Policy for Setting the Normal Operating Level
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Abstract
In May 2021, the NCUA Board (Board) invited comment on the policy to set the National Credit Union Share Insurance Fund (Share Insurance Fund) Normal Operating Level (NOL). The Board requested comment on eight specific factors that impact the calculation of the NOL. This final notice responds to comments on these factors as well as other subjects on which the Board received comment in the notice.
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<title>Federal Register, Volume 86 Issue 242 (Tuesday, December 21, 2021)</title>
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[Federal Register Volume 86, Number 242 (Tuesday, December 21, 2021)]
[Notices]
[Pages 72279-72283]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2021-27639]
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NATIONAL CREDIT UNION ADMINISTRATION
Policy for Setting the Normal Operating Level
AGENCY: National Credit Union Administration (NCUA).
ACTION: Notice.
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SUMMARY: In May 2021, the NCUA Board (Board) invited comment on the
policy to set the National Credit Union Share Insurance Fund (Share
Insurance Fund) Normal Operating Level (NOL). The Board requested
comment on eight specific factors that impact the calculation of the
NOL. This final notice responds to comments on these factors as well as
other subjects on which the Board received comment in the notice.
FOR FURTHER INFORMATION CONTACT: Russell Moore or Amy Ward, Risk
Analysis Officers, National Credit Union Administration, Office of
Examination, and Insurance at (703) 518-6383 or (703) 819-1770.
SUPPLEMENTARY INFORMATION:
I. Background
On September 28, 2017, the Board approved the following actions:
\1\
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\1\ 82 FR 46298 (Oct. 4, 2017).
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<bullet> Closing the Temporary Corporate Credit Union Stabilization
Fund (Stabilization Fund) and distributing its funds, property, and
other assets and liabilities to the Share Insurance Fund, effective
October 1, 2017.
<bullet> Setting the NOL of the Insurance Fund to 1.39 percent,
effective September 28, 2017.\2\
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\2\ The Board last set the NOL at 1.38 percent on December 9,
2019. The Board retained the 1.38 percent NOL at its December 17,
2020, meeting.
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<bullet> Adopting the policy for setting the NOL, as outlined
below.
Policy for Setting the NOL
The policy for setting the NOL was adopted in 2017 and established
a periodic review of the equity needs of the Share Insurance Fund, the
results of which are communicated to stakeholders.\3\ At least
annually, NCUA staff reviews the level at which the NOL is set and
reports this information to the Board. Board action is only necessary
when a change in the NOL is warranted. The policy establishes that any
change to the NOL of more than one basis point shall be made only after
a public announcement of the proposed adjustment, with an opportunity
for comment.\4\ For any such adjustment, the NCUA would issue a report
and request for comment that includes data supporting the proposed
adjustment. The policy established the following objectives for the
Board to satisfy when setting the NOL:
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\3\ As noted, the Board adopted this policy for setting the NOL
in 2017. The Board emphasizes that, as a general statement of the
NCUA's policy regarding setting the NOL, the Board is not required
to follow the notice-and-comment rulemaking process when revising
this policy. See 5 U.S.C. 553(b)(3)(a). Nevertheless, the Board
voluntarily solicited public input on this policy.
\4\ One basis point is one hundredth of one percent.
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<bullet> Retain public confidence in federal share insurance;
<bullet> Prevent impairment of the one percent contributed capital
deposit; \5\ and
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\5\ Federally insured credit unions are required to maintain a
deposit equal to one percent of their insured shares with the Share
Insurance Fund. 12 U.S.C. 1782(c)(1)(A)(i).
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<bullet> Ensure the Share Insurance Fund can withstand a moderate
recession without the equity ratio declining below 1.20 percent over a
five-year period.
The current economic landscape and pending resolution of the
obligations associated with the corporate credit union asset management
estates and NCUA Guaranteed Notes (NGN) Program, discussed later in
this document, warrant a re-evaluation of the NCUA's current NOL
policy.
II. Legal Authority
Pursuant to the Federal Credit Union Act (Act), the NOL is an
equity ratio specified by the Board, which may not be less than 1.20
percent and not more than 1.50 percent.\6\ The Board has historically
set the NOL as the target equity ratio for the Share Insurance Fund.
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\6\ 12 U.S.C. 1782(h)(4).
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The Share Insurance Fund's calendar year-end equity ratio is part
of the statutory basis to determine whether the
[[Page 72280]]
NCUA must make a distribution to insured credit unions.\7\ The Act
states:
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\7\ The equity ratio is also part of the statutory basis for
determining whether a premium or Share Insurance Fund restoration
plan is necessary. The unprecedented share growth related to the
pandemic resulted in an equity ratio of 1.26 percent as of December
31, 2020, and an equity ratio of 1.23 percent as of June 30, 2021.
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``The Board shall [ . . . ] effect a pro rata distribution to
insured credit unions after each calendar year if, as of the end of
that calendar year--
<bullet> Any loans to the Fund from the Federal Government, and any
interest on those loans, have been repaid;
<bullet> The Fund's equity ratio exceeds the [NOL] and
<bullet> The Fund's available assets ratio exceeds 1.0 percent.''
\8\
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\8\ 12 U.S.C. 1782(c)(3)(A). This section is also subject to 12
U.S.C. 1790e(e).
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The above provisions of the Act are generally implemented at 12 CFR
part 741 of the NCUA's regulations.
III. Current Normal Operating Level Methodology and Process
To implement the current approved policy, the NCUA developed a
calculation based on scenarios using the following factors:
<bullet> The modeled performance of the Share Insurance Fund over a
five-year period, assuming a moderate recession.
<bullet> The modeled potential decline in value of the Share
Insurance Fund's claims on the corporate asset management estates in a
moderate recession; and
<bullet> The projected equity ratio decline through the end of the
following year, assuming no economic downturn.
The stress scenario entails estimating three primary drivers of
outcomes: insurance losses, insured share growth, and yield on
investments. Additionally, the risk associated with the Share Insurance
Fund's claims on, and obligations related to, the asset management
estates of the five failed corporate credit unions is a factor in this
analysis. The Share Insurance Fund's exposure related to the asset
management estates of the five failed corporate credit unions has
substantially declined since the last NGN trust matured on June 12,
2021. Though the amount of time needed to fully liquidate all the
assets and satisfy all the liabilities of the corporate asset
management estates will depend on market factors and ongoing
litigation, the risk has significantly declined and will continue to
decline and end as the residual assets are liquidated and the estates
closed. More information regarding the NGN program and the Corporate
System Resolution may be found on the NCUA's public website.
The NCUA's stress analysis is based on the Federal Reserve's
adverse economic scenario and applied to the primary drivers. However,
the Federal Reserve did not publish an adverse scenario in 2020 or
2021; therefore, the NCUA developed an adverse scenario based on the
average of the Federal Reserve's baseline and severely adverse economic
scenarios. Historically, this has been a reasonable proxy for a
moderate recession. The absence of an adverse scenario published by the
Federal Reserve and the pending completion of the corporate resolution
program warrant a re-evaluation of the current NOL policy.
IV. Comments on Normal Operating Level and Responses
The Board sought comment on the policy and approach for setting the
NOL of the Share Insurance Fund. Commenters were encouraged to discuss
any other relevant issues for the Board to consider. Specifically, the
Board was interested in comments addressing the following factors:
<bullet> Should a moderate recession be the basis for evaluating
the Share Insurance Fund performance during an economic downturn, or
should the NCUA change the policy to consider a severe recession?
<bullet> What data source(s) should the NCUA use for determining
the characteristics of a potential moderate or severe recession--the
Federal Reserve scenario, an independent source, or the NCUA's
judgment?
<bullet> Should the NCUA continue modeling the performance of the
Share Insurance Fund over a five-year period? Should the period be
longer or shorter?
<bullet> How should the NCUA utilize the modeled potential decline
in value of the Share Insurance Fund's claims on the corporate asset
management estates going forward, until the estates are fully resolved?
<bullet> Should the NCUA continue to incorporate in the NOL
analysis the projected equity ratio decline through the end of the
following year without an economic downturn? Should this period be
longer or shorter, or not factored into the analysis at all?
<bullet> Given forecasting uncertainties and timing challenges,
would it be reasonable for the NCUA to change the requirement to
request public comment only if the NOL were to change by a larger
amount than just one basis point?
<bullet> Should the NOL be re-evaluated in the midst of an economic
downturn or should it be left unchanged until the onset of an economic
recovery?
<bullet> Should the NOL be re-evaluated on qualitative factors
based on the COVID-19 pandemic?
<bullet> Is there any other information that the Board should
consider when setting the NOL?
The Board received 23 comment letters from credit union leagues,
trade associations, credit unions, and credit union service
organizations.
Moderate or Severe Recession
Most commenters stated a moderate recession is an appropriate basis
for evaluating the Share Insurance Fund's performance during an
economic downturn. Commenters who did not support using a severe
recession cited the few numbers of severe recessions recorded in U.S.
history and noted that the low probability of losses stemming from a
severe economic event reduces the utility of a severe recession as a
basis for modeling. The commenters noted that the majority of the
losses to the Share Insurance Fund have been from fraud, concentration
risk, etc., and not from severe economic factors; thus, a model based
on a severe recession would not be useful. Commenters expressed that
NCUA's own capital planning requirements for credit unions do not
require credit unions to build capital to accommodate high impact, low
probability events. The Board agrees with the commenters and will
retain the moderate recession scenario as the basis for modeling the
NOL.
Data Sources
Commenters emphasized the need for NCUA to use an independent
source to provide data for NCUA's modeling of a potential moderate or
severe recession. The majority of commenters supported continuing to
use the Federal Reserve as this independent source, due to its
credibility in the industry and its wide use among other banking
agencies. Several commenters favored an independent source other than
the Federal Reserve or some combination of the Federal Reserve and
independent sources. Most commenters recommended the Board not use NCUA
judgement as an exclusive means for modeling a moderate and severe
recession. Several commenters believed NCUA judgment would be
acceptable as a backup means to define a moderate recession when the
specific Federal Reserve scenario was not available.
Several commenters did express concern that the Federal Reserve
data includes bank losses, which historically have been greater than
credit union losses, and the impact this would have on modeling for
credit unions. The Board emphasizes the Federal Reserve
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data used in the modeling process is broad macroeconomic assumptions
and is not specific to any one industry. The Board believes the Federal
Reserve scenarios are the best choice due to their public availability
and wide acceptance. Other independent sources may not be readily
available for public scrutiny or require subscriptions to be able to
view. Based on the feedback, the Board believes the NCUA's methodology
of using an average of the Federal Reserve's baseline and severely
adverse scenarios to approximate a moderate recession is the best
alternative.
Modeling Period
While commenters supported the current use of a moderate recession
in the modeling process, many commenters recommended the Board shorten
its modeling period from the current policy of five years to a shorter
period of 18 months to three years. Commenters suggested the current
five-year period is no longer applicable because it was put in place in
2017 to account for the remaining maturity of the NGN Program, which
was set to mature in 2021. Commenters expressed that a shorter modeling
period is also more appropriate because the duration of economic
recessions was less than five years. Commenters emphasized the
applicability of a shorter period, noting the Federal Reserve baseline
and severely adverse recession scenarios are based on 13 quarter terms.
Other commenters that supported using a longer period than five years
suggested modeling consistent with business and economic cycle trends
that typically exceed five years.
The Board disagrees with commenters that state the Share Insurance
Fund's performance horizon should be less than five years. As outlined
in its July 2017 Notice and discussed at the July 2017 Board meeting, a
five-year horizon for modeling the Share Insurance Fund was selected
for several reasons. One compelling reason is that the National Bureau
of Economic Research--the not-for-profit research organization that
establishes the beginning and end of U.S. business cycles--has
calculated that, from 1854 through 2020, the United States has averaged
59 months from the peak of one business cycle to the next. If the
modern era (1945 to 2020) is considered, this cycle extends to 75
months.
Though a recession may end, the economy may remain weak during the
recovery period. A struggling economy also poses risks to credit
unions, and a thorough analysis of the Share Insurance Fund's equity
position needs to account for the period of continued economic
weakness, which more realistically reflects a recession's effects on
the credit union industry. A primary reason the NCUA's projections
extend the Federal Reserve's 39-month (13 quarters) scenario to 60
months is that it may take more than 39 months for the effects of the
recession and the weak recovery to produce losses. Five years is also
consistent with the agency's strategic planning cycle. Therefore, the
Board plans to retain a modeling horizon of five years.
Potential Decline in Value of the Share Insurance Fund's Claims on the
Corporate Asset Management Estates
Many commenters recommended eliminating the modeled potential
decline in value of the Share Insurance Fund's claims on corporate
asset management estates since the estates are almost fully resolved
and no longer pose a material impact to the modeled results. Commenters
felt any remaining impact of the corporate resolution program is likely
immaterial and therefore not needed in the analysis.
The Board agrees with the commenters. The last NGN certificate
matured in June of 2021. The remaining assets of the corporate asset
management estates have not been fully liquidated yet, but the Board
agrees this component in the NOL calculation can be eliminated as the
exposure has significantly declined and will be fully resolved within
the next modeling period.
Decline in the Equity Ratio Through the End of the Following Year
Without an Economic Downturn
The majority of comments on this issue supported eliminating the
projected equity ratio decline from the NOL analysis through the end of
the following year without an economic downturn. The rationale provided
was the near completion of the NGN Program, which negates the need to
analyze the projected equity ratio decline through the end of the
following year as a backstop to ensure the Share Insurance Fund could
stay above 1.2 percent under a moderate recession during the remaining
life of the NGNs. One commenter supported retaining the analysis and
suggested that the NCUA standardize the period used in the forecast.
The Board agrees with the commenters. This component of the NOL
calculation was originally intended to protect against a decline in the
equity ratio while the NGNs were outstanding. The NGNs have all
matured, and while there are remaining Legacy Assets, the impact of a
decline in their value is no longer significant to this analysis.
Public Comment Only if the Normal Operating Level Were To Change by a
Larger Amount Than One Basis Point
Fourteen commenters offered comments on NCUA's current policy of
notifying and requesting public comment in the event the NOL changes by
more than one basis point. Nine of these commenters favored keeping
this requirement in the policy, with most citing the potential impact
on credit unions and transparency as the basis for their view. One
commenter expressed that even one basis point reflects a large dollar
amount and has a material impact on individual credit unions.
The current policy to notify and request comment is necessary to
provide transparency involving actions taken regarding the management
of the Share Insurance Fund. Commenters believe it is sound public
policy to provide stakeholders the opportunity to participate in
considerations of even modest adjustments to the NOL and other
adjustments that impact the Share Insurance Fund (referring to the
Overhead Transfer Rate). One commenter supported continuation of the
notice and comment practice but suggested a range of three to five
basis points would provide the Board sufficient latitude to adjust the
NOL without a full comment period.
Two commenters stated public comment is warranted any time the NOL
calculation results in an NOL above 1.3 percent. Individual commenters
expressed the following:
<bullet> NCUA eliminating the comment requirement for a one basis
point change is concerning because it may trigger NCUA to make a series
of one basis point increases without the opportunity for public
comment.
<bullet> Public comment is only necessary if the change prompts a
required premium for all credit unions.
<bullet> Public comment should be required for all NOL changes,
regardless of amount.
Many of the commenters stressed the importance for the Board to
consider setting the NOL at a level that achieves a balance between a
stable Share Insurance Fund equity position and minimizing financial
strain on credit unions. Commenters noted that preserving as much
members' equity as possible supports a credit union's mission of
providing products and services to their members. Commenters also noted
the majority of credit unions are well capitalized and pose little risk
to the Share Insurance Fund. Credit unions with higher risk to the
Share
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Insurance Fund are properly identified and working toward resolution,
as evidenced by the low number of failures that pose a cost to the
Share Insurance Fund.
Many commenters expressed the prolonged history and adequacy of a
NOL of 1.3 percent, stating the Board is provided sufficient tools
within the Act (premiums and distributions) to manage the Share
Insurance Fund's equity within the statutory range of 1.2 percent and
1.5 percent. Many of these commenters cited the more recent NOLs the
Board set at 1.39 percent in 2017 and 1.38 percent in 2019 were based
on the closure of the Temporary Corporate Credit Union Stabilization
Fund (Stabilization Fund) and the consolidation of the Stabilization
Funds' assets and liabilities into the Share Insurance Fund. In the
commenters' view, these do not reflect an appropriate NOL going
forward.
Other commenters expressed concern over NCUA's budget. These
commenters focused on the agency's need to manage expenses to reduce
the Share Insurance Funds' obligation to fund a portion of NCUA's
operating budget, thus maintaining higher levels of equity in the Share
Insurance Fund and minimizing the credit union industry's obligation.
The Board agrees public comment, although not required, could be
helpful when considering a change to the NOL policy or methodology. The
Board also wishes to clarify two points that may have confused some
commenters. Several commenters stated public comment should be
requested anytime the NOL results in a premium or potential premium.
The NOL does not trigger a premium, but rather establishes the point
above which a distribution is required. The actual equity ratio is
measured against the NOL to determine if a distribution is required.
The Board may only levy premiums when the Share Insurance Fund's actual
equity ratio falls below 1.30 percent. Even if the actual equity ratio
is below 1.30 percent, the Board weighs other factors, including
financial projections, prior to determining whether to assess a
premium.
The Board believes the NOL must be set based on a quantitative and
qualitative analysis, with the quantitative analysis being the primary
driver in setting the NOL and the qualitative factors considered by the
Board, as appropriate. The Board agrees with commenters that a request
for public comment, although not required, is helpful if the NOL
changes. The Board will continue seeking public comment when the NOL
changes by more than one basis point.
Should the NOL be re-evaluated in the midst of an economic downturn or
should it be left unchanged until the onset of an economic recovery?
Ten commenters responded to the issue of whether the NCUA should
reevaluate the NOL in an economic downturn or leave it unchanged until
the onset of an economic recovery. Three commenters stated the NOL
should be continuously evaluated and one stated the NOL should not be
changed. The remaining commenters emphasized the need for the process
to be standardized and for NCUA to strike a balance between
safeguarding the Share Insurance Fund and avoiding overburdening credit
unions and their members.
The Board believes the current process is standardized and based on
the risk inherent in the Share Insurance Fund. The recent economic
downturn due to the COVID-19 pandemic resulted in unusual share growth
and volatility in the financial markets. The Board will continue to
apply a standardized approach to calculating the NOL while also using
experience and judgment to determine if the NOL should remain unchanged
under such circumstances.
Should the Normal Operating Level be re-evaluated on qualitative
factors based on the COVID-19 pandemic?
Ten commenters responded to the question regarding whether the NOL
should be re-evaluated on qualitative factors based on the COVID-19
pandemic. Seven commenters stated the NCUA should not re-evaluate the
NOL based on abnormal events with a high level of uncertainty. Several
commenters stated they were opposed to the inclusion of qualitative
factors as it would reduce transparency. Three commenters stated some
support for evaluating factors due to an economic downturn. One
commenter stated the NOL should be evaluated holistically, accounting
for both data and environmental factors. Another commenter expressed
support for a policy that is based on historical record that all U.S.
recessions would last only a few months, as has generally been the case
since the Great Depression. Finally, one commenter reiterated that the
NOL should always be re-evaluated based on qualitative factors, but the
policy should be to look beyond the numbers and make decisions based on
actual or perceived risk to the Share Insurance Fund and the credit
union industry.
The Board agrees the NOL policy should not be constructed to react
to single events such as the current pandemic and the methodology
should be quantitative and qualitative, with the quantitative analysis
being the primary driver in setting the NOL and the qualitative factors
considered by the Board, as appropriate. In terms of qualitative
factors, the Board reserves the right to consider environmental factors
in the decision to change the NOL or retain it at its current level
given all available information. Unusual non-quantitative factors
affecting the decision regarding the NOL may be disclosed if the impact
is material.
Is there any other information that the Board should consider when
setting the NOL?
Fourteen commenters offered responses regarding additional
information the Board should consider when setting the NOL. Nine
commenters suggested the Board set the NOL at the pre-2017 level of
1.30 percent. The rationales presented include:
<bullet> The risk from the merger of the Stabilization Fund no
longer exists,
<bullet> The Board cannot assess a premium when the equity ratio is
above 1.30 percent, and
<bullet> The NCUA should not hold more equity than legally
required, except for identifiable losses.
Commenters also voiced opposition to any statutory changes removing
the 1.50 percent NOL ceiling or removing the restriction on premiums
when the equity ratio is at or above 1.30 percent. Several commenters
stated the NCUA should convert all Share Insurance Fund accounting to
private generally accepted accounting principles (GAAP) to allow for
earlier recognition of the one percent capitalization deposit
adjustment. One commenter stated that, if the NCUA wanted to manage to
a NOL higher than 1.30 percent, there would be a couple of options,
including but not limited to cutting operating expenses, increasing
investment yields, or using its borrowing authority. Finally, one
commenter recommended the Board reconsider the current NOL policy
objectives. The commenter stated the NOL does not prevent impairment of
the contributed capital deposit and setting the NOL has very little to
do with public confidence in federal share insurance and the equity
ratio declining below 1.20 percent over a five-year period. What
matters is identifying and preparing for risks that threaten the Share
Insurance Fund's equity ratio.
The Board does not agree with arbitrarily setting the NOL. The NOL
represents the level of equity the Share Insurance Fund should have to
meet the
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policy objectives based on a robust modeling of risk.
While commenters provided feedback opposing any statutory changes
removing the 1.50 percent ceiling on the equity ratio or the 1.30
percent cap on the Board's ability to charge a premium, the Board has
determined these comments are outside the scope of this request. These
changes would be a matter for Congress to decide. However, the current
statutory restrictions are a constraint on the Board's ability to
pursue a counter-cyclical approach to managing the Share Insurance
Fund.
Regarding changing the accounting methodology for the Share
Insurance Fund, the NCUA offers the following response. GAAP treatment
does not directly tie to the NOL policy and is considered beyond the
scope of this request. This can be considered separately as
appropriate.
With respect to the audit, the NCUA's Office of Inspector General
engages an independent auditor to express an opinion on the NCUA's
financial statements based on their audit and in accordance with
auditing standards. The 2020 audit opinion indicated the Share
Insurance Fund's financial statements present fairly, in all material
respects, the financial position of the Share Insurance Fund in
accordance with U.S. GAAP. Share Insurance Fund footnote disclosure
numbers eight and fourteen include detailed financial information about
the NGN program and the Asset Management Estate Fiduciary Revenues,
Expenses, Assets and Liabilities. These footnote disclosures and the
amounts contained within them are fully audited as part of the Share
Insurance Fund's financial statement audit.
With regard to the comments stating that if the NCUA wanted to
manage to an NOL higher than 1.30 percent there would be a couple of
options, including cutting operating expenses, increasing investment
yields, or using its borrowing authority, the Board notes that it
controls operating expenses to the extent possible consistent with
having sufficient resources to achieve the agency's mission. The Board
has limited options to increase investment yields, as those are
determined by the market and the Share Insurance Fund is limited by law
to investing in ``any interest-bearing securities of the United States
or in any securities guaranteed as to both principal and interest by
the United States or in bonds or other obligations which are lawful
investments for fiduciary, trust, and public funds of the United
States.'' \9\ Finally, borrowing funds on behalf of the Share Insurance
Fund would be a liability and would not increase the equity ratio.
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\9\ 12 U.S.C. 1783(c).
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Regarding the commenter who offered specific comments on the NOL
policy objectives, the Board offers the following responses: The Board
believes having a robust methodology to determine what level of equity
the Share Insurance Fund would need to prevent impairment of the one
percent capitalization deposit, and to prevent it from falling below
1.20 percent over five years in a moderate recession, bolsters public
confidence. The Board agrees that it is important to identify and
prepare for risks that threaten the Share Insurance Fund. The NOL
policy is designed to determine the risk to Share Insurance Fund under
a stressed environment, which is when losses generally occur.
Final Action
The Board will retain the current objectives for setting the NOL.
When setting the NOL, the Board will seek to satisfy the following
objectives:
<bullet> Retain public confidence in federal share insurance;
<bullet> Prevent impairment of the one percent contributed capital
deposit; and
<bullet> Maintain the Share Insurance Fund through a moderate
recession without the equity ratio declining below 1.20 percent over a
five-year period.
The impact of changes in value of the corporate asset management
estates and the decline in the equity ratio through the end of the
following year without an economic downturn will be removed from the
NOL calculation. The Board will continue to use a decline in the Share
Insurance Fund's equity in a moderate recession to estimate the
additional equity needed to prevent the equity ratio from falling below
1.20 percent. Any change to the normal operating level of more than 1
basis point shall be made only after a public announcement of the
proposed adjustment and opportunity for comment. In soliciting comment,
the NCUA will issue a public report, including data supporting the
proposal.
By the National Credit Union Administration Board on December
16, 2021.
Melane Conyers-Ausbrooks,
Secretary of the Board.
[FR Doc. 2021-27639 Filed 12-20-21; 8:45 am]
BILLING CODE 7535-01-P
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</html>This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.