Matz Answers Reputation Risk Query
In response to questions raised by an investigation into the FDIC’s Operation Choke Point, NCUA Board Chairman Debbie Matz said the NCUA does not directly consider reputation risk in its supervisory actions.
“NCUA does evaluate seven key risks to evaluate a credit union’s overall risk under the CAMEL rating system. Four of the key risks – reputation risk, along with transaction risk, strategic risk and compliance risk – are difficult to quantify,” Matz wrote to House Financial Services Chairman Jeb Hensarling in a letter dated June 12.
“Nonetheless, we identify objective qualitative assessment factors that may be used to measure a qualitative risk level in each of the above-mentioned risks. (The) NCUA expects examiners to consider current and prospective performance indicators, both quantitative and qualitative, in forming their conclusions about CAMEL ratings,” she added.
“Under the CAMELS supervisory framework, reputation risk is not a standalone indicator that, on its own, can warrant a recommendation by your agency that a depository institution cease providing a particular product or serve,” he wrote.
Matz told Hensarling qualitative factors could lead to high levels of reputation risk.
“However, NCUA does not force an institution to change its business practices simply on a reputation risk matter. We instead would address the underlying unsafe and unsound condition contributing to the reputation risk concern,” Matz wrote.
The Operation Choke Point initiative was made public after a payday lender and payday lending trade association sued banking regulators, claiming they had pressured banks into cutting off their services by citing reputation risk as an exam exception.