|Not much help...|
But in the short run, if the NCUA Board would like to save an easy $5 million+ bucks annually...
... simply drop the stress-testing and "capital planning" review required of those CU's over $10 billion in assets.
It is not required by law nor regulation and NCUA is paying $5 million annually to outside consultants (Blackrock) do perform the analyses - that would be a $25 million+ savings over the 5 year budget cycle!). NCUA senior staff acknowledges - very accurately and truthfully! - that they don't have the technical ability to perform these analyses!
Daniel Tarullo at the Fed, Barney Frank of Dodd-Frank fame, Jeb Hensarling in Congress, etc, etc all have agreed that the minimum asset hurdle for this exercise should have been set at $250 billion+.
The NCUA Board could independently act on
this budget savings at its December board meeting - and save $25 million to be used to retrain its own staff appropriately [NTEU are you paying attention?] to do this type of analysis in house in the future.
|You can do it!|
Would be a nice $25 million X-mas present for CUs!
ACCOUNTABILITY - COMPETENCY - TRANSPARENCY
[You said you wanted some real budget advice!... so ACT!]