The 2012 Temporary Corporate Credit Union Stabilization Fund assessment of 9.5 basis points of insured shares will reduce annualized return on average assets for federally insured credit unions an estimated 8 basis points industry wide, to 0.81%, the NCUA said during its monthly board meeting July 24.
Credit unions with less than $10 million in assets will be affected the most, with aggregate ROA falling from 0.07% to negative 0.01%. Credit unions with $10 million to $100 million in assets will fall to 0.36% ROA, and the $100 million and up peer group will see their annualized ROA fall to 0.88%.
The assessment will also cause 335 federally insured credit unions to experience negative core income solely due to the assessment. Additionally, 46 credit unions are expected drop below 7% net worth, subjecting them to the earnings retention requirement of prompt corrective action.
Fifteen credit unions will drop below 6% net worth, which will require them to prepare a net worth restoration plan, and one credit union’s net worth will fall below 2%.
The total 2012 assessment will be $790.53 million. Assessments were $337.4 million in 2009, $999.6 million in 2010 and $1.96 billion last year. Assessment payments will be due Oct. 9. Credit unions should expense the assessment in August and report the entire expense on their Sept. 30 Call Reports, the agency said. The estimated 2013 corporate assessment will be announced in November, said Larry Fazio, director of the NCUA’s Office of Examination and Insurance.
The money will be used to fund repayment of corporate credit union liabilities–their legacy assets–and this assessment brings to $4.08 billion the amount of corporate system resolution funds paid by credit unions since 2009, the board said.
The 2012 assessment closes the door on medium-term NCUA Guaranteed Notes that resecuritized corporate legacy assets. The two remaining notes mature in October 2012 and November 2012 and will require approximately $3.5 billion in payments to investors. In addition to the $790.5 million 2012 assessment, the TCCUSF will have to borrow $1.87 billion from the Treasury.
Fazio said the cash flow requirements for legacy assets will reach a high point in 2012, and future assessments will be used primarily to pay off Treasury borrowings and any losses that exceed estimates on remaining NGNs. After the NGNs mature this fall, the TCCUSF will owe the U.S. Treasury $5.1 billion.
The NCUA has seen such an increase in state-chartered federally insured credit unions with assets between $250 million and $500 million showing “some degree of financial stress,” it has lowered the threshold for joint exams from $500 million to $250 million. As a result, the time NCUA examiners spend participating in joint exams has nearly doubled to 120,000 hours per year, NCUA Staff Attorney Steve Widerman told the board.
Hence. the NCUA’s proposed rule to allow the federal regulator to declare a state-chartered credit union in “troubled condition,” a regulatory privilege that is currently only granted to state regulators. The rule is designed to guard against ratings discrepancies to better protect the share insurance fund, the NCUA said.
The proposed rule would define a state-chartered federally insured natural person or corporate credit union as troubled if either the state regulator or federal regulator assigns it a CAMEL or CRIS code of 4 or 5 in either the financial risk or risk management categories.
U.S. Central FCU is such a key player in providing Central Liquidity Facility access to credit unions, once the corporate is closed in October and its CLF stock is redeemed, the CLF’s subscribed capital stock and surplus–and therefore, borrowing capacity–will drop 96%, Fazio said. He was explaining the need for the meeting’s second proposed rule that would require all federally insured credit unions with more than $10 million in assets to develop an emergency liquidity plan. Additionally, those with more than $100 million in assets much establish their own ability to borrow from the CLF or Federal Reserve.
The NCUA will produce an informational webinar for credit unions on the CLF and the proposed liquidity rule Aug. 14.
Corporate credit unions may facilitate CLF membership for its members by performing such services as assisting with credit applications, serving as a collateral custodian and administrator and assisting with credit reporting requirements. However, credit unions would still be responsible for subscribing to CLF stock in an amount not less than one half of 1% of the credit union’s unimpaired capital and surplus.
Corporates may also serve as a CLF agent as U.S. Central did, but the institution must subscribe to CLF stock for all of its members that aren’t regular CLF members.
The board said it is also exploring whether certain Basel III liquidity measures and monitoring tools should be incorporated into NCUA’s supervisory expectations for credit unions with more than $500 million in assets. Basel III’s proposed standards could include the use of a liquidity coverage ratio and a net stable funding ratio, as well as liquidity monitoring tools to track maturity mismatches on the balance sheet, funding concentrations and the amount of unencumbered assets available for secured borrowing.
“These measures and monitoring tools are designed to enhance the liquidity risk management framework and improve the banking sector’s ability to absorb shocks arising from financial and economic stress,” the NCUA Board said in its memo.
The board also approved an adjustment to the NCUA’s 2012 operating budget during its board meeting last week that will apply $2 million in savings to the 2013 budget. The revised 2012 annual operating budget is $234,854,336.
Despite total staffing increasing by two full time positions, the $2 million savings was realized in employee pay and benefits, which had a net decrease of $3.67 million. That was offset by a net increase in contracted services of $997,900, which included the transfer of $700,000 worth of pay and benefits to contracted services in the Office of Chief Information Officer, and an additional $120,000 to purchase software required to address Government Accountability Office findings.
Additional actions included the reauthorization of the 18% interest rate loan ceiling through March 2014, the approval of the quarterly insurance fund report, and the approval of a $2 million reduction in the NCUA’s operating budget for 2012 and a board briefing regarding an interagency proposal regarding mortgage appraisals.