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The Federal Reserve Bank’s fed funds target has not changed for seven years, keeping rates low for an unprecedented time. Simultaneously, consumers moved billions into the deposit accounts of banks and credit unions while credit unions added record levels of long-term assets (see the accompanying graph on page 2 of mortgage loans, for example). As a result, effective liquidity management for credit unions has perhaps elevated in importance to a level never seen before while potentially becoming a competitive advantage (or disadvantage).

Regulators began adjusting supervision of liquidity with last year’s new liquidity rule and their focus will likely increase in the coming months. Guidance on “How to Comply with NCUA Regulation §741.12 Liquidity and Contingency Funding Plans,” implemented in March 2014 mandated that credit unions with assets of $250 million or more must have a written liquidity policy providing a framework for managing liquidity and a list of contingent liquidity sources that can be employed under adverse circumstances. The credit union must also have a contingency funding plan that clearly sets out strategies for addressing liquidity shortfalls in emergencies and establish access to at least one contingent federal liquidity source: The Discount Window and/or the Central Liquidity Facility.

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