National Issues: Dual Chartering At Work
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1 National Issues: Dual Chartering At Work 2017 Connecticut Executive Forum Rocky Hill, CT November 6, 2017 Lucy Ito President & CEO, NASCUS (703)
2 Charter Choice: State or Federal Dual Charter Unique to the US: Choice & healthy tension foster growth & innovation Member-Consumers benefit NASCUS: A national association with a twist: State Regulators and Credit Unions Voice of the State Chartered System, and Defender of a Robust Dual Charter System (to benefit both state and federal charters) NASCUS 2017
3 Members in The Nutmeg State
4 Today s Roadmap National Credit Union System Snapshot The Dual Charter System at Work National Issues NASCUS 2017
5 National Credit Union System Snapshot NASCUS 2017
6 Total CUs Nationwide 2,253 SCUs + 3,568 FCUs = 5,821 39% Federal Credit Unions 61% State Credit Unions NASCUS 2017
7 Assets & Memberships $1.37T Total Assets 110.6m CU Memberships 51% 49% SCUs FCUs 52% 48% SCU FCU Yes including Navy Federal & PenFed NASCUS 2017
8 Key Performance Ratios FCUs SCUs Return on Average Assets Net Worth Loan-to-Share Ratio Delinquency NASCUS 2017
9 The Dual Charter System at Work NASCUS 2017
10 State-Fed Conversions: State > Fed Assets Fed > State Assets $0 billion 6 $1.4 billion $1.1 billion 13 $9.2 billion $0.6 billion 10 $6.2 billion $0.02 billion 11 $10.3 billion $1.72 billion 40 $27.1 billion $0.5 billion 4 $0.3 billion (July) $3.6 billion 7 $1.8 billion : Overwhelming conversion to state charters 2016: NCUA FOM Modernization Rule è Wait & See 2017 thru July: Interstate Branching + MS conversions 2017 Aug-Dec:?? NASCUS 2017
11 Private Insurance Option Exercised in 9 States All State CUs PISCUs Credit Unions 2, % Assets $669 billion $16.4 billion 2.5% Memberships 52.6 million 1.3 million 2.5% AL, CA, ID, IL, IN, MD, NV, OH, TX Statutory Option Provision: AK, AR, CO, GA, KY, LA, MT, OR, PA, VA, WA
12 Prize-Linked Savings Deposits held in a financial institution risk-free (just like traditional savings accounts or CDs). Depositors are entered into a drawing based on #or $ of their deposits during a given period. è Chance to win prizes (funded through interest that accrues across the pool of prize-linked accounts). Gambling v. Gamification Save to Win ( data) Ø 50,000 accounts Ø $94 million Note: 20 states including CT + neighbors RI ME NY (MA NH VT5) 2017 NASCUS. All rights reserved.
13 CAMELS: Reaching the Tipping Point Status # States Implementing S Sensitivity to Market Risk (Interest Rate Risk) 21 CT, MI, ME, TX, WA, MA, CO, NH, UT, VT, MT, NE, NV 2016: ID, WI, MD 2017: IA, MS, LA, ND Under Consideration 2018: GA IN, AZ, OH (AL), (KS), (NCUA/DE)
14 Director Compensation Permitted in 17 States: AZ, CO, GA, IN, KY, MD, MN, ND, NJ, NV, OR, PA, RI, TN, TX, WA, WI Of Interest: FCUs permitted to compensate one director. NASCUS 2017
15 Field of Membership MI, OR, WA = Effective Statewide FOM CT = Permitted but not exercised as of 2016 Mix & Match What does Community mean today? q Local geographic vs. Larger social network q Singular vs. Multiple q Foundational vs. Antiquated? (Rising Tide; Taxation Banker-Speak) q Border communities: Live/Work/Worship in 3 different locations q Safety & Soundness supports diversification What is an Association for FOM purposes? q Can you put a fence around it? q What about fenced but still national? q Cross-border q Cf. NCUA FCU Association rules
16 Test Case: NCUA Association Rules New rule took effect July 6, 2015: ü 12 pre approved categories ü Totality of Circumstance Test 1. Are opportunities provided for members to further its the goals 2. Membership list 3. Other activities sponsored 4. Membership eligibility requirements 5. Whether members pay dues; 6. Member voting rights 7. Frequency of meetings 8. Separateness Automatically approved: (1) Alumni associations (2) Religious organizations (3) Electric cooperatives (4) Homeowner associations (5) Labor unions (6) Scouting groups (7) Single school district PTAs (8) Chamber of commerce groups (9) Athletic booster clubs (w/voting) (10) Fraternal/civic orgs (w/voting) (11) Cultural/ national/ethnic origin (12) Trade professional organizations Cf. Sept 2017 NCUA approved new charter: Clean Energy FCU (Serving ASES members = renewable energy professionals & enthusiasts 2017 NASCUS. All rights reserved.
17 Interstate Branching Agreements Midwest Agreement Southeast Agreement 3 Signed Both 41 States permit interstate branching: AK/CO/NV = Do not allow. MN? 19 Total States
18 Dual Charter Choice: Connecticut Power/Authority CT FCU Sales Tax Exemption Yes Yes Prize-Linked Savings Yes Yes Director Compensation No No? CRA Community Reinvestment Act Yes No Derivatives Authority Yes Coming CAMEL(S) Yes No May purchase a bank No Yes Fixed Assets Rule 5% Eliminated Field of Membership: Mix & Match Yes No Interstate Branching Yes, but Yes
19 National Issues Overhead Transfer Rate Right-Sizing Examinations Equifax Debacle NASCUS 2017
20 Correlations: Budget, OTR, Fed Op Fee NCUA OTR Δ FCU Budget Op Fee 2009 $178m 53.8% -6.77% 2010 $201m 57.2% -1.58% 2011 $225m 58.9% -2.86% 2012 $237m 59.3% -0.90% 2013 $251m 59.1% = +0.24% = 2014 $268m 69.2% -18.4% 2015 $279m 71.8% -0.90% 2016 $291m 73.1% -0.47% Δ $113m +64.6% +19.3% -31.6% 2017 $298m 67.7% +25.5%
21 NCUA Proposed OTR Methodology NASCUS has advocated for NCUA to: ü Acknowledge Safety & Soundness Responsibilities as the Chartering Authority of FCUs (cf. OCC & FDIC) ü Publish OTR in Federal Register for Formal Notice and Comment (cf. APA) ü Enhance OTR Transparency ü Prudently Manage NCUSIF (If separate board, OTR) ü Be Fair to the State System (and the Federal System) On June 23, 2017, NCUA published a proposed revised OTR Methodology. The proposed changes: Ø Acknowledge NCUA s Title 1 (chartering) Responsibilities Ø Streamlines the Formula to Enhance Transparency Ø Commits to Notice & Comment in Federal Register on Regular Basis OTR takes away SCU & FCU $ NCUA Board Meeting: Nov NASCUS. All rights reserved.
22 Right-Sizing Exams & Presence Joint Working Group NCUA & States Greater NCUA reliance on State exams? Alternating & Joint Exam Options (driven by States) NCUA-State collaboration to reduce: Duplication between NCUA & States Presence in / Burden on CUs Costs (NCUA Operating Budget) Note: FDIC support for extended exam eligibility: $1 billion è $2 billion NASCUS 2017
23 The Game Changer NASCUS 2017
24 Regulator Authority è Tough Qs for CUs Evident Gap: CFPB & FTC: UDAAP FBI: Criminality of Hackers è CUs, CUNA/Leagues, & State AGs 47 State AGs Join Investigation Bigger Questions: 1. Regulator Third Party Vendor Authority FDIC / OCC / Fed + 27 states NCUA? 2. FI Position on CFPB s UDAAP Authority
25 How Credit Reports Should/Could Work Hold Credit Reporting Bureaus (& Retailers) to same standards as CUs & banks. Default: Freeze on all 3 bureaus credit reports When 3 rd party wants to check consumer s credit, require multifactor authentication from consumer. Replace SSN with National ID# -- a replaceable # like lost/compromised credit & debit cards. Self-sovereign identification? (cf. Sovrin digital ledger) For NASCUS Members: 10/23/17 NASCUS Equifax Briefing (Recording & Transcript) How? / Risk Mitigation / Legal Fallout / PR Nightmare
26 Symbiotic Relationship: State & Federal Mutual Charter Innovation & Vitality States offer healthy reality check on NCUA Mutual back-stop in event of federal/state gaps Ø A strong state system benefits both state and federal CUs. Ø Robust dual charter system preserves vitality of both credit union charters. NASCUS 2017
27 Upcoming in 2017 High-level overview on topics including: Real Estate loan workflow Fannie/Freddie as Investor/Servicer Business of Loan Servicing Economics of Servicing Servicing Components Loss mitigation
28
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