|"Mama don't bluff..."|
While we wait on that decision, we need to look at the other NCUA staff "strategic error" which is misleading the NCUA Board into thinking that America's credit unions must cough-up $300 to $600 million in 2017 to prop up the NCUSIF. The first problem, of course, is the recent, incomprehensible long-term investing "snafu". The second serious problem is the 5-yr forecast of the NCUSIF equity level presented by staff to the NCUA Board on November 17, 2016 (here's the link).
Look at pages 11 and 12 of the power point. Page 11 gives you the NCUA's objectives in forecasting the equity level of the NCUSIF, only one of which is required by law (The Federal Credit Union Act - "1782(c)(2)(D)") [here's that link - pg. 26... on the right]. The FCUA requires the NCUA Board to act (say with a $300/600 million assessment!) only when the forecast projects the equity ratio to fall over the next 6 months below 1.20% - not 1.30%! All else is discretionary for the NCUA Board...
Page 12 shows you the four forecasting model inputs: future 1) interest rates, 2) insurance losses, 3) CU asset growth, and 4) growth in the NCUA operating budget. All you need to look at is the "interest rate inputs" - they are neither probable nor supportable, and appear to be intentionally misleading... purposefully driving the NCUSIF equity ratio "into a ditch" - and potentially costing you and your members hundreds of millions of dollars in 2017.
The Board's answer may cost credit union members $300 million - is it well-reasoned?
ACCOUNTABILITY - COMPETENCE - TRANSPARENCY