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Moore provides insights into Treasury's ECIP in new network posts
In new posts on NAFCU's Compliance and CFO Networks, Regulatory Affairs Counsel Aminah Moore broke down a recent NCUA webinar on the Treasury Department's Emergency Capital Investment Program (ECIP). The program was created by the Consolidated Appropriations Act to help community-based financial institutions support consumers and small businesses in low-income and underserved communities.
In the post, Moore noted that the ECIP provides $9 billion in funding for credit unions, banks, and bank holding companies collectively, with some funds set aside for small and midsize financial institutions. CDFI and minority depository institution (MDI) credit unions are eligible to participate in the program.
During the NCUA’s recent webinar, U.S. Treasury Acting Program Lead Brian Donovan provided the below insights into the ECIP:
- a credit union may not be approved for the full amount requested in their application;
- the accrual clock will begin on the 2-year anniversary of the date the credit union closes on the note;
- the definition of fiscal year has not been decided yet, but it will likely be defined as the institution’s fiscal year; and
- during the application process Treasury will be soliciting feedback from the NCUA on credit union’s applications.
Moore also noted that, for credit unions, ECIP investments will be given in the form of subordinated debt. Each credit union has a limit of an aggregate principal amount that is no more than $250 million and:
- no more than 7.5% of total assets if a credit union’s total assets were $2 billion or less;
- no more than 15% of total assets if a credit union’s total assets were between $500 million and $2 billion; or
- no more than 22.5% of total assets for a credit union’s total assets of less than $500 million.
A powerpoint from the webinar is available here, and the webinar is available on-demand. If credit unions have questions with the application, they are encouraged to contact the Treasury Department directly via email.
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