Compliance Blog

Posted by Anthony Demangone

The "word on the street" is that NCUA will (or perhaps already has this morning) issue another accounting bulletin to clarify some accounting issues with the corporate stabilization program. 

• Access NCUA's corporate stabilization page here. 
• Access NAFCU's news articles here, which should have information about the new guidance.

Update:  NCUA released the Accounting Bulletin 09-2 this morning.

Here's a sneak peek at some of the info that should appear in the bulletin.

AICPA Statement of Position (SOP) 01-6 states, “to the extent that the NCUA Board assesses premiums to cover prior operating losses of the insurance fund or to increase the fund balance to ‘normal operating levels,’ credit unions should expense those premiums when assessed.”  Credit unions should rely upon the advice and guidance of their independent licensed accountant to interpret generally accepted accounting procedures (GAAP) and ensure accurate and transparent reporting on their financial statements.  If a credit union chooses to implement an accounting treatment other than that stated above, they should be prepared to provide written guidance from their accounting practitioner to support that treatment.  If a credit union’s licensed practitioner is willing to provide a written opinion that allows for the delay in the recording of the expenses and indicates in their opinion it is in compliance with GAAP, NCUA examiners will not take exception absent a definitive ruling from the accounting profession to the contrary.

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As you may be aware, the Regulation Z changes to open-end lending do not affect HELOCs.  A Fed representative yesterday indicated that the agency will issue a separate rulemaking to address HELOCs.  There was no word on a time-line.