arrives, just looking up the years of records, charges and potential refunds, would seem to suggest any income is not worth the potential cost.

Also don’t forget abandoned safety deposit boxes must also be reported as unclaimed after the statutory period of inactivity.

NCUA’s Unclaimed Policy

Just as a footnote, NCUA also acquires unclaimed insured share accounts when liquidating credit unions.

It is interesting to note that the agency’s policy is contrary to the legal practice required of credit unions.

As stated on the website, if NCUA cannot locate the party after 18 months, it converts them to “uninsured” and retains the balances for use by the insurance fund.

Invariably, some items may remain unclaimed. Some checks are never cashed; or the credit union’s address information was incomplete. There are also cases when we don’t have a recent address and are unable to get a forwarding address from the post office.

Share accounts claimed within the 18-month insurance period are paid at their full-insured amount. At the expiration of the 18-month insurance period, shares that are not claimed are considered uninsured and written down to share in the loss to the National Credit Union Share Insurance Fund. Even if shares are uninsured when they are claimed, there may still be a distribution.

On rare occasions, the liquidation of a credit union may result in surplus funds. If a surplus remains, a distribution to the shareholders is required. This may occur several years after the credit union is liquidated and it is sometimes difficult to locate these members.

This is another example where NCUA exempts itself from the rules credit unions are required to follow to protect member’s assets.

 

 

 

 

 

 

 

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Where’s The Rest of Credit Union Members’ $1.2 Billion?

In early January following NCUA’s posting of the September 30, 2021 AME financials for the five corporates, I published an analysis of the forecasted amount to be paid to credit unions.

That analysis showed NCUA projected total distributions of $3.185 billion to shareholders of four of the five estates.  The $569 million in additional payouts NCUA announced on February 28 brings actual payments to $2.010 billion.

Even with  these latest payments, there is still $1.2 billion due to credit union members based on NCUA’s financial projections.

The portion that NCUA announced as dividends on February 28 will go to the former Southwest Corporate shareholders.  They already received their entire capital contribution and are projected to be paid a $330 million liquidating dividend.   After this initial “dividend,” they will be due $120 million more.

Questions Abound

 

The NGN program ended in June 2021.   Why has it taking so long to return the remaining $1.2 billion balance to credit unions?   Will NCUA post a list of the remaining legacy assets and their current market  value with its December 2021 AME financial statements?

The five spread sheets of every legacy asset updated through September 2017 for each estate are already completed.  Shouldn’t NCUA now update these and publish the current market value for every remaining asset?

Is it fair to conclude that 12 years after the 2010 liquidation of the five corporates, only one was actually insolvent?   The other four were deemed insolvent because they were victims of exaggerated and inaccurate loss provisions projected decades into the future?

At this time NCUA forecasts total cash recoveries over $5.7 billion. Of this amount $2.6 billion was the TCCUSF surplus merged into the NCUSIF on October 1, 2017.

Is it correct to say this cash surplus occurred only after the agency subtracted $3.6 billion in liquidation expenses as reported in section B 1 Liquidation Expense in the AME financials?  Are these expenses approximately the same amount as the net legal recoveries?

The so-called legacy assets seized in 2010 have never changed.  Is it reasonable to suggest that this regulatory modeling miss-estimate of $6 to $8 billion was how NCUA determined the corporates to be insolvent?  Moreover, the vast majority of the projected credit defaults had not occurred when the corporates were seized.

If these erroneous projections of at least the $5.7 billion cash surpluses are reasonable, does this suggest why a look back at the entire event should be undertaken?  How can such misleading estimates be avoided in the future?

The Critical Work Still to be Done

 

NCUA’s errors in models and their assumptions resulted in irreversible damage for the credit union system and the individuals involved.   It continues still today in the diminished role of the corporate network.

While many might say let bygones be gone, the processes and powers that created this regulatory debacle have not been assessed or even changed.

The real work of the Corporate Resolution Plan remains to be completed.   Paying out the recoveries from events that should have never taken place should not be the end.  Rather it should compel a thorough look at what caused these errors and miscalculations in the first place.

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A Potentially Pivotal NCUA Board Meeting

Last Thursday’s NCUA monthly board agenda seemed light.  It started at 11:30 and lasted less than an hour.  But the ultimate outcomes could be consequential.

The main topic required no action: the report on the NCUSIF 2021 yearend audit by KPMG. And an extension of PCA covid waiver.

However I believe seeds were planted that could have a significant impact on credit unions and the NCUA’s management of the NCUSIF for credit unions. Here’s why.

The NCUSIF Dialogue: Planting seeds for Change

Chairman Harper opened the NCUSIF review with these words:

For nearly 40 years now, the NCUA has earned an unmodified opinion for the audits of its funds. This sustained achievement underscores the NCUA’s commitment to transparency, accountability, sound financial management, and the careful stewardship of the resources entrusted to the agency.

NCUSIF is the only federally managed insurance fund to require an outside independent CPA audit.  GAO audits the FDIC and the FSLIC– when it existed.

An important difference is the establishment of a loss allowance account following GAAP accounting standards.  The process took three years (1982-1984) for NCUSIF’s reserving process to be independently  validated by the auditors with a clean opinion.

Harper then stated: As a regulator, we need to hold ourselves to the same standard that we expect of the credit unions we oversee.

The Chairman’s commitments to “transparency” and following “the same standard we expect of credit unions” could be critical if followed through with actions on topics raised by his fellow board members.

Hauptman on Investment Policy

After noting the NCUSIF’s sound performance, he made the following comment:

The National Credit Union Share Insurance Fund is a mutual asset — both reported and controlled by the NCUA and an asset reported by the credit unions. Credit unions are required to supply the majority of the fund’s equity through a 1-percent contribution of their insured shares. Just like any credit union board, the NCUA Board has the responsibility to regularly review its investment strategy . And for the sake of transparency and clarity, to do so at an open Board meeting.

He asked questions about the fund’s current investment approach and how to respond to “critics” of recent decisions.   The NCUSIF investment policy last updated in 2013,  is  now being posted with the audit. Hauptman committed to “working with my fellow Board Members on reviewing and updating the investment policy soon.” 

I believe credit unions should also comment on the policy, especially the fund’s duration management.  In the last seven years the NCUSIF portfolio’s weighted average  life (duration) at yearend was reported as follows:

2021 – 1,306 days

2020 – 1,204  days

2019 —   971   days

2018 —   901   days

2017 —   951   days

2016 —  1,864  days

2015 —  1,815 days

Under one policy, these numbers show a 100% change from the lowest 2.5 year duration, to 5.1 years.  Staff maintains this was just maintaining a consistent ladder, not timing the market.

In 2021 the investments robotically followed a seven-year ladder that extended the duration when the interest rate cycle was at an historically low point.

Effective investment management is critical to the fund’s operational design, but also, as Hauptman noted, for credit union confidence in NCUA’s oversight of their 1% asset.  If the policy is updated for more effective monitoring and performance, this could be an important improvement. The sooner the better.

Hood on Accounting Options and Understating the NCUSIF’s NOL

In Hood’s remarks he addressed the fund’s NOL (normal operating level ratio) “true-up” at yearend and its impact on the equity ratio.  He pointed out a “timing difference” in that the 1% share deposit is from June 30, but the insured shares and retained earnings in the ratio are from December 31 numbers.

If the ratio used the same balance sheet dates, the NOL “pro-forma” would be 1.29% not the reported 1.26% at December 2021.

Each basis point (.0001%) is $166 million.  This “timing difference” understates the actual financial position of the NCUSIF by $500 million at yearend.

In the dialogue that followed,  the CFO said this understatement averaged 2 basis points over the last ten years, and has been as high as 6.

Hood then quoted from a memo by Cotton and Company:  the memo produced by the outside accounting firm states that the timeliness and accuracy of data is required in the Federal Credit Union Act so this provision in the law “may provide some latitude from a strict interpretation that the equity ratio must be calculated based on the financial statements amounts, particularly given the knowledge of the timing effect on the calculation of the equity ratio…. Accordingly, it may be permissible to use the pro-forma calculation of the contributed capital amount, when calculating the actual equity ratio.”

When Hood remarked that he would like to see the full Cotton memo published, the CFO replied, “Okay.”

Two Commitments for Greater Transparency

Improved investment transparency and management and better presentation of the NCUSIF’s financials would greatly benefit credit unions.   Moreover, the NOL “true up” is just one of several changes that would make the financial reporting more useful.

In 2010 NCUA changed the accounting standard for the NCUSIF from private GAAP to federal GAAP practice.   There are numerous presentation differences that make the federal approach more difficult to understand because that format was intended for entities that rely on federal appropriations.

Each of the other three funds managed by NCUA report their financial performance and audits using private GAAP.  Given Chairman Harper’s intent  that NCUA follow the “same standard that we expect of the credit unions we oversee,” changing the NCUSIF to the practice followed in its first 30 years would certainly be appropriate.

Sounds of Silence or What was Not Said

The context around the NCUSIF’s financials was all positive with the overall CAMEL ratings showing improvement.

After Harper’s opening recognition of the NCUSIF’s and credit union soundness, he ended with his obligatory theme of future fears:  Nevertheless. . .

  • If the elevated growth of insured shares continues, we can expect a further erosion of the Share Insurance Fund’s equity ratio;
  • the emergence of inflation—something many Americans have never experienced at this rate before—means that the interest rate environment is uncertain.
  • Additionally . . . in my view, the system has not experienced the full extent of the pandemic’s financial and economic disruptions just yet.

Yet despite these uncertainties none of the board members, including the chair, made any mention of assessing a premium which the board had authority to do as long as it did not raise the NOL above 1.3%.   Given Chairman Harper’s previous statements about the fund’s adequacy, this is an interesting silence.

Moreover, the board’s acknowledgement of the yearend NOL at 1.26% (or 1.29%) shows their recognition that the NOL is a range with a low end of 1.2% and a high end cap, currently 1.33%.  The NOL is not a single magic number, but rather an outcome with a “buffer” above 1.2%  that varies depending on current assessments.

This silence after so much talk in early in 2021 about a possible premium, is hopefully a recognition of the flexibility and resilience of the fund’s design.   When combined with enhanced board reporting of NCUSIF investments and a reexamination of accounting presentation, credit unions could be a much better position to understand their fund going forward.

The Board’s public commitments to transparency of the fund’s modeling, the Cotton accounting memo and its presentation options, and the investment policy enhancements would be vital steps to bring the NCUSIF into full cooperative sunlight.

 

 

 

 

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Managing the NCUSIF-Is It too Late to Act?

What should credit unions do when the regulator who makes the rules, does not follow its own rules?

Yesterday the consumer price increase for calendar 2021 was reported as 7%, the highest in 40 years.  This was not a surprise.   Concern about increasing inflation and the Fed’s response had been growing since the summer of 2021.

Interest rate risk is not a new topic. NCUA first proposed adding an S for sensitivity  to the CAMEL rating in 2016.  In October 2021, the board approved a rule adding this “S”  with Chairman Harper saying:

The NCUA’s adoption of the CAMELS system is good public policy and long overdue.  Separating the liquidity and market sensitivity components will allow the NCUA to better monitor these risks within the credit union system, better communicate specific concerns to individual credit unions, and better allocate resources.

The agency’s description of interest rate risk was straight forward:

The sensitivity to market risk reflects the exposure of a credit union’s current and prospective earnings level and economic capital position arising from changes in market prices and the general level of interest rates. Effective risk management programs include comprehensive interest rate risk policies, appropriate and identifiable risk limits, clearly defined risk mitigation strategies, and a suitable governance framework.

Ignoring its Own Rules

However Just six days prior to this, those responsible for managing the NCUSIF’s portfolio invested $1.0 billion (5% of the portfolio) at an average weighted life of 5.95 years and yield of 1.19%.

These investments actually extended the portfolio’s overall maturity from the month before.

This was a continuation of the robotic process  the NCUSIF investment committee had followed since market rates had fallen to near zero in 2020.

In December 2020 question were raised about these investment decisions: What Is NCUSIF’s IRR Investment Policy? Is this a Gap in NCUA Board Oversight?  The article pointed out NCUSIF’s most recent investments included a 7-year fixed rate yielding only .45%.  Would any reasonable person make this investment at this point in the cycle of historically low rates?

In August 2021, the NCUSIF continued its market tone-deaf investing by placing $1.2 billion at an average weighted yield of .943% and life of 5.7 years.   The analysis pointed out that these decisions were hurting credit unions.  One immediate decision that month cost credit unions $4.2 million in foregone revenue over the next 7 years before it matures.

At the same time, credit unions in contrast, reported keeping 53% of their record level of investments in overnight funds.

Who Makes These Decisions?

The NCUSIF has an investment committee of four people including the Chief Financial Officer, the Director of E &I, the chief economist and the head of the Capital and Credit Markets division.

NCUA preaches interest rate management,  but does not practice it.  One doesn’t have to run a stress test to see the devastating results  of these recent decisions. The  NCUSIF’s monthly data documents the decline in portfolio value as rates began  rising over the past 12 months.

In September 2020, the $17 billion NCUSIF reported a market gain of $586 million. In October 2021, the latest report available, this had fallen  by 97%, to just $16.2 million on a portfolio $20.3 billion.  Large portions of the most recent investments are now worth less than their purchase price.  These low yields will hurt the NCUSIF’s performance for years to come.

Who Is Responsible for this Performance Failure?

The NCUA board receives a monthly report on the NCUSIF and a quarterly in-person update.

In questions about investments as recently as December’s meeting, staff’s response is they are just following Board policy.   In the September’s 2021 board meeting the CFO agreed to make public this investment policy.  It didn’t happen.  Several meetings later, he explained the policy was under review and would not be released until that was completed-at some indefinite time in the future.

The Board unanimously approved the new interest rate sensitivity rule in October 2021, which was first published in March.   It receives the monthly report showing the robotic investment activity and steadily falling portfolio values.  The board’s  words and deeds are far apart when it comes to IRR.

The Costs to Credit Unions and NCUA

When the agency’s highest professionals show an inability to manage the agency’s largest asset, the $20 billion NCUSIF, in accordance with its own rules on interest rate sensitivity, fundamental questions are raised.

Are senior staff competent for this task?  Are these investments what the Board really intends with policy?   Is no one in the agency,  staff or board, able to see the damage this causes to the fund’s revenue and its financial soundness?

Good judgement comes from experience.  And experience?  That comes from bad judgement. How many more bad judgements does the board need?

More than the NCUSIF’s future is at stake, as important as that is.   This year-long example of failure to respond to the changing economic conditions in managing the funds, begs the question: Is the agency capable of overseeing this issue in credit unions?   The IRR monitoring of the NCUSIF is simple.  In most credit unions the issues are much more complex.

Both the NCUA board and senior staff are letting credit unions down.  Sooner or later the bill for this failure will come due.   A simple portfolio yield of just 2% on $21 billion is sufficient to cover the normal financial expenses in the fund.  When these investment decisions lock in rates of 1% or less for 5 or 6 years, a premium may be required to pay for the damage caused by poor management.

If this failure is the outcome for the simple management of the NCUSIF’s IRR, the bigger issue is whether the agency has the grasp to properly monitor the industry through the coming rise in the interest rate cycle.

The first test will be what the leadership does about their responsibility for the NCUSIF.  Will the board and senior staff continue to kick the can down the road, blind to the consequences of inaction, or make a difference now?

 

 

 

 

 

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“No Wonder We All Are Bored with NCUA Board Meetings”

This week I asked my good friend Randy Karnes for his perspective  on the upcoming NCUA board meeting (12/16/21). Here’s what he had to say:

Chip hoped that I might inspire the NCUA board to consider its agenda differently; to move away from the agenda’s details and towards activities that would craft a new expectation for us all.   

NCUA and its governance needs to focus on bigger issues. Issues that inspired owners. Issues that made business fun for those who derive  meaning from their efforts. Issues that extended value so that the everyday owners, and professionals reporting to them, would care about board meetings and NCUA’s  oversight functions.

He hoped the three politically selected directors would consider that we need more from the regulator.  We want a group that cares about our professions, our ideas for governance,  and our safety nets.  That the credit union-funded institutions at NCUA are still there to back our plays, our efforts, and our belief in the work ahead.

So I read Chip’s 12/13 blog as the inspiration for my comments, but only found the inspiration to declare I understand why no one gives a sh*t anymore.

Here’s what we’re looking at for Thursday; an agenda that claims we should be paying attention:  Got to wonder?

Multiple issues with the RBC/CCULR capital regulation, a topic of great concern that will affect the CU industry for years to come – a bureaucratic press headline and a staff that cries wolf.

    1. Lots of numbers (NCUA/FDIC) – far from any consequence for those locally looking for numbers that will sustain them.
    2. CU’s have already maintained enough dollars for last few “so called crises” – but who would waste a crisis yet to come?
    3. Is it credit unions  or the NCUA Board  who is focused on “change for change” to their own ends – we see no need for any capital change.
    4. Why trust their “ends” at all, no wonder we all are bored with NCUA board meetings, they are not for us and we hear no mention of us in their words or declarations.
    5. More reg burden for the sake of burden. Another option for NCUA to leverage their situational control of our members’ futures. These new tools are ineffective and simply clutter other work that screams for action.
    6. Confusing stats for the sake of stats, oil and water displays, confusion just to take our eyes off the ball – member value.
    7. Member faith in NCUA thinking is muddled by over wrought academic complexity.  No workman’s simplicity in this group, that would take experience; a care for the work.

Now shift to the budget item.

The next budget is just another edition off  an assembly line of budgets – cranking out ugly babies with no mirrors in sight. More spending wanted, when less would send a message of hope and clarity.

    1. Planners who expect a rising  curve of more money in this to the next year, to every year – void of awareness from past exploits or value adds.
    2. More people to pad our importance, to enhance processes now un-manned, and with no plans for when needed. We need more people without recognizing there are none to be had.
    3. The budget is not about the flow of our industry and the requirements for its sustainability.  It is simply to ensure the NCUA outlasts its ward, that the NCUA is the last group standing.
    4. The industry’s funds are always there to direct, and NCUA will always be  quicker, slicker, and quietly positioned to direct those funds from members’ activities to a bureaucratic engine fueled by money.
    5. Just give us more, we are hungry.

These are the “minutes” for the 12/16 NCUA Board meeting,  ahead of time, a template of expectations from a bored audience of the industry’s CU members – customer-owners who wonder why the value of ownership has lost its punch.

But the funny thing is we all really do still give a sh*t! We are hungry to believe, follow, and to give homage to the NCUA’s efforts if they would simply find the heart to sell us that they still have the will to deliver value to our members. The heart to simply believe in the work of cooperatives. The heart to inspire us with the simplicity of a local community’s effort to lift itself up by work well done.

I know that Chip wants me to declare that 12/16 is a day for us to rally our voices and take on these tactics from the agenda – to shout we give a damn about RBC/CCULR or the board’s broken budget processes, but I can’t.

The only goal I have for the NCUA’s board and bureaucrats is to work harder, and work smarter to bring back those days when we waited in earnest to read the press reports of an NCUA board meeting. To read the reports ready to smile with the effort and the intent that made us believe we had a valuable ally for our futures.

It’s not that America has given up on its institutions that ensure our success; rather we simply forgot how to promote  leaders for these institutions whose roles are to guard and foster our efforts. We need to change how NCUA board members rise to the occasions ahead.

Too many times these directors have started out as lame ducks….and it has nothing to do with their terms. Lame work is becoming the standard.

Tell Me Why I’m Wrong.

 

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Tomorrow’s NCUA Board Challenge:  A Turning Point of Just More of the Same?

Most individuals and organizations  realize at some point in their journeys,  that money does not guarantee success.  Nor happiness.

Thursday’s NCUA Board is, at first glance, all about money.  Tens of millions.  And how it is to be raised, allocated and spent.

Since all NCUA’s funds are from credit union members, it behooves we all pay attention. For NCUA has no other revenue. It is the steward of almost $400 million in annual costs paid by members.

The Board’s financial decisions on Thursday  include:

  • The size of NCUA’s annual and capital budget spending;
  • How these costs are allocated (OTR) between the CLF, NCUSIF and Operating Fee;
  • The limit, or cap, on the maximum relative size of the NCUSIF via the NOL, after which a dividend must be paid;
  • The disposition of the approximately $100 million in surplus retained in the Operating Fund from excess FCU annual fees collected over recent years.
  • Even the proposed CCULR/RBC rule is about money, not just burden. It would require credit unions to retain from revenue initially as much as $26 billion more in reserves that would otherwise be available for greater  member value and service.

All About Money, or Is It?

The justifications for the amounts NCUA is seeking, is that the regulator’s financial resources are what sustains a safe and sound movement.  More financial resources enables more effective supervision.

This leadership approach is a fallacy.  It is often used to explain NCUA’s and even many  credit union decisions.  Institutional strength or capability is measured by asset size, by net worth ratio or for NCUA, the annual spend or dollars on hand.

Resilience Not Resources

However, over and over again especially this year, events have shown that resilience is a leadership characteristic, not the amount of resource an organization controls.   Credit unions with double digit net worth, managing hundreds of millions, even billions, are routinely merging saying they lack the resources to cope with future challenges.  That is a leadership failing, not a resource gap.

Every credit union in existence today was started with no financial capital.  They survived, prospered, and thrived because of volunteer sweat equity, sponsor support, member self-help and shared belief in their purpose.  In other words, leadership.

These critical intrinsic motivations are being replaced with an assumption that more and more dollars are the key to survival.   The thought that resilience depends on more dollars cuts against the grain of what a coop financial system is and can be.

This reasoning is used by some CEO’s who end their tenure with mergers accompanied with large added retirement or financial bonuses.  Greed not gratitude becomes the hallmark career-end.

Who Will Credit Unions Become?

How the Board decides the issues before it tomorrow will send a clear message who they believe credit unions are today and what they will become in the future.  Will it be about more money for NCUA or an effort to inspire credit unions through careful stewardship of their resources and decisions based on objective data?

During the past two years of the pandemic credit unions have shown their best side.  Waving fees, making loan adjustments, lowering charges, and being with members or in person no matter the severity of the epidemic.   The growth in member savings and bottom lines have resulted in back-to-back record setting outcomes and zero NCUSIF insurance losses.

Daily credit unions are announcing bonus dividends to members to share their success in the millions.

The board’s decisions on resources will communicate their view of whether credit unions are special kind of financial service provider that warrants further inspiration, or just a minor-league version of banking.

Will the board present made up worries and projects lacking outcomes to support funding?  Will it succumb to temptation to offer unknowable future risks to retain unneeded reserves?  Will it affirm the idea that every credit union must stand on its own bottom—no system safety nets or mutual support in the event of problems?

All for One and One for All?

Credit union’s manage people’s money to promote other member’s financial opportunity. The well-being of one is linked to the well-being of all.   The same approach has, in the past, applied to credit union’s intra-dependent cooperative system design.

The result is credit unions are much stronger than individual numbers alone would ever indicate.  The member relationships, based on a premise that this financial community will help ones neighbors, creates goodwill and loyalty creating value that far exceeds  financial ratios.

Credit unions are a classic example of American innovation with leaders that have attracted  tens of millions of adherents or fans, called members.  It is self-help, self-financed and self- governed, formed from the grass roots and built on community respect.

A Contradictory Stance On Credit Union’s Role

The NCUA board has represented a different portrait of the system.  In the past decade, NCUA’s priorities suggest credit union’s meaning and value is measured primarily by how many dollars are on the  balance sheet and in net worth.

The whole theme is to get more.  There is no underlying recognition about the practical life of the members or their credit union’s role.  Such a world view cannot inspire the movement let alone feed the soul of  members.

NCUA’s increasingly dystopian views augmented by faulty analysis and misleading numbers blinds them to see what they can’t see.  NCUA no longer see credit unions as they are, because NCUA see things as they are.  They no longer seek information that would change their approach;  rather they look for a story that confirms what they already have in mind.

NCUA’s decisions rest on a simple falsehood that more is necessary rather than a more  complex reality.  Resilience and credit union success is not built on financial performance, but by leaders imbued with purpose and community well-being.

Inverting Common Sense

Even worse is the proposed RBC/CCULR rule.  It inverts the legal maxim that bad cases make bad law. In NCUA’s  view a bad loss requires an ever more complex rule.

When NCUA approves a generally applicable rule like RBC to counter an extreme outcome or circumstance, the risk is that all credit unions’ freedoms are now restricted by the behavior of a very few.

The burden of the RBC/CCULR rule will fall directly on the membership, in the initial proposal by at least $26 billion.

Will the NCUA board respond to the incredible credit union performance during the pandemic for members.  Will it say, “Job well done?”  Or now is our time to get more funds?  Will they respect and recognize the documented track record of the industry since 2008 (reported yesterday) or will they continue to present misleading analysis and mythical future outlooks?

Whatever the outcome, it will set the tone and direction for years to come.  It is unlikely there will be a better time or circumstance for the NCUA board to affirm its faith in the credit union system, the performance of cu leadership during COVID,  and to restrain the never ending instinct  to acquire more resources.

 

 

 

 

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A Pivotal Week for the Credit Union System’s Future

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?

Read the draft of the NCUA 2022-2023 budget here.

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A Better Way-NCUSIF Losses and Revenue Management

(Part 3 of 3 on the NCUSIF , A Better Way for credit union share insurance)

In 2010 GAO reviewed the FDIC’s financial statements for 2008 and 2009 (report 10-705). The summary, What GAO Found, contained the following comments:

“Because of a material weakness in internal control related to its process for estimating losses on loss-sharing agreements, in GAO’s opinion, FDIC did not have effective internal control over financial reporting  . . As of December 31 2009 the DIF had a negative fund balance of $20.9 billion and it had a negative 0.39 percent ratio of reserves to insured deposits.”

This was the third negative position for the fund since deregulation. In the most apocalyptic and highly erroneous NCUA projections about the corporate crisis during (and after) the Great Recession, none projected the NCUSIF would ever be in a deficit position.

After these two significant  economic downturns in one decade, the NCUSIF stands tall, stable and resilient.  However current NCUA Chairman Harper has openly called for the NCUSIF to be changed so it can mirror the FDIC-an entirely different financial design.

His suggestions show a  lack of knowledge about how the NCUSIF has succeeded in an environment that has seen every  other federal deposit insurance premium-based system fail.

NCUSIF’s Record in Recent Crisis

The 13-year period from 2008 through 2020 includes two serious economic downturns.

The cumulative insured loss rate for credit unions during this period is 1.5 basis points(bps) as shown below.  The annual losses range from 0 in 2020 to 6.96 bps when the taxi medallion losses were recorded in 2017.

The NCUSIF’s financial design rests upon the 1% deposit underwriting which grows proportionately with the insured risk plus an equity cushion that has had a traditional cap of .30 basis points of  insured shares.

The board is required to manage this equity level between .2 and .3.  If the NOL is under 1.2%, then the board must present a plan to return to this range.  Above the 1.3% cap (or other limit set by the board to a maximum of 1.5%), the board must pay a dividend to credit unions to reduce the equity to 1.3%.

Loss Provision Estimates Way off Mark

The fund has never incurred losses close to this 10 basis point range.   However NCUA’s loss estimates have often been spectacularly in error.   This graph shows that net cash losses reported in audits have no relation to provision expense.

The next chart shows how the much the overfunding of reserves  compares to actual losses.

The yearend loss reserve has fluctuated wildly  exceeding subsequent actual cash losses by over 10 times in multiple years (1,000%).

These wide disparities between actual losses and provision estimates require subsequent reserve adjustments.  These create very misleading financial bottom line results.  The provision expense, subtracted from or added back to earnings does not present  actual loss experience in a timely and consistent manner.

The fund’s structure is more than adequate for insured credit union losses.   What is most ominous is that NCUA seems to have no consistent, objective and verifiable method for setting the loss reserve.  That is a management problem, not a fund design issue.

When the  annual operating expenses of 1.8 basis points are added to the 1.5 basis points, total costs average 3.3 basis points.  As outlined earlier, the most persistent increasing expense is NCUA’s overhead transfer, not the costs from insured loses. This expense should be more controllable but has in fact become an increasing funding source covering almost two thirds of NCUA’s annual budget.

What About Revenue?

Costs are covered by revenue.  In addition to the two costs above,  income is required to maintain the retained earnings portion of the NOL growing at the same pace as share growth to keep a ratio in the .20-.30 equity range.

The math is easy.   An example. Assuming $1.5 trillion of insured shares, a cash loss rate of 1.5 basis points requires $225 million of income.   As investments equal 1.3% of insured savings, the an investments yield 1.2% covers losses.  To pay the 1.8 bps overhead expense adds another 1.4% for a 2.6% yield to cover all costs in the most 13 years.

If  the long term growth rate is 6.5% of insured savings, an additional yield of 1.3% is necessary to maintain equity. Using just the last decades results would seem to require a 3.9% yield to sustain the funds NOL.

But this return on investments is not required in most normal years.  And a far lower yield, as in the 2021 of 1.23%, can still result in a very strong bottom line.  Here’s why.

First, average insured losses at 1.5 bps are much higher than the long-term historical outcome.  The 13-year experience reflects two unusual events: the Great Recession of 2008-2009 and the taxi medallion losses.   If those three years removed from the average, the average insured losses are far below 1 basis point.

In 2021, insured share losses have been zero and there have been net recoveries from previous loss expense provisions.  In 2020, there were nil insured losses. In the previous three decades prior to 2009, insured losses were often zero and far under the most recent period’s 1.5 bps.

Overhead expense can be controlled.  It has grown at the same rate as insured shares (6.5%) because NCUA has transferred a disproportionate amount of its budget increase in every year to the NCUSIF—over 62%.  If the NCUSIF expenses grew at the same percentage as NCUA’s overall budget, this would reduce the 1.8 basis point portion significantly.  Moreover the growth in the investment portfolio shows that in 2021, the yield needed to cover this year’s projected $195 million OTR is only 1 bps.

Finally the equity ratio is a range of 1.2-1.3.   It can and has historically varied between a low of 1.24 to the cap set by the board in the past 13 years.  In other words a 1 to 2 basis point variance in yearend NOL is normal.  And if there is a truly unforeseen event, then the premium option can be exercised.

But the average model does provide guidance to the fund’s most important month to month role of managing the investment portfolio.   As described in prior posts, the NCUSIF investment committee seems oblivious to the current period of historically low interest rates.

As recently as August during the increased market worry about inflation and rising rates, the  investment committee acted by rote. It laddered out $1.2 billion (6.2% of the fund) at an average weighted  life and yield of 5.7 years and .943% .  One seven-year investment decision alone cost credit unions $42 million in lost revenue because of the committee’s timing.

This is not the first time the committee has made similar decisions seemingly oblivious of the historically low interest rate period the economy is passing through.

These kinds of investment decisions, the continual piling on of expenses, and significantly erroneous estimates of loss are all examples of inadequate management.  No fund design can overcome human folly.

A Dynamic Model to Follow performance

Even with a 1.22% yield in 2021, the financial reports through September suggest the fund will in fact have positive net income and grow the equity ratio.  Why?  There is minimal loss reserve expense and net recoveries from prior loss reserves, a lower cost  of operations, and a decline in insured share growth from 2020.

A simple spread sheet model can track all these variables in real time.  The spread sheet accessed here uses the September numbers for the NCUSIF and insured share growth.  It projects a year end equity ratio of 28.19 which with the yearend 1% deposit true up equals an NOL of 1.2819%.

So even in an historically low yielding and poorly managed investment portfolio, the fund’s result is within the designed outcome.

Even Better News

Traditionally the fund’s equity has not included the loss reserve which has been expensed from earnings but not used.   When this reserve is added to the yearend actual equity ratio, then the NCUSIF reserves are even stronger, always exceeding .30, sometimes by as much as 10-20 basis points higher.

The Better Way design works, not because it is perfect, but because it is flexible and aligns resources with insured risk through constant 1% deposit required from credit unions.  It tales prudent management of expenses, careful loss control and conscientious investment management.

To continue NCUSIF’s performance pattern, four steps should be taken:

  1. Audit and present the fund’s financial position following private GAAP accounting standards. Reset the NOL cap to 1.3% and follow accounting practice used prior to the 2001 change in recognizing the 1% deposit true up.
  2. Reduce the OTR to 50% to correspond to the percentage of state-insured shares in the fund.
  3. Update the oversight and transparency of the NCUSIF investments.
  4. Continue to minimize losses to the fund by working through problem cases not cashing out losses problems by sales to outside bidders.

 

 

 

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A Better Way IF Expenses Are Properly Managed

(Part 2 of 3 on  the  NCUSIF, A Better Way for credit union share insurance)

Throughout the NCUSIF redesign effort in 1984, credit unions had one primary concern with the new concept.  The question was, “If we send this money to Washington, how do we know government just won’t spend it?”

In response the legislation and implementation included multiple guardrails to prevent misuse of the fund by NCUA.  This included a legal cap of 1.3% on total fund size, after which a dividend must be paid; a limit on assessing premiums;  an annual independent  CPA audit following GAAP accounting; monthly public financial reports to the Board; the ability to withdraw the 1% deposit and a commitment to use the fund to minimize losses through 208 and other forms of temporary capital assistance.

Credit union concerns were well-founded.  The NCUA has become increasingly agile in charging the NCUSIF for its operating overhead expenses.

In the 13-year period 2008 through 2020, NCUA has spent a total of $3.321 bn.   Of that amount the operating fee has covered $1.172 or just 35% of NCUA’s expenditures. The NCUSIF has been charged $2.149 bn, or 65%.

Prior to the OTR change in 2001, the fund had never paid more than 50% of NCUA’s operations.

The Fund’s primary expense is for administration not insured losses

As a result, since 2008 NCUSIF’s operating costs exceeded the insurance loss provision expense of $1.880 billion by $270 million.  The primary financial role of the fund is to pay for insurance losses.  The cost have  been primarily through the Overhead Transfer Rate (OTR) process.  This process has been a source of ongoing  manipulation starting  in 2001.

The OTR History

Prior to 1985, the OTR was 33% which was based on the percentage of state-chartered insured shares in the NCUSIF.  In 1985 shortly after Ed Callahan left NCUA, the board raised the OTR to 50% even though the percentage of state chartered insured shares was still 33%.

This 50% ratio remained constant until 2001.  Dennis Dollar, as an NCUA board member and Chair (1997-2004),   made two changes in how the NCUA managed the NCUSIF. The first was making the OTR an annual adjustment, versus a fixed 50%  and secondly, delaying the recognition of the 1% deposit when calculating the yearend NOL.

The first change as reported in footnote 8 of the 2000 NCUSIF audit under the heading, Transactions with NCUA Operating Fund:

The allocation factor was 50% to the Fund and 50% to the NCUA Operating Fund for 2000 and 1999.  On November 16, 2000 the NCUA board voted to increase the allocation factor to the Fund for 2001 from 50% to 66.72%.

The only explanation for the change was that a new study of staff time spent on insurance versus supervision “indicated the rate should be changed to 66.72% for 2001.” ( Page 31 NCUA 2000 Annual Report)   This 33% increase in the transfer was at a time when state chartered  insured shares were only 44.6% of total NCUSIF insured risk.

Since this 2001 break with the long standing 50% transfer, the OTR has been recalculated every year reaching a peak of 73.1% in 2015.  The transfer rate for 2021 is 62.3 %.

The OTR has been the topic of contentious congressional hearings plus countless credit union objections to the arbitrary nature of the process.  See this link for congress’ questioning the OTR.  Even board members have expressed puzzlement with the explanations for how the transfer rate is determined.

Changing the NOL Calculation

The second change made in 2001 also had an ongoing consequence to the fund’s financial position and credit union’s dividend payment.

In 2000 the Normal Operating Level (NOL) was calculated as follows in footnote 5, Fund Capitalization:

The NCUA Board had determined the normal operating level to 1.33% as of December 31,2000, which considers an estimated $31.9 million in deposit adjustments to be billed to insured credit unions in 2001 based upon total insured shares s of December 31,2000. . . The CUMAA mandates the use of year-end reports of insured shares in the calculation of specified ratios and thus dividends related to 2000 will be declared and paid in 2001 based on insured shares as of December 31, 2000, as reported by the insured credit unions.

This was the method used in all the fund’s preceding years. Subsequently dividends of $99.5 million associated with insured shares as of December 31, 2000 were declared and paid in 2001.

But then this NOL calculation,  a consistent process  since 1985, was changed by the Board in 2001 as explained on page 21 if the Annual Report:

the deposit adjustment credit unions submit to the Share Insurance Fund to maintain their required deposit level of 1 percent of insured shares is not recorded until March 2002. In March, the equity ratio moved above the normal 1.3 percent operating level established by the Board. 

This delayed recognition allowed the NCUA to omit the required dividend in 2001 because the actual ratio exceeding 1.3% was not recognized until March.

Since the redesign of the NCUSIF’s in 1984, the adjustment to the 1% deposit had always been collected after yearend (as is the case today), but  still recognized in full when calculating the  December 31 NOL.

This change was discussed in the audited footnote 5 which revised the previous 2000 NOL calculation as follows:

The equity ratio at December 31, 2000, was 1.33%, which considered an estimated $31.9 million in deposit adjustments billed to insured credit unions in 2001 based upon total insured shares as of December 31, 2000. Subsequently, such deposit adjustments were excluded and the calculated equity ratio at December 31, 2000 was revised to 1.30%.

Thus the NCUA board gave itself the flexibility to delay recording the 1% true up versus continuing an  established and clearly understood ratio computation followed for almost 20 years in NCUSIF’s audited statements.

The Impact on the NCUSIF Financial Reports

The annual change in OTR from the long standing 50% and the delayed recognition of the 1% true up have given NCUA greater access to NCUSIF funding.

Since 2008, the operating expenses allocated to the NCUSIF have grown at an annual rate of 6.9%.   In contrast, following the change to a “variable” OTR, the operating fees paid by federal credit unions have increased only 3.6% demonstrating NCUA’s  increased use of the NCUSIF for its total budget.

The graph below shows NCUSIF operating expenses are almost all due to the Overhead Transfer with a different rate set each year.

Regaining Accountability for the NCUSIF

Credit unions were prudent to worry about NCUA’s instinct to spend money under its stewardship.  The NCUSIF is meant to be a financial safety net for the cooperative system. Instead it has been converted to a cash cow  anytime NCUA wants to reach in for more money via the allocation process.

Dividends that would have been paid under the 35- year long-standing 1.3% NOL cap were eliminated when  NCUA simply raised the cap to 1.39 in 2017 and 1.38 in subsequent years.  As many commentators pointed out, there was no objective  data supporting this change.

NCUA’s annual open-ended expense draw compromises the Fund’s primary role as a resource for insurance losses. Before the OTR change in 2001, the NCSIF paid six consecutive dividends. This kept NCUA’s commitment that credit unions could earn a dividend on their 1% investment in years of negligible losses.

Now NCUA takes their toll off the top rather than being limited to 50% a number which aligns with the proportion of state-chartered NCUSIF insured shares.

It is the NCUA board that made the above changes.  Accounting standards can accommodate different ways of presenting financial information.  These statements reflect management decisions, not accounting truths.  The changes in practice described about were not  in the best interests of credit union owners.  Auditors present, but do not approve such decisions.

NCUA’s 2022 budget is up for debate and comment.  The OTR should be set to reflect the proportion of state insured shares, not some opaque, manipulated internal study.  Expense control is a critical for  the proper management of any organization but especially a fund set up primarily to pay for insured losses.

Credit unions  have a duty to  speak up so the Board can right this series of decisions shortchanging the fund’s owners today.

Tomorrow in part 3 I will review the history of NCUSIF losses  to  analyze whether the long standing 1.3% cap and 1% deposit design provide sufficient financial resources for the fund.