MEMBER BUSINESS LOAN WAIVERS AVAILABLE (FROM PAGE 4)
specific items that must be submitted along with the waiver
request including a copy of the business lending policy,
sufficient documentation supporting the ability to manage the
activity, and an analysis of the credit union’s prior experience
making MBLs including, at a minimum:
; History of loan losses and loan delinquency;
; Volume and cyclical or seasonal patterns;
; Diversification of the portfolio;
; Concentration of credit to one borrower or group of
associated borrowers in excess of 15 percent of net worth;
; Underwriting standards and practices;
; Types of loans grouped by purpose and collateral; and
; Qualifications of personnel responsible for underwriting
and administering member business loans.
In evaluating the request, regional staff will review the
information submitted, evaluate the level of risk the waiver may
pose to the institution, and review the credit union’s historical
CAMEL composite and component ratings. It is important that
you include adequate documentation necessary for the regional
office to evaluate your request as the most common reason for
denial is the lack of sufficient documentation.
Because each request is unique, it is impossible to give a one-size-fits-all answer to the question, “Other than the list in the
regulation, what else must we put in the request?” I can
recommend, however, you carefully think the process through
and submit any information that would bolster your position
and demonstrate that you can safely engage in the activity
with a waiver in place. Waivers are not likely to be approved
if the documentation package as a whole does not
demonstrate a well-constructed plan for the activity proposed.
It is also important to note that a state-chartered, federally
insured credit union must submit any waiver request to its
state supervisory authority. If the state supervisory authority
approves the request, the state regulator will forward the
request to the appropriate RD.
RDs are required to notify you of the action taken within 45
calendar days of receiving a complete request from the federal
credit union or the state supervisory authority. If you do not
receive notification within 45 calendar days of the date the
complete request was received by the regional office, you may
assume approval of the waiver request.
If you would like additional information, please contact your
NCUA BUDGET TALK (FROM PAGE 4)
In 2010, we added 39 new examiners, and in 2011 another
53. As a result, we made significant progress in moving to an
annual examination schedule for all federal credit unions, no
matter their asset size, and all state-chartered, federally insured
credit unions with more than $250 million in assets, in
addition to those determined to show elevated insurance risks.
But, today we are still not at the level where I feel comfortable.
You may ask why NCUA needs so many examiners when
the number of credit unions is shrinking. There are a number
; Credit unions are becoming larger and more complicated
as the result of mergers;
; The products being offered require greater examiner
; Investment portfolios require a greater understanding; and
; In certain states, budget cuts, resulting in fewer state credit
union examiners, have required NCUA to add additional
examinations to its schedule.
The protection of the Share Insurance Fund is a top priority,
as any one failure hurts every credit union.
So by being more vigilant, doing more exams and having the
necessary number of examiners to do the job, NCUA
provides a greater safety net and comfort line for everyone in
My goal at NCUA is simple, the protection of the deposits of
91 million Americans, a safe and sound credit union system,
and a strong Share Insurance Fund.
In addition, I want NCUA to be the best, most responsive, and
most effective federal regulatory agency. We are on our way to
that, building a staff of competent, dedicated professionals.
I have always said, if we catch a problem at the credit union
earlier, we can potentially save the Share Insurance Fund
millions of dollars in losses. That is good for all credit unions
and will save them and the Fund amounts that will offset any
NCUA budget increases.
When the corporate situation occurred, I pledged: “Never
again.” With the new corporate rule, new corporate structure
and the dedication of everyone, it won’t.
At NCUA we are committed to do the best possible job we
can. My commitment as a Board Member is to make sure the
resources are there to accomplish that goal. If additional
examiner hiring is necessary, I will support that effort because
I believe we need to do what is required to keep credit unions
the best financial service providers in the country.