From The Field...

"But, not you and me of course..."

"The problem with common sense is that  most folks are morons..."

Transparency...

News Item:  CFPB to Open Advisory Board and Council Meetings to Public

"In the face of growing criticism over its practice of conducting most of its Consumer Advisory Board, Community Bank Advisory Council, Credit Union Advisory Council, and Academic Research Council meetings behind closed doors, the CFPB announced last week that: " To provide more transparency and to be responsive to the requests we've received, we're changing the format of our Board and Council meetings and opening these full meetings to the public."

It was quite refreshing to note that an NCUA spokesman followed up almost immediately with:

"... a reaffirmation of our long-held policy of full transparency for all meetings of our Credit Union, Consumer, and Research Advisory Boards and Councils. NCUA's policy has been, and will continue to be, to never meet with these groups behind closed doors.  Transparency is a core value of our Agency."   

When asked when the next open meeting of one of NCUA's Advisory Boards or Councils was scheduled? The Agency spokesman said,....

Memorial Day...

North Carolina's WWII Memorial:

The U.S.S. North Carolina

Some things need to be honored in  a very large way....

Special Edition….

Yes, still do….very much !!!!

Downloading….

… and paperless transactions !
(…. that's Al Gore on the right.)

On The Wagon...

Credit Unions:
Alas,  in "Wonderland"...

"Well ! I guess that will ….

Implausible Deniability….

"Brace Yourself." 

The third Thursday of each month should be "hard-wired" into your credit union enterprise risk management (ERM) plan as periods of " code red, heightened risk alert".  Because on those Thursdays, it's highly probable that the NCUA Board will be meeting - as they are today. And of late, when the NCUA Board meets, the credit union movement is in jeopardy.

Playing with matches...

What makes today's NCUA Board Meeting (www.ncua.gov) of particular interest is the proposed risk-based capital (RBC) rule which has drawn a firestorm of controversy and criticism from over 1,000 inflamed commenters, and has attracted a Congressional call for review, signed by over 300 members of the U.S. House of Representatives.

Not sure that we Americans have seen that much unity (over 75%!) at any time, on any subject over the last dozen years! Even several Senators have openly expressed strong reservations about the NCUA RBC proposal.  Sen. Al Franken (D-MN) even went so far as to personally thank NCUA for all the free, ridiculous, comedy routine material, which he can put to good use, if he ever retires and returns to "Saturday Night Live"!

All the major CU trade associations, also, have asked that Chair Matz extend the "Comment Period" (ends May 28, regcomments @ncua. gov) or withdraw the proposed RBC rule entirely, until professional analyses can be conducted of the current and future consequences of the rule. All were reasonable, polite, responsible requests; all were promptly denied by the Chair -  without a vote, without recourse, without dialogue, without provision for appeal.

Careless and reckless?

The risk Ms Matz has created for the Agency is a "mini-Benghazi" crisis scenario. NCUA was careless and reckless in writing the RBC rule putting all CUs at risk. When advised of the massive risk exposure that has been created, the Chair has unilaterally refused to heed the calls for caution and greater protection; and, has so far heightened the risk by failing to act. The looming, threatening results of further inaction - much like Benghazi - appear painfully clear.

Refuse?

But today is the third Thursday of the month; the NCUA Board is meeting; Chair Matz can easily act to extend or withdraw the RBC rule … and provide the intelligent, prudent leadership response required to prevent this pending credit union "Benghazi" firefight….

If the Chair refuses again today, to act to safeguard America's credit unions from this crisis; then at least in the future, there will be no argument about the source of the problem and exactly…

Something Sphinx!

Am I the only one beginning to feel like an Egyptian?

OldeTowne Alexandria...

Lots of fear, loathing, and unrest out there on CU Main Street .... GAO scrutiny, catastrophic corporates, heavy assessments & million dollar fine threats, home-based CUs "are history", stress tests & RBC, and CU boards & staff as the new "criminal class", …. 

All fueled and fanned to an intense heat by an Agency, which continues to show a remarkable knack for running - full throttle - into brick walls.  Those  "Have you heard the latest one about NCUA ?" jokes are becoming a bit too easy, a bit too edgy, a bit too accurate.  

When did NCUA become a terrorist organization?

 And, why?

Can it really be true that the only people qualified to run a credit union, now all work for NCUA?  Or think they do?  Were most field examiners really rejected for prior employment at TSA for being "too hands on"?  Are we actually well past the "sell by" date with Agency senior management?  How can Duke Street continue to assume command, while continuing to deny responsibility?

Has an Agency which has never been famous for listening - nor hearing; willfully turned a stone-cold, deaf ear and a blind eye to the world beyond its own -  always self-flattering - vanity mirror?  Can NCUA - Mubarack like - no longer "be bothered" by the needs of the people?

It's very, very dangerous to be right these days when NCUA is wrong.  It is increasingly difficult to choose a consistent course when the Agency does not practice in the field what the Pharoahs preach in webinars  on high.  You can't much trust what the Agency says anymore until it's officially been denied.   It is difficult to get in step and to fall in line when we receive simultaneous commands to both advance and retreat.  The noblesse oblige is insufferable, as in the very latest…. 

"...would speak to an audience that doesn't exist."

 (NCUA, April 24, 2014) !!

Am I the only one beginning to feel like an Egyptian?  

Something Sphinx in Alexandria…

regcomments@ncua.gov  

(* You might like to know that this alarm was first published on 2/17/2011 and "progress" since that time "in Egypt" has meant starting to shoot those who have peacefully sought reform.... and also innocent bystanders.)

                                                                                                                                               

NCUA: A Clear And Present Danger...

A "Stalking Mule"?

Mentioned in a earlier post that the NCUA Stress Test Rule (for credit unions with assets over $10 billion) approved in April was "a stalking horse" for the upcoming NCUA risk-based capital (RBC) rule.  The stress test rule mandates a whole new cacophony of capital tests, "watch your A" forecast "stimulations", and a couple of "one just never knows", Nebraska tsunami-risk probability studies for larger credit unions.  

If you would like to know what's in store for you, your credit union, and your members with the new RBC rule; just spend a few minutes watching the April 24th NCUA Board Meeting video (at www.ncua.gov), particularly the Board/staff discussion of their justification and "logic", underlying the various components of the stress testing rule.

But if you are short on time and just way too busy to do anything of importance in your life today, then read this direct quote from the video [it occurs at minute 37:00]… 

"A Real Eye Opener…."

Mr. Metsger, Welcome to D.C. !!

Mr. Rick Metsger has arrived in Alexandria and has already begun to make his mark. As NCUA's newest Board member, many had high hopes for Mr. Metsger as "a fresh face", with actual first-hand, board leadership experience at a highly-regarded, Oregon credit union.  Well, the honeymoon, as they say, didn't last long.

Heather Anderson, the increasingly "Menckenesque" editor at CUTimes, reported on one of Mr. Metsger's initial appearances before a credit union audience - a NACUSO conference in Orlando.  "Nobody laughed at his jokes.  Nobody even cracked a smile.  And most importantly, nobody bought what he was selling." A follow-up panel of NCUA senior staffers was evidently equally effective and convincing….

Rants And Raves...

Mitchell News-Journal
(Home of the brave - and the brash!)

*  People who abuse animals should be abused in the same way.  

( That's certainly one thoughtful way to persuade people…)

*  Everyone pays taxes, but now we have to drive real slow.  

(Run that by me again…?)

*  Remember that "Nero fiddled while Spruce Pine burned". 

(The emperor did "bluegrass"!?)

*  I'm just glad that on Judgment Day that God will do the judging and not the folks who spout off in "Rants and Raves".  

(Speak of the Devil…!)

*  Absolutely right on the federal government takeover of healthcare, it's going to be great and they chose exactly the right name for what lies ahead - The Affordable Care Act.  

("Lies ahead"?)

And this week's "say no more" clincher...

The World's Best/Worst Joke? "One" More Time...

You're psychic!

The Dalai Lama walked into a pizza restaurant and was told before he could even ask…

NCUA RBC: You Don't Need A Weatherman...

"LOOK OUT KIDS DON'T MATTER WHAT YOU DID…"

(Hang with it; video takes a few secs to load…)

regcomments@ncua.gov

"… to know which way the wind blows."

From The Field...

"OK, OK but can you at least
handle the drive-thru?"

"Had a good bit of illness in the branch lately.  The worst case was Melanie Adams who came down with a staff infection…"

(That can be hard to overcome sometimes…)

Sooner Or Later...

Sage advice...

"I try to buy stock in businesses that are so wonderful that an idiot can run them.  Because sooner or later, one will."

- Warren Buffett

Strategic Planning For a Bear Market...

Best approach to
risk management?
… "play dead"?

Credit Union Boards and staff must now have a written plan for every eventuality… "risk" has recently been "discovered" by the powers that be and is their singular obsession de jour.  

We are very fortunate that our leaders in Alexandria have discovered this new concept of "risk", a concept of which most folks who work in credit unions were entirely unaware. 

Hard to imagine how lucky credit unions have been to have survived over the last 100 years - and especially since 2008 - without having known about "risk".  Understand that some of those "robust" folks who helped "discover risk" worked previously with Al Gore on the invention of the Internet; credit unions are indeed very, very fortunate … 

A "bear market" is the latest hysterical hissyfit, fully fueled with a forecast frenzy, from "the robusterians". Here are a few important safety tips…

NCUA RBC - You Don't Have To Live Like A Refugee!

  CREDIT UNIONS…

"… you don't have to live like a refugee!"

regcomments@ncua.gov

("… everybody's had to fight to be free.")

NCUA RBC - For What Its Worth….

"BETTER STOP CHILDREN…"

".… AND LOOK WHAT'S GOING DOWN."

regcomments@ncua.gov

("… it starts when you're always afraid.")

Bank On It !!…..

Absolutely Shocking !!!

Headline - Extra! Extra!: 

"The Multi-Trillion Dollar Bank of America Has A Little $4 Billion Problem…"

"If you're a bank executive, it's never going to be easy to tell your shareholders: Oops, we made a $4 billion mistake!"

 - Gretchen Morgenson (NYT - 5/4/2014)

Well, that's exactly what Brian Moynihan, the CEO of BOA - the largest bank in the U.S. by many measures,  had to do last week. Got any idea where and how the little $4 billion oversight occurred? Let's take a look:

"The issue concerned so-called structured notes.  If you don't know anything about these, you're in good company.  In short, these are hybrid securities that include different types of financial products - say, a stock or bond plus a derivative.  In the present case, according to the WSJ, the notes were bonds with set maturity dates paired with related derivatives."

Located across the street
from NCUA !
Alexandria, Va

"The purpose of commingling products [with derivatives] like this is to change the risk profile - that is, to make the underlying securities less risky and thereby increasing or decreasing potential returns." - The Motley Fool (4/30/2014)

As I recall, one federal regulatory agency has

Located across the street
from The Motley Fool !
Alexandria, Va

recently adopted a derivatives rule while frankly admitting that the agency didn't have the staff expertise to monitor and provide oversight of derivatives…

Contingency Planning….

What gives with "the finger"?

Several of you asked what the "Hope your finger's doing better." phrase meant in yesterday's blog. When a finger was mentioned as part of my interaction with the Agency,  many of you naturally assumed the worst. Well, that's not exactly what happened… let me explain.

First, let me acknowledge that Gerry Poliquin did call me back bright and early Monday morning. We had a very pleasant conversation about the process and procedures which NCUA uses for posting comment letters.  Mr. Poliquin was polite, informative and gracious.

Finger on the pulse of the Agency.

But by the time of his call, I had already "sniffed around" a bit in the back alleys and had received an "unofficial and confidential" rundown on NCUA's position.  You don't exactly have to be an Edward Snowden to "hack" into the NCUA "grapevine". Lot's of long-term, good-hearted folks at the Agency still willing to speak truth to power. 

Here's what I learned about NCUA's policy on posting comment letters:   They don't have one!

During several exchanges I heard a lot of explanations: "We do the best we can"; "We are a small Agency"; "We only have one webmaster"; "Usually every Thursday, but there is no set schedule"; "Sometimes it can take a couple of weeks"; "We don't have enough help"; "Gerry broke his finger"….

Which finger?
Never mind….

Guess I was a bit put-out by all those "explanations", but "Gerry broke his finger" kinda hit a nerve.  I asked if NCUA had a contingency plan for posting comment letters and I was advised that yes the plan was to get the comments posted when Gerry got back.  Which I guess, in a weird, twisted sort of way, does make some sense. 

No policy, no consistency, no backup, no contingency plan… but know what really got the tighty-whiteys in a wad?

Hope It's Not "Caller ID"…..

Mr. Gerard Poliquin
NCUA, Secretary to the Board
1775 Duke Street
Alexandria, Va. 22314

Looks like "snail" may be fastest !

Ref:  Commenting on Proposed Risk-Based Capital (RBC) Rule

Dear Gerry,

Called you last week and left you a message.  Wanted to ask you a question about NCUA's policy governing commenting on proposed rules; but I never heard back from you.

Actually, I tried to call several very important folks at NCUA, but all I found out was that everybody at NCUA has voicemail. Guess you were all out "regulating".  Hope it was that; and not that you have "caller ID".  (Just kidding!… sorta.)

My question was:  "What is NCUA's official policy on posting comment letters in a timely manner?"  The reason I ask is that there has started to be a lot of grumbling that NCUA is purposefully delaying the posting of comment letters on the new RBC rule.

I would imagine that's not true, but thought it best to ask.  As always, you just can't count on the Post Office delivering those emails to you in a timely fashion. Been a lot of " snow, rain, heat, and gloom of night" out there on the internet of late, so delays can happen! Realize that the law requires you to post the comment letters "as submitted", but could you let us all know what the law means or what you've decided it means, if you know what I mean.

It's kinda important since everybody and his sister is up in arms about the RBC rule and are being urged to send you a comment… or worse!

And, even though the Chair has adamantly refused to extend the comment period, we all know she's listening and already knows what's best; so getting those comment letters posted quickly really can't hurt, can it?

If you're real busy regulating; you could just drop me a comment on this blog, if you like.  Hope your finger's doing better.

Sincerely,

Jim Blaine

May The Fowlth ...

Cuatro de Mayo:
"It was quite a party… !"

"Bach, Bach…."

Q:  Who's there?

A:  A classical chicken...

Did you know that May 4th is International Respect for Chickens Day (IRCD - pronounced "irk-ed")?  Well, you do now! Go ahead and add it to your Outlook calendar before you forget it.    ("IRCD, IRCD…"  Q: Who's there?  A: One mad, "p.o.'d" chicken…!)

Many people say, despite what you've heard,

Might be able to pass for a poodle...

that chickens are "a man's best friend"
( Disclaimer: not of course meant to be too gender specific, undiverse, imply any disrespect for dogs, nor indicate any support for the LA Clippers).  Not sure who came up with that idea, nor how they arrived at it; but, suspect that it comes from the fact that you generally don't have "to walk" chickens.  Which is a good thing… 'cause you'd look pretty silly walking a chicken, wouldn't you.

"No, we're not going to do
 an Easter egg hunt…!

Chickens do raise some difficult issues though.  There is always that mind-numbing question of : "Which came first?  The chicken or the egg?"(Probably need to ask your local school board to clarify their policy on teaching this "fundamental creation question" in your hometown schools). Personally, I can picture both sides on that issue; assuming, of course, that an egg has a side…

"Cross"-moi !?!  I'm not
"the problem" , honey...

The other question which people always ask is:  "Why did the chicken cross the road?" Never have understood why folks found that one to be so difficult.  Believe they try to over-think it, make it too complex, or simply don't get out enough in the real world.

If you live outside the city or have ever driven around in the countryside a bit, you know exactly why a chicken crosses the road...

Only In North Carolina….

Banzai !

FROM THE TAYLORSVILLE TIMES:

"An airplane landing at the Taylorsville airport collided with a man and a lawn mower on the ground according to authorities.  The incident was reported about 12:30 Saturday afternoon…"

(Betcha this doesn't happen often at O'Hare, LaGuardia, or LAX….)

(P.S. Unfortunately, the man was killed; he is no mow.)

From the Field...

"I think the one on the right
is real cute…"

"The Town held its Annual Turkey Festival and several employees helped to judge the contestants."

(Wonder what the trophy said…?)

Feng Shui for Fang Slay......

First, don't get rattled
or become hissterical!

Q :  What's the proper way to harmoniously kill a poisonous snake?