Several credit unions are reviewing or have announced intentions to convert to bank charters. Those CUs which leave the NCUSIF are apparently not currently required to pay their share of the "$15 billion bill" for the Corporates.
The more CUs who choose to leave, the higher "the bill" for those who remain! At some point, this opportunity to "get out of jail free" may become a dangerous game of "musical chairs" with Boards and CEOs who "do the honorable thing" being bankrupted by their amoral peers.
Does NCUA have the authority to require an NCUSIF "exit fee" on departing CUs?
If so, the exit fee should be announced to help CUs plan, who are contemplating a conversion. If not, when will NCUA propose regulation or legislation to correct this issue of injustice and fairness?
If NCUA is truly intent on helping CUs manage "risks", they should have no higher priority.
If NCUA can't "manage" this very, real threat; be prepared for a new look on Duke Street in the near future...
"Perfection of means and confusion of goals seem, in my opinion, to characterize our era." *
- Albert Einstein
*Translation: In American finance, we have moved from a system of "Caveat emptor!" ("Buyer beware!") to a system of "Caveat *x#*|*!" ("Buyer be *x#*|*!") ...... "CASH" seems to be the only "value system" which now guides professional financial behavior.
The NCUA, over the last two decades, centrally (out of Alexandria) managed, monitored, regulated, and examined the national system of Corporate credit unions. The NCUA had a special, separate department - the Office of Corporate Credit Unions - within the Agency, which employed its "best and brightest", its most highly skilled examiners - "capital market specialists". Those capital market specialists were hired for their acclaimed expertise in ALM modeling, economic forecasting, interest rate risk analysis, securitization and derivatives, and for their well-seasoned, strategic vision and insight.
The NCUA, through the Office of Corporate Credit Unions and these capital market specialists, examined the Corporates on an annual basis and even housed its capital markets experts within several, specific Corporates. Those experts continually rated the Corporate System highly - safe and sound.
We all believed those firm assurances from the NCUA .... they were in there, on the ground, in the trenches with experts, specialists .... and the experts' opinions were highly favorable, supportive.
In retrospect, this expert advice was very expensive (last count about $15 billion); and the Alexandrian, central management model was, in the final analysis, ....
Comment Letters to NCUA on the recently proposed, expanded Interest Rate Risk (IRR) regulation have now been posted on the NCUA website.
NCUA encouraged you to write Comment Letters; I would encourage you to read them!
Here's how: 1) Go to www.ncua.gov; 2) Click on "Resources and Publications"; 3) Go to "Legal ... Regulation, Legal Opinions, and Laws"; 5) Then, "Proposed Regulations"; look for "Interest Rate Risk" and click on "Comments".
You'll have almost 50 Comment letters to choose from - stay informed, happy reading!
If by chance you do not have time to read through the whole list; I have attached below, a very brief overview of the opinions expressed on the most likely impact of providing NCUA with additional IRR authority....