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NCUA Reduced Expenses $64 Million During 2020 Pandemic

During the 2020 virtual exam and work-from-home administration, NCUA reduced its total NCUSIF and Operating expenses by over $64 million. This result certainly deserves a shout out to the NCUA board which oversaw this.

The million dollar question is whether these efficiencies and exam oversight improvements will be sustained? Or might the instinct to make up for “lost expenditures” take over?

The Numbers Total $64 million

The agency’s operating expenses, after OTR transfer, fell by $3.2 million from 2019. However, the $116.3 million total was still $40.6 million, or 54% higher, from five years earlier. At least for one year this inexorable upward trend was reversed.

The greater savings were in the NCUSIF. Administrative expenses fell by over $10 million to $181 million which is the lowest level since 2014.

The largest amount was in the net cash losses (payments less recoveries) for credit union failures. Net cash losses are a more accurate reflection of real performance as the provision expense has shown little or no correlation to actual losses for the past 13 years.

In 2019 the NCUSIF reported net cash losses of $41 million. In 2020 there was a net recovery of $10 million, the first time this has occurred in the past 13 years. This positive recovery was in a year of the worst economic downturn since the Great Recession.

These NCUSIF savings due to a $51 million loss turnaround, plus $10 million in administrative expense reduction added to the $3 million in lower operating costs, together total $64 million.

Sustaining Success by Incorporating Lessons Learned

These numbers are a tribute to credit union resilience and the ability of all segments of the cooperative system to pivot to virtual management. The critical test is whether these virtual gains can be incorporated as ongoing activities so they are maintained when the COVID adjustments are over. Doing so would mean lessons learned that can bring benefits for years to come, even from a crisis. $64 million is a solid achievement not to be lost.

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Three Credit Union Airplane Stories

PenFed’s 2020 Annual Report is a wealth of detail especially in the auditor’s report. Page 53 footnote 9 lists the $542 million net, of property and equipment purchases owned by the credit union.

Two items stand out. Of the over $400 million spent for computer equipment and software, 80% is for software. This affirms the maxim that managing a credit union’s in-house technology solutions entails a never-ending cycle of reinvestment.

But it was a new item listed in 2020 that caught my eye. A total of $10.5 millions for “aircraft equipment” which I assume means an airplane. That amount could buy a lot of plane. Similar to other technology investments, ownership is just part of the cost. There is maintenance, pilot’s salaries and operating costs.

Not sure why a credit union should have its own plane. Perhaps it could be used to survey the credit union’s national field of membership acquired in its merger with Progressive Credit Union.

This purchase reminded me of two prior credit union airplane stories.

Ed Speed, CEO, Texas DOW Employees’ Story

“On Friday afternoon (9/2/2005) Texas DOW Employees CU in Lake Jackson, Texas, received an urgent cell phone call from Jeff Hendrickson, the CEO of DOW Louisiana FCU in Baton Rouge, Louisiana.

“The hundreds of thousands of refugees from the New Orleans and coastal areas who were arriving in the Baton Rouge area had immediately started overloading the entire financial services capacity of Baton Rouge. One area of critical need was cash-regular cash money.

“Although much of Baton Rouge was operational, the entire telephone grid was either damaged or overloaded with attempted calls. As a result, POS terminals, credit card terminals, and ATMs-the great majority of which use dial-up connections-were rendered useless. Because of this, merchants, restaurants, motels, grocery stores, pharmacies began requiring cold hard cash.

“This even became a problem for people who had money in accounts, and many more, including refugees who were being issued paper checks.

“DOW Louisiana FCU was becoming desperately short on cash. They wanted to stay open throughout the Labor Day weekend, but repeated calls for cash deliveries never arrived and none were expected until this coming Wednesday. Local banks started shutting down early Friday as they ran out of cash.

“Jeff Hendrickson, DOW Louisiana FCU’s chief executive, was determined to stay in service. Jeff called us at 1:56 p.m. on Friday asking us to sell them desperately needed cash. Jeff said that without more cash, people coming to his credit union would not be able to get food, shelter, clothing, and medicine. Jeff said he would do whatever it took-even drive to Lake Jackson if we could find cash for him. He said that $500,000 to $600,000 would hold them until cash shipments arrived on Tuesday.

“I marshaled our senior staff and within 15 minutes had a full count of cash on hand from all branches. Lance Wortham, our commercial vice presidents, called his contact at 1st National Bank and got a commitment of $200,000 if we needed more.

“Less than 25 minutes after Jeff had called we were able to call him back with a commitment to deliver $600,000 in cash immediately. My thanks to Steph, Vickey and Kay for their help.

“Within 90 minutes the needed cash ($600,000) had been brought in, counted and bagged. (It was now 3:30 p.m. Friday).

“The problem was going to be the delivery.

“First, we could tell from their voices that they were bone tired and in no shape to drive anywhere. Our driving the cash to Baton Rouge was going to be problematic because Janice Arizmendi, our chief of staff, had contacted the Texas DPS and had been told that individual relief efforts were being turned away at the state border. Without special permission we would be turned back and never get the cash to the credit union.

“That left one viable solution: fly the cash to them.

“I made the decision that I would fly my plane to Baton Rouge that afternoon. Lance Wortham would go with me.

“By 4:00 p.m., less than 2 hours after the initial call, we had the plane loaded. We had to wait about an hour for some local weather to clear. We were able to go “wheels up” right at 5:00 p.m.

“The flight to Baton Rouge took about two hours. When the FAA Houston Control Center handed us off to Baton Rough Approach Control we immediately heard the frenzied air traffic control communications.

“We came to find out that the Baton Rouge airport had become the staging area for all aviation rescue and relief efforts. This was the major staging and refueling point for all of the helicopters you have seen on TV and all of the large supply aircraft. In addition, the airport was the staging area for relief supplies coming in and for flying out refugees who were arriving on buses. We actually saw refugees being off-loaded from buses onto aircraft.

“As we approached the Baton Rouge airport our air traffic controllers told us to expect ‘extended vectors for sequencing.’ I knew we were in for some delays getting in. The controllers eventually brought us in, but only after about 45 minutes of practicing 360 degree holding turns. (Lance was very impressed!!)

“Until the day I die I will never forget the words of the Baton Rouge tower controller: ‘November-Eight-Four-Three-Five Foxtrot (N8435F), you are cleared to land Runway Four-Right (4R), straight in approach… and Three Five Foxtrot, I need you to go as fast as you can!'”

“My response was: ‘Roger, three-five-foxtrot is cleared to land, straight in approach, runway three-five-right, full power, full speed!'”

“We touched done about 8:00 p.m.; six hours after the initial call.

“We were met by the CEO Jeff Hendrickson, his chief operating officer, Todd Zirkle, and armed security from the local sheriff’s department who came out to the plane to meet us.

“We ‘convoyed’ the $600,000 to the DOW Louisiana FCU main branch where the vault staff was waiting to take the cash. In one of the attached pictures one can see that the clock in the vault reads about 8:30 p.m. Six and a half hours start to finish.

“We exchanged the cash for a check, had a quick meal and were escorted back to the airport.

“Lance and I touched down back in Lake Jackson about 1:45 a.m., tired but exhilarated. [We treated ourselves to some comfort food at IHOP!]

“If there is a hero here it has to be Jeff Hendrickson, chief executive of DOW Louisiana FCU. He was determined that his credit union would not, under any circumstances, fail people in need. And, in a way that really humbled me. Jeff said: ‘I knew if I called upon another credit union, if I relied on our Movement, I knew someone would come through for us. I just knew it. This is who we are. This is what we do.'”

“When faced with that type of leadership, determination and faith, I knew we here at TDECU had to deliver for him. Our TDECU team came through and my airplane performed well.

“It all came together.”

Read more: The Great Credit Union Cash Airlift | Credit Unions https://www.creditunions.com/articles/the-great-credit-union-cash-airlift/#ixzz72aHcpDsI

A Charismatic CUNA President and His Airplane

Herb Wegner was CUNA President/CEO 1971-1979. He was responsible for helping credit unions develop many services currently taken for granted today, as well as traditional trade association activities. Among the national programs that started during Wegner’s tenure were:

  • Mortgage loans (CUNA Mortgage Corp)
  • Share drafts (Chase payable thru program)
  • Credit Cards (CSG Card Services)
  • Corporate CUs (US Central)
  • Share Certificates
  • IRAs (CSG IRA Administration)
  • ATMs & Shared Branching
  • Gov Securities Program (ICU GSP)
  • Joint Advertising (CUNA National Advertising Program)

Wegner was elected Vice Chair of the Commission on Electronic Funds Transfer (EFT) in 1975, raising the visibility of credit unions as important players in modern technology programs for the first time in history.

Here is what Paul Thompson said about Herb in his book, Development of the Modern U.S. Credit Union Movement: 1970-2010:

“Shortly after, CUNA gained new leadership by naming Herbert G. Wegner managing director in 1971. Herb Wegner had spent seven years as head of CUNA International’s Latin America division. A former Navy pilot, he was a flamboyant, charismatic leader devoted to modern management techniques such as “management by objectives.”

Wegner reorganized CUNA, and under his guidance it added services to assist credit unions through an increasingly turbulent time. It was an interesting period to be in credit union work, not only because of the fast-changing financial landscape but because credit unionists still saw themselves as a world-changing force.

As Wegner put it: “The exciting thing is not financial, it’s social – the phenomenon of a people’s organization. This is a delightful place to be in an increasingly monolithic world.” 

On the way home from attending Herb’s funeral in Washington D.C. in 1987, Chuck Siebold, Tony Schumacher and Brad Murphy brainstormed how to keep Herb’s memory and accomplishments alive. They suggested an award be granted annually in his name by the fledgling CUNA Foundation. The foundation agreed. The Herb Wegner awards became the centerpiece of the Foundation’s formal gala at each year’s CUNA GAC.

How Herb Lost His Job

A former league President describers Herb Wegner as special. “What he did for us is amazing. An example is when we all feared the emerging cashless checkless society, the US Congress put together a commission to study electronic payments. We were all afraid that credit unions would be frozen out by bank influence. George Mitchell, Vice Chairman of the Federal Reserve Board, was appointed to head the Commission. Herb listened to our fears, flew to Washington DC to meet with George Mitchell, and emerged as Vice Chairman of the commission!”

He describes the CUNA Board meeting in which Wegner lost his job:

“Herb did bring a style that some questioned. Jeans and open collared shirt a lot on the job. He wanted a fireplace in his office when they were building the complex that is now CUNA and Cuna Mutual headquarters in Madison. (The board said NO.) He hired a few Peace Corps individuals who some thought should be people with credit union backgrounds. So there was a small cadre who did not understand what all he brought to the table.

Herb had an airplane. He had a deal with CUNA that he would be reimbursed the equivalent of 1st class airfare if he flew his plane. He would also be reimbursed regular class airfare for others that would fly with him if CUNA was paying their expenses.

Fred Krause was Treasurer of CUNA. He surprised all (or at least most) of us at a board meeting when he gave his Treasurer’s Report and concluded by saying he was tired of fighting Herb about airplane expenses. He then made a motion to fire Herb. John Adams seconded it. Everyone was stunned, but no one fought back. The vote passed. Herb was in disbelief!

Herb was a fabulous leader, well liked, and immensely respected. Most of us thought the CUNA board was short sighted and made a big mistake.”

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Before NCUA’s “Regulatory Backlash”

In my Credit Union Museum video, I described NCUA’s approach to credit unions since 2009 as an era of “regulatory backlash.”  The term summarizes the unilateral imposition of rules, premiums and new examination tests after the Great Recession crisis. The agency repeatedly asserted it was an “independent” ruler and  treated credit unions as their subjects.

One example is the creation of the 424-page risk based capital rule which is so burdensome that it has been postponed for almost 8 years.  Meanwhile the FDIC has dropped this as a required calculation.

One reader disagreed.  He said the backlash began in 1998 with the imposition of PCA on credit union net worth assessments as part of the Credit Union Membership Access Act.  (CUMAA)

However NCUA’s record suggest this is not the case.   When the Supreme Court ruled 5 to 4 in 1998 that the field of membership of a federal credit union could only be a single group, a substantial portion of new members added by FCU’s would have been thrown out if CUMAA not been passed.  It was Treasury, not NCUA, that imposed the PCA, in return for their not opposing this legislative change.

NCUA’s Support for the Credit Union System

The following are brief highlights from NCUA’s 2000 and 2001 Annual Reports demonstrating multiple ways the agency continued to support the credit union system beyond its traditional examination and supervision roles after PCA.

This cooperation began in the deregulation era of the 1980’s.  This early effort culminated in the passage of Congressional legislation redesigning the NCUSIF along cooperative principles in 1984.

Chairman Ed Callahan described this Great Victory in this 1.5 minute NCUA Video Network excerpt from 1984.  His central point is how everyone contributed to achieving this unique result.

The Key Themes of a Cooperative Regulatory Approach

The Annual Report excerpts that follow demonstrate the agency’s efforts at cost control, financial transparency, joint assistance programs, and an overt willingness to support cooperative expansion.   NCUA  recognizes and supports the diverse and unique nature of all credit unions, large and small.

They acknowledge their accountability to the credit union system (stakeholders) in their communication efforts and their stewardship of credit union resources.

This was the culture developed in the three decades following deregulation. These are only a few of many mutual efforts that had characterized this most critical cooperative system relationship in this period.

That mutual respect  is what was lost during the Great Recession and is missing in NCUA’s approach to its role today.

From the 2000 Annual Report

Student Internship Program

The OCDCU 2000 College Student Summer Internship Program was the most successful to date. The program creates partnerships between low-income designated and other credit unions (large or small) and college juniors and seniors to train and develop a pool of potential future credit union managers. The students selected are business, finance or marketing majors.

With technical assistance grant stipends, the 2000 summer intern program matched 29 college student interns with 58 different credit unions. Stipends provided the interns totaled $72,500 in 2000 compared with $67,500 in 1999 for 27 students.  Pg 16

National Small Credit Union Program

The NCUA Board adopted the National Small Credit Union Program (NSCUP) in March 1999. The NSCUP exists to:

  • Promote credit union service to people of modest means;
  • Increase access to credit unions for individuals in underserved communities by fostering a regulatory environment where small, newly-chartered and low-income designated credit unions can provide appropriate and needed services to members;
  • Promote successful, financially healthy small credit unions through appropriate technical and financial assistance; and,
  • Facilitate a regulatory environment that empowers small credit unions.

Nearly 500 credit unions voluntarily participate in the program. The NCUA has committed 74 field staff — 13 economic development specialists (EDS) and 61 small credit union program specialists (SCUPS) — located throughout the nation to carrying out the NSCUP objectives.

These specialists focus on increasing access to credit unions and credit union management development through training and mentor relationships. Recognizing the uniqueness of small credit unions and the necessity to maintain an informed staff, OCDCU conducted two EDS/SCUP training workshops during 2000. The workshops focused on increasing access to credit unions, business development, information technologies and alternative capital sources.

Reducing the Operating Fund’s Balance

The 2000 budget projected a $7.4 million net loss to the Operating Fund as the agency continues efforts to reduce the fund balance. However, because of budget savings from vacant staff positions, the net loss for 2000 was approximately $4.1 million. As a result, the Fund balance at year-end 2000 was $2.2 million.  Pg  31 (note: it was $136.3 million at December 2020)

From the 2001 Annual Report

The Board itself demonstrated its commitment to more responsive accountability for agency operations and finances by conducting NCUA’s first ever Public Forum and Budget Briefing, which resulted in stakeholders having a better understanding of the agency’s budget and operations.

Likewise, the NCUA initiated an internal Accountability in Management self-study, which presented opportunities to streamline operations, reallocate resources and improve the overall efficiency of the agency. These important initiatives are being implemented and will remain a high agency priority in 2002.  Pg 5

As part of NCUA’s strategic planning and as requested by Chairman Dennis Dollar, via his Accountability in Management (AIM) initiative, all areas of agency operation are being reviewed to determine efficiency and effectiveness. NCUA’s 2002 budget incorporated many recommendations attributed to that purpose and one result was the consolidation of several central offices.

Consolidation coupled with regional staff reductions, due in large part to the new flexible examination schedule, results in a projected 3.4 percent reduction in staff by the end of 2002 and positions the agency to achieve at least a 4 percent staff reduction by the end of 2003.

Just as the credit unions NCUA regulates and insures continually plan for the future, we will continue to review both the central and regional office structure with an eye toward boosting efficiency and saving cost. We expect many cost saving changes in 2002 — risk-focused examinations, flexible examination scheduling for qualifying credit unions and accountability in management initiatives — will result in an improved examination program and continued good stewardship of agency resources. Pg 8.

In the Future

During my first year as executive director, we made a commitment to establish open, frequent lines of communication with NCUA’s stakeholders. Chairman Dennis Dollar’s groundbreaking idea to conduct NCUA’s first open budget briefing and public forum provided an excellent opportunity for timely, direct input from our key stakeholders. Due to the success of this approach, you can be assured that NCUA will remain committed to providing open forums for gleaning input, which allows for an optimal decision-making environment

NCUA News was produced by PACA and sent to more than 10,000 credit unions and related organizations. NCUA News is often the voice of NCUA for credit union officers and volunteers, those who need to know what is happening in and around the agency. Responding to media inquiries, issuing press releases, advancing media contacts, writing the NCUA News and Inside NCUA, an internal newsletter for NCUA staff, monitoring and updating the NCUA web site and producing the annual report comprise the core public affairs responsibilities of PACA.  Pg 11

Small Credit Union Program

The Small Credit Union Program (SCUP), which is monitored by OCUD, is operated by the regions to promote successful, financially healthy small credit unions (those under $5 million in assets; in operation less than 10 years with under $10 million in assets; or low-income designated credit unions). This is accomplished through appropriate use of technical and financial assistance (e.g., on-site contacts and workshops).

The NCUA Board has committed 78 specialists —17 economic development specialists and 61 small credit union program specialists—to this program. There are 4,381 credit unions that fall within the SCUP criteria that are eligible to participate in the program. At December 31, 2001, there were 721 credit unions participating in the program. During 2001, the regional specialists performed 705 on-site visits providing one on one, on-the-job training.

Another aspect of SCUP is group training, where germane topics are addressed with program credit union officials and staff members. Outreach was in high gear during 2001, with the regions completing 43 workshops. More than 2,100 credit union officials attended these workshops.  Pg 16

 

 

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An Era of “Regulatory Backlash”

America’s credit union museum has begun an oral history series of recordings about critical events in the 110 years of the movement.

Episode 16, my contribution, is in two parts.   Part 1 tells the story of deregulation.   I described this approach as a pragmatic response to the disruptive economic and political forces changing many areas of American enterprise in the late 1970’s:

“Deregulation was not a political ideology, strategic blueprint or onetime response to a changing economy.

In credit unions it was nothing less than building a better system of “cooperative credit in the United States.” It turned upside down the practice of government making everyday business decisions for credit unions.

Rather that responsibility was now in the hands of those closest to the members-management and boards.”

Callahan’s Calling Card

In part 2, I recall the reasons Ed Callahan gave when asked why he was leaving the NCUA Chair with over two years remaining on his term. One was to help credit unions take advantage of the opportunities provided by deregulation.

In founding Callahans, the firm’s first effort was to establish a database of all US credit unions.  In 1986 this became the source for the first and only annual Credit Union Directory. Volume 36 was released this past quarter.

This data resource became the multifaceted Peer-to-Peer database and software that is the go-to, most advanced analytical tool for understanding the industry today.

The Ending of an ERA

Part 2 discusses the ending of this fourth chapter of credit union history–deregulation–in 2009 as the Great Recession financial crisis occurs.  Each of these four ERA’s is approximately a generation long.

While the following 25 years have yet to be fully lived, I suggest the initial decade’s dominate activity could be described as a time of “regulatory backlash.”  The mutual regulatory-industry approach to change and response to disruptions was ended.  NCUA emphasized its “independence” from the credit unions and undertook a series of unilateral regulatory initiatives to re-regulate and impose greater restrictions on multiple areas of activity.

When an NCUA Chair today testifies before Congress that his oversight North Star is FIRE, the cooperative system has been put on notice.  The Chair is just one board vote shy from throwing credit  unions into the pit of regulatory damnation.

The presentation is 22 minutes.   I refer to both recent history and current topics such as mergers, the idolization of size, and the ever-present temptation to become “bank-lite.”

Whatever name sticks when the current 25-year chapter is closed, I trust reviewing these initial years of NCUA activity in the light of prior ERA’s experiences will be educational.

 

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Are App Platforms the Future of Financial Services?

COVID  accelerated the online movement  for all aspects of social and economic life.  In credit unions, some assert the transition away from the branch-based model of financial services to an all virtual one is now inevitable.

One example of this total virtual embrace is the former United Airlines, now Alliant CU with $14 billion in assets. It has no branches and is the ninth largest credit union in the country.  In contrast the $8 billion Wings Financial whose initial sponsors were also airlines, still has 30 branch operations in airports as well as in the communities surrounding its home office of Minneapolis-St Paul.

The Startups

Multiple startup financial providers, relying solely on virtual platform services, are attracting venture capital and IPO attention.   As described by Ron Lieber of the New York Times, What’s in a First Name for the New Money Apps:

The start-ups’ interfaces are indeed generally slicker and simpler, very much a welcome change.

And if you resent all of the overdraft and other fees the big brother banks so often charge — and you do, there’s little doubt — Dave and friends look even better. They tack away from old-fashioned bankery, with a suite of offerings like advance access to your paycheck, overdraft fee avoidance and assistance building credit.

Their brand’s “personalization” is communicated with  first names like Dave, Marcus, Albert or Bella.  Or sometimes with a disruptive promise like Aspiration and Revolut.   One online offering called Simple was just that, and has already closed.

The Enduring Advantage

While distribution options and transaction volumes migrate to virtual self-service, that does not mean branches will go away.  They may decline in traditional teller transactions but become more vital for other service interactions

Credit unions are organized around a “community” of people versus organizations built with venture capital.  Their cooperative advantage is relationships which are also the core of their organization’s purpose.

The value of human touch is often lost in AI automated interfaces, text messages, self- service applications and video demonstrations.   “People seeking financial service” as one consultant expressed, “do not visit branches, they visit bankers.”

Moments of Impact

Times’ writer Ron Lieber ends his review of virtual financial apps with the following story:

Davy Stevenson, the vice president of engineering at Hasura, which helps software developers more easily build applications using data, was an early neobank adopter herself. She experimented with the first versions of Simple, which no longer exists.

Today, she banks with her humble credit union. Though she pines a bit for the technical wizardry that her software developer brain knows the institution could deploy, she’s also happy with the way the people there treat her.

One CEO in his monthly staff updates includes examples of this member service advantage.  Here is a member comment from the July newsletter:

Dear (CEO’s name:)  (employees and cu name omitted)

Customers probably contact you when you when something goes wrong. Not this time. I wanted to let you know when your customers are given the best customer service, which is just what I received from the CU recently.

Two ladies I dealt with recently are the epitome of the great people on your staff. The first was J., and I apologize that I didn’t get her full name. J. was extremely knowledgeable in helping us transfer money to a friend living in England. She insisted on staying on the phone as I processed the transfer. She was so polite, helpful, and extremely efficient and I wanted you to know that!

Then, around the same time we were also processing a loan for an RV we were buying. M. B.  processed our loan so professionally and politely that I felt you needed to hear about her also. She instantly took care of everything and two old people are now ready to hit the road! Another great CU employee!

The Humble Credit Union

As long as members remain the mission, the future is secure.  Even when that future is increasingly enabled with Internet Retailing.

 

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Learning from the Past. . . or Not?

Franklin Delano Roosevelt, an adult victim of polio, founded the National Foundation for Infantile Paralysis, which he later renamed the March of Dimes Foundation, on January 3, 1938.  Those who survived the disease usually suffered from debilitating paralysis into their adult lives.

Since 1946, Franklin Delano Roosevelt, 32nd President of the United States, has been  the face on the dime coin  because of his drive to stop polio.

A President confronting a national epidemic and personal tragedy by  leading  efforts to cure polio.

 

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A Once In a Generation Opportunity for Credit Unions

NCAA rule changes and state laws that went into effect July 1 opened the door for college athletes to sell the rights to their names, images and likenesses (NIL) for the first time. Most importantly, earn income from these sponsorships.

This “NIL” marketing revolution for college athletes has taken off. Agents are offering their services. There are online courses to assist interested students learn about the possibilities.

Auburn quarterback Bo Nix has signed a deal with Milo’s Sweet Tea. Milo’s Sweet Tea is based in Bessemer, Ala., southwest of Birmingham.

Not to be outdone in the SEC, Coach Nick Saban announced that  Alabama  sophomore quarterback Bryce Young, who has yet to start a game in his career, has already signed deals using his name, image and likeness that are worth more than $800,000. He has been presented with deals well in excess of $1 million.

Fresno State’s basketball twin powerhouse, Hanna and Haley Cavinder, will be sponsored by Boost Mobile. The Cavinders have more than 5 million followers combined across all of their social media platforms.

And the Arby’s chain of sliced sandwiches are advertising to sponsor running backs in this tweet on July 1.

But why should college athletes be the only focus for marketing sponsorships? Can Credit unions take the NIL concept to the next level and promote their unique brand at the same time?  And gain the allegiance of the next generation of members?

Introducing Harper

Harper has newly arrived on the performance stage as you see by her picture. Nonetheless she is seeking sponsorship, obviously from a credit union.

Harper is open to offers that will include at least three benefits:

  • Credit union membership
  • A 529 plan for her educational options
  • A Roth IRA account for her retirement

She believes her image or likeness reinforce the idea that credit unions are family. Membership covers all stages and needs for life.

Her athletic and professional directions are yet to be fully defined. However she is willing to consider a long term relationship now that could pay enormous future benefits for sponsors.

She will consider granting exclusive territorial rights to her NIL so that marketers do not have to worry about competing against their own “branding” campaigns.

Instead of the uncertainty and brevity of a college athlete’s fame, Harper is offering a financial “put” on her ever-emerging NIL. That content should produce marketing images and stories for at least a generation.

For example: first toy, first steps, first birthday–documenting progress in all of life’s wonderful phases.

Interested credit unions, leagues, CUSOs or even vendors are welcome to contact Harper at this email: harperwinninger@gmail.com. Her “agents” are on standby.

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The Cost to Members of Overcapitalization

The concept of an “overcapitalization bias” in the credit union system was the topic of yesterday’s post.

One comment from financial consultant Mike Higgins showed how to calculate the cost-that is money taken from members’ pockets.  Here is his analysis:

I’d like to bring some specific concerns to the table for discussion on raising credit union capital.
The proposed regulation establishes a phased-in 10% net worth floor.  We all know that credit unions will carry a buffer to avoid going below the floor – most likely in the 1.0% to 2.0% of assets range.  So, the new net worth standard from a practical basis will be 11.0% to 12.0%.
This creates a huge safety reserve, before any consideration for CECL.  Recall that loan loss reserve is effectively net worth too, just specifically earmarked to cover anticipated loan losses.
For perspective, there are 600 credit unions with assets greater than $400 million that have net worth below 11% as of the 3/31/2021 call report.  I specifically included credit unions greater than $400 million because they will have to prepare for the higher capital standards as they approach the $500 million threshold.
The current low interest rate environment is making it difficult to accrete capital via asset growth.  This fact must be considered as part of the discussion.
Any net worth requirement is a tax on asset growth.  Raising the net worth requirement increases the growth tax.  For example, a credit union growing 10% per year with an 8% net worth target must produce a ROA (profit taken from members) of 0.80% to maintain its net worth ratio.  If the net worth requirement increases to 11%, that same credit union must now produce a 1.10% ROA.
Credit unions that cannot produce the higher ROA to support the new net worth target will have their ability to grow and serve new members stifled.  It will also make it more difficult to invest in the cooperative to maintain market relevance.
In a perverse twist, credit unions may have to take more risk because of the proposed regulation to produce the higher ROA necessary to maintain net worth.
Ultimately, a higher net worth requirement harms the people credit unions are designed to serve.
I am genuinely concerned this regulation is a gift to the competition because it erodes the advantages credit unions currently hold in the marketplace.  The concept of evaluating risk to determine necessary reserves, especially in outlier situations, is important, but I agree with Chairman Hood, it should be used as a tool and not a rule.
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The Overcapitalization of the Credit Union System

Twenty-five responses were filed responding to NCUA’s request for comments on the appropriate NOL cap for the NCUSIF.  One provided an insightful context for their remarks.

This excerpt from the Ohio Credit Union League  points out a larger industry bias.  This observation is especially relevant in view of NCUA’s proposal to raise the well capitalized standard for credit unions over $500 million in assets.  This new net worth option called CCULR, would raise the well capitalized compliance standard 43% in two years, from 7% to 10%.

Here is their partial comment:

. . .we wish to register a general objection to the notion of unnecessary over-capitalization of the credit union system wherever such an idea takes root. Except for a relatively small proportion of outliers, where ordinary supervision serves as an appropriate intervention, credit unions themselves are strongly capitalized to the extent that the primary buffer (natural-person credit union capital) against shocks to individual credit unions or the credit union system, is deep and broad.

Prior to the pandemic (December 2019) the average total capital ratios for U.S. and Ohio credit unions were 11.87% and 11.89%, respectively. As the pandemic began receding (March 2021), these metrics remain thoroughly robust (10.51% and 10.53%, respectively) despite the tremendous stresses of a global pandemic, global recession, and stimulus-driven ballooning balance sheets. The abundantly healthy capital levels and ratios in credit unions served the intended purpose quite effectively and in essence, shielded NCUSIF from material impact.

The regulatory process, perhaps beneficially, engenders a bias for more capital at the credit union level (seemingly, ever-stronger balances and ever-higher ratios). Yet this bias must be tempered by business discipline to ensure that capital balances in credit unions and in the NCUSIF remain strong but not excessive, so the various costs of capital are reasonable (even supportable).

To the extent that we witness what appears to be strong NCUA bias for more capital (unnecessarily larger balances and unnecessarily higher equity ratios) and noting the nexus of this concern to NOL strategy, we draw attention to the potential disruptive and costly over-capitalization of the credit union system at the credit union level, in NCUSIF, and particularly in combination. In this context we reiterate our call for the return of the NOL to its previous strong and proven level of 1.30%

Amen

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A Devastating Regulatory Burden- “The Juice is Not Worth the Squeeze”

(part 2 on NCUA’s new capital proposal)

The new capital proposal’s complexity and burden is evidenced in that eight senior staff were required at the board presentation. If the agency needed eight, how many senior credit union employees will have to be involved to respond and implement it?

The new rule is 126 pages on top of the 424 pages of the 2015 RBC rule. 530 pages in total.

This proposal imposes three different plans: the 110-year old simple leverage approach for credit unions below $500 million. For credit unions over $500 million, some will have a choice between the not implemented RBC or the new CCULR. An untold number would not qualify for CCULR under the reg, so they will be forced to use the untried RBC.

Mandating $24 Billion Addition to Restricted Reserves

The CCULR alternative raises the well-capitalized minimum to 9% on Jan 1, 2022, and 10% on Jan 1, 2024. The 117 credit unions below the 9% level would have just months to raise an estimated $3 billion to be at 9% or fall under RBC. No estimate was given for the net worth shortfall for these 117 at the 10% level.

The rule also states: Subordinated Debt would not be eligible for inclusion as capital under the CCULR framework unless the complex credit union is also a low-income designated credit union.

NCUA estimates complex credit unions eligible for CCULR must hold approximately $24 billion more as regulatory capital than the total under the RBC proposal. So why would a credit union not opt for RBC?

Regulatory Coercion

NCUA’s logic is that the “simpler” CCULR calculation will cause credit unions to opt for it since 48% of complex credit unions now have total net worth exceeding 10%.

NCUA offers this regulatory “alternative” for credit unions to avoid the burden and unknowns of RBC. All that is required is to reclassify 3% of assets now in net worth from unrestricted retained earnings to the rule-mandated legal reserves, a 43% increase.

Vice Chair Hauptman explained the tradeoff this way in his opening statement:

. . .all of that (prior wording) is an (admittedly long) way of saying that a simpler-yet-higher capital standard isn’t just useful because it saves time and effort. It’s also a way of protecting the system from the problems inherent in any risk-weighting process.

This is not choice, but regulatory blackmail. Here’s one example of how NCUA says this coercion will be applied:

While a qualifying complex credit union opting into the CCULR framework, is required to have a comprehensive written strategy for maintaining an appropriate level of capital, such strategy may be straightforward and minimally state how the credit union intends to comply with the CCULR framework, including minimum capital requirements and qualifying criteria. In contrast, complex credit unions that do not opt into the CCULR framework will be required to have a more detailed written strategy. The NCUA intends to review the written strategies during the supervisory process.

A Lack of Respect for Process and Credit Unions’ Track Record

Springing a completely new capital requirement to augment one that has yet to be tried with at best a 90-day implementation timeframe, is regulatory autocracy. It shows total disdain for credit unions’ proven record of capital management.

Throughout this rule there are many movable definitions and unexplained criteria. The definition for “complex” has no meaning other than asset size. Even that simplistic approach has moved from $50 million, then $100 million and finally to $500 million to define what “complex” means.

Using this superficial asset criteria, NCUA throws its complex blanket over every large credit union. Even the $5 billion State Farm FCU with minimal products would be included.

The proposal uses two different definitions of net worth in the numerator of the capital ratios: one for CCULR and a different one for RBC. (Page 49 proposal). Net worth means one thing and then another. This overturns GAAP accounting by whatever the regulator puts in rules.

Both capital options provide four ways to calculate average assets. This makes intra-industry comparisons at best uncertain.

Even the illusion of capital choice is incorrect. Credit unions can move from one capital plan to another within the same quarter in one part of the rule. However, in another section, NCUA can stop that. Under a new Reservation of Authority, NCUA can prevent a credit union going from one standard to the other.

Credit Unions’ Capital System Is Fundamentally Different from Banking Options

Banking regulators ended the RBC requirement in 2019. The rule requires only a simple tier 1 leverage ratio which is exactly the historically proven credit union practice for measuring capital adequacy.

NCUA has kept RBC and added another banking solution overlooking fundamental differences when comparing the two systems’ capital options and purpose.

The cooperatively funded NCUSIF can provide capital assistance if that is the best solution to address a problem.

This NCUSIF’s role supporting member owned cooperatives is very different from the FDIC’s. NCUA is authorized and has used capital injections and other support (208 guarantees) to return credit unions to self-sufficiency. The FDIC cannot assist privately owned firms to restore their financial solvency.

Banks have two primary equity sources: share capital and retained earnings. Generally, the two are split about 50/50. Bank equity comes in many forms: preferred shares, subordinated debt, public and private common equity. Moreover, there are different organizational structures: bank holding companies and stand alone to increase capital flexibility.

$1 of Credit Union Capital is Worth More than $1 of Bank Equity

Moreover, $1 of credit union retained earnings is much more valuable than $1of bank earnings. The taxation of bank earnings means that each firm must earn $1.25 to $1.50 to retain $1 in reserves. Also, shareholders expect to be paid dividends on their shares or see appreciation in their stocks’ market value.

Credit union capital is Free in all respects. All sources of bank capital have requirements that do not make them “free” when choosing options.

Action Needed Now

When Board Member Hood asked staff if the majority of credit unions opposed the 2015 final RBC rule, staff replied:

“Yes, a majority of the comment letters opposed the proposal in its entirety, and many suggested the rule be withdrawn.”

So why can this comment outcome be different? I think two factors can lead to the withdrawal of this rule:

  1. The rule lacks any data, objective criteria or historical analysis as the rationale for increasing the risk based net worth ratio. There is zero objective evidence for the rule.

When commenting, must show the history of their capital details to demonstrate the credit union’s record in managing risk. Include capital plans and other documents to demonstrate your competence.

  1. Hauptman and Hood are open to listening and learning. If they are to object to this dramatic extension of regulatory micromanagement, they must be armed with information to counter the unproven assumption that credit union capital is not sufficient.

Hood closed his Board meeting statement:

The world has changed since 2015. The reality is RBC should be a tool — not a rule. If it is effective in identifying risk, put it in the examiners’ toolbox, but the last thing the NCUA should do is impose it on credit unions as an operating model. The juice just isn’t worth the squeeze for risk-based capital because this is a regulatory burden with limited benefit. Again, we already have a risk-based net worth framework as required by law, so this is not needed.”

I would add one thought, what if there is no juice? How many credit unions faced with a 500-page new capital rule will just give up and close?

Credit unions rarely fail from too little capital. They fail because their leaders’ spirits are broken. This could be the final straw for many boards and managers.