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U.S. Debt Downgrade?

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Six days before the deadline to raise the national debt limit, 30 of 53 economists surveyed by Reuters news service believed the United States will lose its AAA debt rating in the near future.  Some would argue that kind of action is overdue with the national debt standing at about $14.5 trillion and growing.  However, many experts contend that the financial markets have already built in the possibility of a debt downgrade.  As such, any material impact on the interest rate environment would likely be muted in the near term but the long-term effect would be to put upward pressure on interest rates.

There are conflicting signals out there on rates, though.  The continued weak economy is likely to keep downward pressure on rates, at least for the near term.  The Fed has said as much in recent weeks.  This remains a very challenging environment for financial institutions.  Successful credit unions are continuing to update and create long-term financial forecasts and develop contingency plans.  What if loan demand remains weak?  What if rates rise; remain low?  Keying in on the performance of new business is a critical component in this as well.  In addition, credit unions should continue to evaluate their levels of interest rate risk and make determinations as to whether those levels are acceptable.  Now, more than ever, effective planning and risk management will be critical to credit union success in the coming years.

Source:  Reuters

Back In The Subprime Game

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In a recent issue of the Wall Street Journal, Lewis Ranieri—once known as the father of mortgage finance—said it is time for nontraditional lenders to enter the market, bringing with them a return to subprime lending.  Ranieri said “the pendulum has swung too far in the other direction,” meaning that lending standards were once too loose and are now too rigid.

The implosion of subprime loans four years ago set off a domino effect that continues to impact global economies today.  As financial institutions struggle to regain their footing, lending opportunities have narrowed for all but the most creditworthy applicants.  Yet lending is a material source of income that could help financial institutions to recover and thrive.

The collateral damage from this recession varies by state.  If your credit union is ready to loosen underwriting standards—even if you stop short of subprime lending—it will be important to strategically plan for all variables involved.  The scars earned in the current economy should serve as a sufficient reminder to avoid being burned in the future.

(Sources:  Pioneer to Revisit Subprime, WSJ, 6/24/11 and Image by Bart Claeys)

Caution: NCUA’s Proposed Regulation On IRR Could Have Unintended Consequences

You think you are already doing everything required in the proposed Regulation.  You think your policy limits are appropriate for your strategy and business model—but will the examiner making the judgment as to whether your credit union is in compliance think the same?

NCUA’s proposed shift from Advisory to Regulation is concerning.

It raises several questions, such as:

  • What power will NCUA gain that they don’t currently have by implementing a Regulation on IRR management?
  • How will NCUA change their approach in the exam process once this Regulation is implemented?  If NCUA says there will not be a significant change in their approach, then why is there a proposal to shift from Advisory to Regulation?  In other words, what problem is NCUA trying to correct?
  • If the board believes the policy limits are adequate and they are managing to those limits, yet the examiner believes otherwise, will the credit union be deemed out of compliance with Regulation?
  • If so, what are the credit union’s options under this new Regulation?  Specifically, what options or control will the credit union no longer have once the Regulation is implemented?
  • Under the umbrella of the Regulation, will the examiner be able to require the credit union to conduct additional analyses or else be deemed out of compliance, even if the credit union feels the cost/benefit would not exist?

We agree with much of the underlying intent of the proposed Regulation.  We also agree with NCUA that it is impossible to establish specific regulatory requirements.  Therefore, by necessity, the proposed Regulation is ambiguous.  Ambiguity creates confusion and will make the Regulation difficult to reasonably implement.

If there is no identified, compelling reason to go from an Advisory to Regulation, then why do it?

Keep in mind as you contemplate our comments that our business is to provide asset/liability management services to financial institutions.  A Regulation of this type could greatly enhance our business opportunities, yet we believe that NCUA shifting from an Advisory position to a Regulation is wrought with undesirable, unintended consequences.

To read our full response, please click here.