Wednesday, July 23, 2014

Analyzing The Chances For A Second RBC Comment Period...

Have some late breaking good news! 

We're colorful !!
The "Crayola economists" over at the Agency have issued a new forecast on the likelihood that Chairman Matz will be reasonable and permit a second comment period on the proposed risk-based capital (RBC) rule!
... see!

Their latest forecast used the very same "robust", quantitative methods applied by NCUA when formulating the RBC rule - and those "risk weights"!  Based on those precise, exacting techniques; the Office of the Chief Economist, in conjunction with E&I and the Capital Markets group, predicts that Chairman Matz will change her mind when...

RBC Listening Sessions: "Hammer" Time...

Second comment period !!
"For those of you who kept asking and asking for a second comment period at the listening sessions; not quite sure what part of "no" you don't understand !!??!"  

"'Cause hey, I told you! Why yah standin' there?? Yo sound the bell, man; school is in, sucker; now listen up homeboys... Let me "break it down" for you on another comment period, YOU... "

Tuesday, July 22, 2014

NCUA Uses the GAO To Weasel Representative McHenry...

This is going to be a doozy
of a hearing - under oath! 

NCUA apparently has absolutely no fear (and perhaps no respect!) for members of Congress - or perhaps the noblesse oblige applies just to Representative Patrick McHenry (R-NC).  Let's take another quick look at Chairman Matz's response letter of 7/18/2014 (here's  the link) to Rep. McHenry:

From page 4, paragraph 2:

"NCUA also proposed retaining the tiered risk-weighting approach in the current risk-based rule to account for the risk associated with credit unions holding higher concentrations of member business loans and mortgage loans. Maintaining the tier risk-weighting approach is consistent with a 2012 report by the General Accountability Office [GAO], which specifically recommended the NCUA address such concentration risk. Similarly, NCUA proposed maintaining the tiered risk-weighting approach in the current rule for long term investments in order to account for interest rate risk and liquidity risk."

Da Drop !
The NCUA has an unseemly tendency to "name drop" highly reputable agencies to enhance its less than stellar credibility, and to justify its own arbitrary actions  by insinuating other agency support. Let's take a closer look at exactly what the GAO said in that 2012 report (Here's the link to GAO - 12 - 247)....

Monday, July 21, 2014

The Response To Representative McHenry: Somebody Appears to Be Lying...

This could get interesting -
under oath!
As you know Representative Patrick McHenry (R-NC), who sits on the House Financial Services Committee, wrote to Chairman Matz on July 7, 2014 asking for an explanation of the many "anomalies" (nicest word I could come up with!), which surround the proposed NCUA risk-based capital (RBC) rule.  Here's a link to Representative McHenry's letter to Chairman Matz.

Representative McHenry asked for a response by July 18, 2014 from Chairman Matz about the issues he had raised Here's a link to Chairman Matz's letter of response.

Would like to call your attention to the 4th and last paragraphs on page 5 of Chairman Matz's letter which read as follows:

"Individual Minimum Capital Requirements"

"The proposed rule includes a provision that permits the NCUA Board (not any individual examiner) to require a higher minimum capital ratio for an individual credit union in an extraordinary case where the circumstances indicate that a higher risk-based capital requirement is appropriate.  The proposed rule also sets forth specific due process procedures that NCUA must follow before issuing an individual minimum capital requirement, including prior notice and a right of appeal." (paragraph 4, page 5)

"While it is the examiner's duty to recommend, through the chain of command, the imposition of an individual minimum capital requirement, if one is necessary, nothing in the proposed rule would authorize an examiner to take such action directly. Thus, this authority would be reserved solely for the NCUA Board." (last paragraph, page 5)

Having read Chairman Matz's response to Congress, would like to draw your attention to the actual verbatim language of the proposed RBC rule as published in the Federal Register (Vol. 79, No. 39, pg. 11207 - Feb. 27, 2014)....

Sunday, July 20, 2014

From The Field...

"Eat Mor Chikin"

"We held our first Advisory Board B-B-Q supper.  It was terrific! We are ready to meat again..."

( Pig-out...!!)

Friday, July 18, 2014

Thursday, July 17, 2014

Listening Sessions: Alexandria - Wrap Up...

Thanks so much for coming!
How did you feel about our responses!!???

Listening Sessions: Alexandria - Not Phased At All By That Argument...

The phases of
the loon...??

"The inane RBC rule which has embarrassed us all profoundly appears to just be a ....."

Listening Sessions: Alexandria - IMCR...

"As to your concern about "individual minimum capital requirements"(IMCR), we just don't understand where this great distrust of the Agency comes from! You know we are fair, reasonable people who have your best interests at heart."

"We're open, we're transparent, we're accountable."  

"Besides the individual examiner will not be making these decisions; the IMCR will be made by me us at the Board and you can always appeal a bad decision to me us.  Why don't you just..."