Call Report Modernization – Request for Information

The National Credit Union Administration (NCUA) is conducting a comprehensive review of two vehicles used to collect information for regulatory oversight of federally insured credit unions (FICUs)—the 5300 Call Report (Call Report) and Form 4501A Profile (Profile). The overarching goal is modernizing content to (i) strengthen on-site examination and off-site monitoring by NCUA and state supervisory authorities, (ii) facilitate richer … Read More

Interagency Guidance Regarding Deposit Reconciliation Practices

On May 18th, the Banking Brotherhood (Federal Reserve System, CFPB, FDIC, NCUA and OCC) released guidance for institutions regarding deposit reconciliation practices. If you recall, last year the CFPB, OCC, and FDIC took action against Citizens Bank for failing to credit consumers the full amounts of their deposited funds.  “Citizens Bank regularly denied customers the full credits of their deposits … Read More

DCU Interpretive Letter I-15-04 Complying with GAAP in Relation to MBLs

The Division of Credit Unions has published Interpretive Letter I-15-04 (Complying with GAAP in Relation to MBLs). This Interpretive Letter clarifies the requirements for Washington State-chartered credit unions when complying with generally accepted accounting principles (“GAAP”) in relation to member business loans (“MBL”) and reserving for their allowance for loan and lease losses (“ALLL”) account. From the letter, State Credit … Read More

DCU Bulletin B-15-16 New Payment Process for DCU Semi-annual Assessment Fees

The Division of Credit Unions has published Bulletin B-15-16 (New Payment Process for DCU Semi-annual Assessment Fees). Starting Jan. 1, 2016 asset assessment fees will be collected on a semi-annual basis  (i.e. in January and July of each year). Under the new system, the credit unions will use  an online payment system to pay the asset assessment fee.  The new … Read More

Reserve Requirement – Regulation D

The Federal Reserve Board amended Regulation D (Reserve Requirements for Depository Institutions) to reflect annual indexing and the low reserve tranche for 2016. The new low reserve threshold will apply to the fourteen-day reserve maintenance period that begins January 21, 2016. For institutions that report deposit data weekly, this maintenance period corresponds to the fourteen-day computation period that begins December … Read More

Final Rule on the Frequency of Asset Assessment Fees (RCW 34.05.325(6))

Starting January 1, 2016, Washington State asset assessment fees will be collected on a semi-annual basis, rather than the current quarterly basis.  This will bring the collection of State assessment fees closer to the Federal assessment fees practice.  The annual aggregate amount will not change. http://www.dfi.wa.gov/sites/default/files/credit-unions/bulletins/B-15-15.pdf

Reserve Requirement Adjustment for Depository Institutions – Regulation D

>The Federal Reserve amended Regulation D to reflect the annual indexing of reserve requirements for 2016. Reserve Liability Reserve Requirement Net Transaction Accounts:   $0 to $15.2 million (from $14.5 million) 0% of amount   $15.2 million to $110.2 million (from $103.6 million) 3% of amount   Over $110.2 million $2,850,000 + 10% of the amount over $110.2 million Nonpersonal … Read More

The NCUA has released a video on its risk-based capital (RBC) rule

The video covers the rule’s framework, changes made from proposal to final rule stage and an overview of the NCUA’s three-year implementation plan. Additional materials, including an impact analysis and a RBC estimator, are available on the NCUA’s RBC resource page. The rule applies to federally insured credit unions with more than $100 million in assets. The rule will become … Read More

Risk-Based Capital Rule

The NCUA released its final rule on risk-based capital requirements. Complex credit unions (those over $100 million in total assets as of its latest Call Report) will be required to calculate their risk-based capital ratio instead of its net worth to determine capital adequacy. Recommended Actions: In preparation for the rule’s effective date of January 1, 2019, credit unions with … Read More