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....