Compliance Blog

Posted by Anthony Demangone

Yesterday, NCUA held its monthly NCUA board meeting.  Here's a link to the draft items that the board considered at the meeting.  For a more detailed overview of the meeting, please read our NAFCU Today article on the meeting. 

NCUA addressed the following items: 

1. Interim Final Rule – Part 704 of NCUA’s Rules and Regulations, Corporate Credit Unions, Technical Corrections.
2. Proposed Rule – Part 704 of NCUA’s Rules and Regulations, Corporate Credit Unions.
3. Insurance Fund Report and Premium/Assessment Ranges.
4. NCUA’s 2011 Operating Budget.
5. NCUA’s Overhead Transfer Rate.
6. NCUA’s Operating Fee Scale.

Regarding the corporate proposal, NCUA issued a proposed rule that would do the following:

• Require corporates to conduct all board of director votes as recorded votes and include the votes of individual directors in meeting minutes;
• Impose internal control and reporting requirements (including audit, reporting and audit committee practices) similar to those required for banks;
• Provide for the equitable sharing of the Corporate Stabilization Fund (TCCUSF) expenses among all members of a corporate credit union, including both credit union and noncredit union members, by establishing procedures for requesting members not insured by the NCUSIF to make voluntary premium payments to the TCCUSF;
• Limit natural person credit unions (NPCUs) to membership in one corporate of the NPCUs choice at any one time and prohibit an NPCU from making any investment in a corporate where the NPCU is not also a member;
•  Require corporates to establish enterprise-wide risk management committees staffed with at least one independent risk management expert;
• Allow corporates to charge their members reasonable one-time or periodic membership fees; and
• Require the disclosure of compensation received from a corporate CUSO by certain highly compensated corporate credit union executives.

The Board also approved NCUA's 2011 operating budget.  The 2011 budget comes in 12% heavier than the 2010 version (reminds me of...well, me), which will allow NCUA to increase its staff by 78 positions.  Regarding the budget, here are a few things that caught my eye:

• The Office of Inspector General will receive an increase of $650,000 to engage outside professionals to conduct Material Loss Reviews, for a total budget of $1,250,000.  That's double from 2010. Are we looking forward to a doubling of material loss reviews in 2011?  
• The budget includes $3,461,000 in pay, benefits, travel, training, and other related expenses for the continuing implementation of NCUA's Annual Examination Program. That program incorporates more frequent onsite contact of all federal credit unions, with emphasis on problem credit unions, and enhanced offsite monitoring of credit unions. The program adds 60 field positions to the regions: 53 examiners, six (6) supervisory examiners, and one(1) lending specialist.

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On the return flight of a recent trip to Boston, my son Briggs was that kid on the plane. 

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Have a great weekend, everyone!