The memo offering details of life after U.S. Central Bridge came out of the NCUA with a bland title, “Fact Sheet APEX-ACH Transition.” But as it has circulated, it has triggered a large question among some corporate credit union executives: Which government body is steering this effort, NCUA or the Federal Reserve?
The stated purpose of the document, distributed to CEOs of corporate credit unions, is to offer detailed guidelines to corporate credit unions as they prepare their exit strategies for leaving U.S. Central Bridge, due to be filed with NCUA no later than Feb. 24.
But hidden in the message, some corporates executives believe, is a ceding of control of the process by NCUA to the Fed.
The document itself shines a bright spotlight on the Fed.
NCUA’s Office of Corporate Credit Unions “is working closely with the Federal Reserve Banks (FRB) to coordinate the APEX-ACH transition. The FRB has provided the names and contact information for ACH operational contacts who will be available to representatives of U.S. Central Bridge and all corporates that are making changes due to the wind-down of APEX-ACH. The FRB has indicated their willingness to address questions or concerns that corporates may have during the transition process.”
One corporate credit union CEO offered his blunt analysis.
“We were just visited by a Fed staff member who let us know that the Fed was overseeing this APEX conversion project. It is unprecedented in my career to see the Fed take charge of a credit union project. NCUA will spin this as coordinating closely with the Fed, but reading between the lines, I see the Fed taking control of this conversion because they don’t have faith in NCUA to not disrupt the payment systems.”
Another senior executive at a corporate indicated that the Fed is deeply involved because so much is at stake. By his estimate, some 2,000 natural person credit unions, operating through their corporates, process payments through U.S. Central Bridge and that large number of institutions now needs to get in a queue to set up processing through the Fed.
The NCUA, through Public Affairs Specialist John Zimmerman, responded that “as a courtesy, and given the Fed’s role in the nation’s payments system, we keep them abreast of our actions.”
He added, “As noted in the fact sheet, NCUA’s Office of Corporate Credit Unions has and is working closely with the Federal Reserve Banks to best coordinate the APEX-ACH transition. Given the Fed's importance in the payments system, we believe our many contacts with them will accrue benefits to corporate credit unions as new relationships are established.”
The document that triggered this dust-up is a dense, four-page memo. The document’s purpose, to quote from the document itself , is to “detail various aspects relating to vendor due diligence for CCUs [corporate credit unions] and relevant timelines and considerations for member CCUs” as those institutions transition out of U.S. Central Bridge, the failed Kansas corporate the NCUA has indicated it plans to shut down by year-end.
The memo also noted, “The transition of payment systems requires specific managerial steps: risk assessment, vendor selection, due diligence, project planning and monitoring. To assist CCUs with executing sound transitions, we have attached guidance on project management and diligence in addition to referencing relevant letters to credit unions. This information should serve as a refresher for those who have not participated or managed a payment systems transition project recently.”