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NCUA UPDATE Utah Credit Union Association Chairman/CEO Summit October 25, 2013 PowerPoint Presentation
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NCUA UPDATE Utah Credit Union Association Chairman/CEO Summit October 25, 2013
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  1. Elizabeth A. Whitehead NCUA Region V Director NCUA UPDATEUtah Credit Union AssociationChairman/CEO SummitOctober 25, 2013

  2. Agenda Financial Trends Risks on the Horizon Examinations, What to Expect Regulations Questions NCUA Update

  3. Success Story: Credit Union Industry’s Recovery Positive Trends in U.S. Credit Unions 2010 – 2013 3RD Qtr. 2012 Year-End 2009 Year-End 2010 3

  4. Your Story: Utah Credit Unions’ Performance Trends in Utah Credit Unions Compared to U.S. Credit Unions 3RD Qtr. 2012 Year-End 2009 Year-End 2010

  5. Risks on the Horizon • Interest Rate Risk • Third-Party Risks • Cyber-Security Threats • Off-Balance Sheet Risks NCUA Update

  6. 6

  7. Third-Party Risks 7

  8. Cyber-Security Threats • Distributed Denial-of-Service Attacks • Web Application Attacks • Computer Malware • Social Engineering Attacks NCUA Update

  9. Cyber-Security Fraud • Account Takeovers • Unauthorized Funds Transfers • Credit/Debit/ATM Card Fraud • Identify Theft NCUA Update

  10. Off-Balance Sheet Risks • Executive Benefits and Pension Plans • High-Risk, Non-Compliant Investments • Money Service Businesses NCUA Update

  11. Managing Risk Risk comes from not knowing what you’re doing. Warren Buffet NCUA Update

  12. Interest Rate Risk Interest Rate and Liquidity Long Term Assets, Short Term Funding Earnings at Risk When Rates Rise Contingency Funding Arrangements - Interagency Policy Statement on Funding and Liquidity Risk Management OTS-2010-0005 Letters to Credit Unions (4): - 00-CU-13, 01-CU-08, 03-CU-11, 10-CU-14 All references available at NCUA Update

  13. Interest Rate Risk • What is likely to happen when rates rise • Rate will impact share rates faster and deeper than past cycles: • Either liquidity will drain (if you don’t price competitively) Or • Costs to maintain stable funding will rise faster than in the past • Asset yield will increase at a slower rate than in the past for Real Estate/Long Term laden balance sheets. • Yield increases will be incremental and may not keep pace with cost of funds • Rapid or sustained rate rises can overwhelm tight margins. • Declining margins and cyclically worsening ROAA • Declining liquid assets/liquidity – possibly triggering events in some credit unions NCUA Update

  14. Balance Sheet Risk Poor IRR Management – Slow Heart Attack Poor Liquidity Management – Blunt Trauma • Gradual Decline in ROAA • Tightening Liquidity • Eventual losses • Eventual Depletion of Capital • Insolvency • Rapid outflows/insufficient inflows • Insufficient contingent liquidity • Sale/liquidation of less liquid underwater investments • Depletion of capital • Inability to meet current obligations (bankruptcy) NCUA Update

  15. Interest Rate Risk What are the Regulatory Requirements? NCUA Rules and Regulations §741.3(b)(5) outlines requirements for a written interest rate risk policy and an effective interest rate risk management program. NCUA Rules and Regulations Part 741 Appendix B provides Guidance for an IRR Policy and effective program. NCUA Update

  16. Interest Rate Risk • What you can expect examiners to evaluate • Policies, procedures, decision support and internal controls consistent with sophistication, and depth/level of potential exposure. • Examiners will challenge your preparedness • Strong policies consistent with size, sophistication, exposure level • Make sure you can support your assumptions • Don’t try to pass a standard set of assumptions as yours. • Whatever the assumptions are they need to tie back to your organization. • Ensure full disclosure all the way up the line • Testing, validation and internal controls around the process • Challenge yourself – How wide or narrow is your safe operating range? • How critical is your non-maturity deposit assumption? • Will you survive an error in your assumptions? NCUA Update

  17. Improving Consistency • Use of Documents of Resolution (DORs) • National Supervision Policy Manual • CU Online provides District Examiner and Supervisory Examiner Contact Info • Pre-Examination Letter • Report Cover Letter provides info on formal and informal appeal options NCUA Update

  18. Examination Report Modernization Document of Resolution and Examiner’s Findings - Stand Alone Documents Only material problems in DORs with agreed-upon corrective actions and time frames Examiner’s Findings – less urgent problems that need to be corrected in the normal course of business Informal Discussion Document eliminated NCUA Update

  19. Examination Report Modernization Overview – CAMEL and risk ratings, high level discussion on CU’s risk profile, financial trends and progress correcting prior items Supplementary Facts – additional information, recommendations Status Update (new) – compliance with LUAs, PWLs. NCUA Update

  20. Examination Report Modernization Streamlined Examination Report Better clarifies priority exam action items to be resolved Reduces redundancy Ensures consistency NCUA Letter to CUs 13-CU-09 NCUA Update

  21. 10 Things Your Examiner Will Like to See Good Risk Management fosters vigilance in times of calm and instills discipline in times of crisis. Dr. Michael Ong • Commitment to make tough choices. • Forward looking strategy. • Well developed and integrated risk management. • Balanced appetite for risk. • Incentives aligned with sustainable risk levels (Taking a long term strategic view). • Continuous monitoring and strong comprehensive reporting regime (Good, Bad or Ugly). • Strong control environment. • Balanced portfolio and portfolio strategy. • Equal weight to the downside risks in the decision making process. • Optimal capital deployment (Scaled to level of risk and no over-reliance). NCUA Update

  22. Resource Reminders AIRES Questionnaires NCUA Update

  23. Recent Regulations • Loan Participation Rule RR 701.22 & 741.225 • Effective September 23, 2013 • Originating CU keeps at least 10% ownership • Purchasing CU empowered to grant loan type • Loan complies with all regulatory requirements • Written loan participation agreement • Borrower is a member of originating or purchasing CU • Has a written participation policy • Limit at the > of $5 million or 100% net worth • Waivers NCUA Update

  24. Proposed Rules Outstanding • Proposed Rule Authorizing Charitable Donations • Parts 703 and 721 • Comment Period Ends October 21, 2013 • NCUA’s Minority Depository Institution Preservation Program • IRPS 13-1 • ANPR Comment Period Ended August 30, 2013 • Maintaining Access to Emergency Liquidity • Part 741 • Comment Period Ended September 2012 NCUA Update

  25. Proposed Rules Outstanding • Financial Derivatives Transactions to Offset Interest Rate Risk • Part 703 • ANPR Comment Period Ended April 2012 • Credit Union Service Organizations (CUSOs) • Part 712 and 741 • Comment Period Ended February 2012 • Proposal on Filing Financial and Other Reports - Parts 741 and 748 - Comment Period Ended August 26, 2013 NCUA Update

  26. Office Contact Page Feel free to contact our office with questions or comments. Primary Staff: NCUA Region V (602) 302-6000 Secondary Staff: Mike Dyer, Associate Regional Director – Programs (602) 302-6003 NCUA Update