Compliance Blog

Yesterday, NCUA responded to Treasury's Blueprint.  The Blueprint, if successfully implemented as proposed, would seemingly eliminate NCUA.  NCUA's response was not surprising. 

...While NCUA agrees with the premise of the report that the ultimate objective of that oversight is "a sound and competitive financial services industry grounded in robust consumer protection and stable and innovative markets,"  we have significant concerns that the many consumer benefits of the credit union system would be threatened by any restructuring proposal that may blur the credit union charter and that eliminates the separate regulatory and insurance function for federally insured credit unions.

Read the entire statement here.   Treasury's Blueprint has quickly attracted criticism from many areas.  Please note that NAFCU will, as it always has, protect the role of NCUA as an independent regulator for credit unions.  For that reason, we'll closely monitor the Blueprint and any related developments. That being said, the sky is not falling. 

For the record, the OCC seems less troubled by the Blueprint.  Conversely, the OTS, as reported in the Washington Post, apparently opposes the restructuring of financial services.

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Yesterday, the Federal Reserve released a set of maps that shows the state of subprime and Alt-A loans throughout the United States. 

The maps, which are maintained by the Federal Reserve Bank of New York, will display regional variation in the condition of securitized, owner-occupied subprime, and alt-A mortgage loans.  The maps and data can be used to assist in the identification of existing and potential foreclosure hotspots.  This may assist community groups, which can mobilize resources to bring financial counseling and other resources to at-risk homeowners.  Policymakers can also use the maps and data to develop plans to lessen the direct and spillover impacts that delinquencies and foreclosures may have on local economies.  Local governments may use the data and maps to prioritize the expenditure of their resources for these efforts.

I would think that lenders could also use the map to see what is happening outside their doors.  The maps are very impressive.  The Fed indicates that:

(t)he maps show the following information for subprime and alt-A loans for each state and most of the counties and zip codes in the United States:

• Loans per 1,000 housing units
• Loans in foreclosure per 1,000 housing units
• Loans real estate owned (REO) per 1,000 housing units
• Share of loans that are adjustable rate mortgages (ARMs)
• Share of loans for which payments are current
• Share of loans that are 90-plus days delinquent
• Share of loans in foreclosure
• Median combined loan-to-value ratio (LTV) at origination
• Share of loans with low credit score (FICO) and high LTV at origination
• Share of loans with low- or no documentation
• Share of ARMs with initial reset in the next 12 months
• Share of loans with a late payment in the past 12 months

You may access the Fed's press release about the maps here.  You might want to forward this to your collections and lending teams.