A Busy Year
Posted by Anthony Demangone
Not too long ago, I shared my general outlook for 2011.Â Â Â That post dealt more with general trends. Â But we do expect some specific things. Â Regarding NCUA, look out for the following in 2011.
- Regulations on interest rate and concentration risks. Â If you've been keeping up with the Material Loss Reviews issued by NCUA's Office of Inspector General, you already know that concentration risk has played a huge role in credit union failures. Â And that risk affects more than just credit unions. Â I was at a meeting recently where an OTS and OCC official both agreed that concentration risks played a role in every major bank failure as well.
- Member business lending.Â Rather than a major overhaul, look for NCUA to incorporate guidance documents into the regulation.
- CUSOs.Â Â NCUA will ramp up its focus on CUSOs, and they may seek examination authority.
- Examinations.Â Â NCUA will overhaul its examiner's manual. Â This is one process to track closely. Â In my view, the examiner's manual is a massive guidance document that can affect your operations and NCUA examinations. Â For that reason, it is very important to see how they change it.Â
- This and That.Â Â NCUA may also overhaul its investment rule (Part 703) and it may direct examiners to review new credit union products/services at each exam.Â
Keep in mind that we can't say for certain that NCUA will act on any one of these issues. Â But based on our conversations with NCUA officials, these are some of the areas of interest. Â Stay tuned!