Wednesday, February 11, 2015

Telling A Larry....

"I Wanna Testify...!"
The Parliaments (1967)
(...almost as good as
The Castaways!)

Really hate to be interrupted while reading the 450-page RBC rule draft (By the way, how you doing with your reading? You are reading it, aren't you?); but Larry Fazio from the NCUA was up before Congress today telling the truth - at least as NCUA sees it, which is often through a very narrow lens, backed up by some tightly closed minds.

But when NCUA testifies before Congress about how it is working hard to relieve the regulatory burden for credit unions; well, what can one say... which can be printed on a civil blog, in a polite manner?  Here's a link to the text: Larry Fazio Before Congress - 2/10/2015.

Mr. Larry Fazio
Burial complex?
NCUA has developed a strong reputation for having "a burial complex" in its proclamations, which simply means that you must start at the end or dig through the footnotes to find out what the Agency is really up to... they save the worst for last!

"Male cow stuff..."
So, true to form, after you have waded through a lot of "male cow stuff" in the testimony; on the next to last page (pg. 14) down at the bottom and in footnote #29, Mr. Fazio finally reveals what NCUA really wants (wags call this..."Telling a larry"!):

Priority #1 and  #2!
"Finally, and most critically, NCUA requests... examination and enforcement authority over third-party vendors....  Obtaining this authority is the agency's top legislative priority."**

** Then in footnote #29: "NCUA has two other legislative priorities.  The second priority would permit NCUA to charge risk-based premiums for the Share Insurance Fund." And the last priority is to improve the CLF.

Not sure about you, but don't see how "NCUA's priorities" will help reduce regulatory burden on small credit unions...

But, if you liked NCUA's ineptness and lack of balance in dealing with the risk-based capital (RBC) rule, then you're going to have a really fine time with NCUA's imperial (spelled "empirical" by the "robusterian" heads-of-point!) caprice in managing NCUSIF risk-based insurance premiums (RIPs). 

RIPs will cost your members real money!

(... and that's no larry!)


Anonymous said...

Digger O'Dell would proud of how Lying Larry buried the information.

Anonymous said...


I have found value in the RBC rule. I could not reach the top shelf of my pantry so I stood on the document and found success.

Does Fazio really understand cost benefit analysis? NCUA has yet to be right on any cost estimate.

Third party vendor authority? Don't worry, be happy. It's DOA.

Advances for credit unions with CLF, MBL, FOM and FAI. Rather the talk, let's see the meat.

Small credit unions $100M? Let's quit playing games and get it to $250M where it should be.