Comments Due to NAFCU: NCUA - Derivatives
NAFCU would like to highlight the following:
- The proposal modernizes the existing derivatives rule by making it more principles-based and provides more flexibility to manage interest rate risk (IRR), while maintaining standards for safety and soundness.
- The proposal eliminates the prescriptive derivative product list and moves towards a characteristic-based approach. In addition, the proposal removes the regulatory loss limits and streamlines the requirements for counterparty agreements, margin requirements, and eligible collateral.
- The proposal provides an application exemption for “complex” FCUs with at least $500 million in assets and a CAMEL rating of 1 or 2.
Comments due to NAFCU: December 9, 2020
Comments due to NCUA: December 28, 2020
NAFCU will send comments on behalf of its members to the FinCEN by their deadline (December 9, 2020).