By The Way

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Chairman Jared Carpenter is a Republican member of the Kentucky Senate representing District 34 since January 4, 2011. He currently serves as the Chairman of the Banking & Insurance committee.

Can you give us your view of the 2019 legislative session, what should people see as the biggest accomplishments of this year’s session?

There were many achievements this session, among them were corrections to the tax reform bill passed last year in order to give relief to non-profit organizations.  There were also several Pro-Life bills that I was proud to support in this session. IN addition to those items one of the biggest achievements was the school safety bill which served to give us a game plan to follow in securing our schools.

What is the most challenging part of being a legislator?

Overall, I think the most difficult aspect of being a legislator is communication; communication with my colleagues, working to build support for an issue, as well as communication with constituents on issues they are passionate about and which effect their lives and on which I must make tough decisions.

What led you to initially pursue election to public office and why do you continue?

I am in my 9th legislative session now, but when I first ran for office, I was only 31 years old, with a young family and deeply involved in small businesses in and around Berea.  At the time I was urged to run for office by several people in the community who, just like me, were not satisfied with how things were being run in Frankfort and the effects they were having on our community. 

Like I said, this is my 9th legislative session and I have continued my service this long and will continue to serve for a few reasons. One reason is that it takes a long time to come to fully understand the process and the system and to learn how to use that system to help my constituents as best as possible. I continue to serve because I am now in a position where I can bring the greatest benefit to my constituents and to our communities.

Tell us about your family.

I grew up in Berea and was the first in my family to graduate from college when I graduated from Eastern Kentucky University.  Most people do not know this, but I attended EKU on a Basketball scholarship, these days I find Bass fishing to be a lot easier on my knees. I went into business with my father who had a small construction business, and now I also own rental properties in addition to the construction business and a cattle farm. I also have a fourteen-year-old son and an eight-year-old daughter.

If you weren’t doing what you’re doing now (work and legislative), what would you like to be doing?

If I weren’t serving as a legislator, I would still be deeply involved in running the businesses I own and very engaged in the community.  I look at my service in the legislature as only one aspect of who I am. I do have a passion for the work I get to do in real estate and I very much enjoy bass fishing when I get free time.

This year, you took over as chair of the Banking & Insurance committee, what do you see as the role/job of this committee your role as chair?  

I believe that the role of the committee and my role as its chairman is to work to protect consumers while giving industry a fair opportunity to provide good quality products and services to the community and to the citizens of Kentucky. Given my background having worked in banking for fifteen years and owning & operating many rental properties, I believe I have a great knowledge base from which to work on these issues. 

Can you tell us about an accomplishment during your time in the legislature that you are most proud of?

It is hard to pick out a single accomplishment to choose as one I am most proud of because I see the work I do in the legislature as a team effort.  I am proud of the work I do with my Caucus and that we have accomplished for the people of Kentucky when we work together.  I am very proud of the things we have been able to accomplish to give workers and businesses the ability to build, grow and thrive here in Kentucky.  I also work hard to bring resources back to my constituents, whether that be through funds for local infrastructure or other means. 

During my time in the legislature I have chosen not to be focused on filing bills in large numbers and rather have focused on taking care of my constituents which would be more difficult if I were focused on passing a large number of my own bills.

What is your view of how credit unions can serve their local communities and be a part of a healthy financial industry that benefits our state?

Speaking of my district where there are both an industrial base as well as a university presence, Credit Unions have always been a big part of the community.  Credit Unions provide affordable services and products to their constituencies that banks may not be able to provide, and that is a valuable thing.

Is there anything else about you that you want our readers to know?

I want people to know that my most important job in Frankfort is to keep my door open.  I hope they know that my door is always open and I welcome the opportunity to help people and industry whenever possible.

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Accelerate Financial Inclusion in Your Community

A learning opportunity supported by Juntos Avanzamos: brought to you by Coopera, Filene Research Institute, Inclusiv, and PolicyWorks; featuring small business lending partners Accion and Grameen America.

Filene, Inclusiv, PolicyWorks and Coopera share a collective cooperative DNA and the conviction that big issues in credit unions and community oriented financial institutions require collaboration and leveraging their strengths. They are proud to offer a series of workshops that will focus on giving credit unions and community-oriented financial institutions tools to effectively drive financial inclusion in their communities. Together, they can help you do more for your members, clients, constituents and community.

These workshops will teach financial institutions to implement ITIN Lending while they engage a new, broader community of consumers in their locality and make a substantial difference in the lives of borrowers. The workshop’s principles of driving financial inclusion, reaching and serving untapped and underserved markets such as the Hispanic community, and operationalizing ITIN Lending is based on over 20 years of experience with the Juntos Avanzamos program and the work of organizations such as Coopera.

These workshops will also empower financial institutions to offer small business loans to underserved entrepreneurs through a new referral partnership with Accion and Grameen America. Credit unions and other financial institutions can enable inclusive economies by expanding access to small business lending. In doing so, they will build in-house capacity and grow their membership.

Act now and register to attend a workshop.

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CECL Symposium

May 21-22, 2019 | Louisville, KY

University of Louisville
440 N Whittington Pkwy., 40222
Room 162/163 in Burhans Hall
Louisville, Kentucky 40222

NASCUS and the Kentucky Department of Financial Institutions invite you to attend the CECL Symposium at the University of Louisville Shelby Campus.

The Current Expected Credit Loss (CECL) model is the future model for recognition and measurement of credit losses for loans and debt securities. The impact of this new loss model is expected to have a significant impact within the credit union industry. This session provides an update of the current status of the standard and how credits unions can begin to start their modeling process. As a part of this course we will cover the following:

1. An overview of CECL and the areas impacted
2. Strategic planning discussion for implementation
3. A review of areas other than loans impacted by the new standard
4. Current allowance levels in the industry and how it may be impacted by CECL
5. Technical training on functionality of Microsoft Excel, and how this can be used for CECL implementation
6. A look at six different methodologies to potentially be used for the calculation of CECL using real data and going step by step on how the computations will be done
7. A discussion of setting qualitative factors under CECL, how to access industry data, and how to potentially utilize industry information with a CECL model.

REGISTER

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Kentucky Credit Union Chapters Volunteer to Build Beds

Ashland Chapter

The Kentucky Credit Union League Ashland Chapter and its partners worked on building beds for those in need on the morning of April 6th for their annual Build-A-Bed project.

The goal is to give beds to school aged children who are forced to sleep on floors, couches, or in beds with multiple other children or family members. This regional Build-A-Bed Project through Morehead State University has provided more than 1,000 beds to children in Eastern Kentucky since it began in 2010. This year, the Ashland Build A Bed committee set a goal to build 100 beds, in addition to the 200-bed goal set by MSUCorps AmeriCorps Program.

The Ashland Build A Bed Project will serve as a branch from the Build-A-Bed Project through MSUCorps.  Ashland Build A Bed will build and distribute beds for the FIVCO area that include: Boyd, Carter, Lawrence, Greenup, and Elliot.  The Ashland Build A Bed is a service project put together by the Kentucky Credit Union League Ashland Chapters which include: Members Choice Credit Union and Ashland Credit Union. 

Louisville Chapter

On April 13th, hundreds of people spent their Saturday helping students in the JCPS school district have a place to sleep.

With hammers and screw drivers in hand and donated lumber, volunteers, including members of the Louisville Chapter, gathered at Thomas Jefferson Middle School to build beds for children in the JCPS school district who may not have places to sleep. 

Leading up to the event, Louisville credit unions helped prepare by collecting 150 pillows, 150 sheet sets and books. 

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CUNA Marketing and Business Development Council Diamond Awards

Thirty-six categories, 1,200+ entries, big bling and bragging rights! The most prestigious annual credit union industry competition, the Diamond Awards recognize and reward creative excellence and outstanding results in credit union marketing. 

Congratulations to the following Kentucky credit union on their Diamond Awards! 

  • Commonwealth Credit Union, Frankfort, KY
  • Fort Knox Federal Credit Union, Radcliff, KY
  • Kentucky Employees Credit Union, Frankfort, KY
  • University of Kentucky Federal Credit Union, Lexington, KY

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Prioritizing member service leads small CUs to success

As president/CEO of a small credit union, Lori Herrick said her credit union focuses on serving member needs. An that’s how Manchester Municipal FCU, Manchester, Conn., is able to run an in-house student loan program for the past decade and “never have a single charge-off, nor amazingly, have one of these loans reach even 30 days of delinquency,” she wrote in Credit Union Journal. 

“Up until 2009, when we launched the program, we were turning away countless members who wanted to send their kids to college but didn’t know how to pay for it. We heard many stories from members who had student loans they’d been paying off for years without being able to make a dent in the principal. Or they’d been hit with fees. Or they were paying interest rates of 10% or more,” she wrote. “It broke my heart, and I knew we had to step in.

“The biggest concern, of course, was the risk. Anyone we consulted with on a potential program warned of that next big bubble, of the possibility of exposing the credit union to massive charge-offs,” Herrick added. “But we knew our members. We knew we could create a successful program.” 

Herrick, the vice chair of CUNA’s Small Credit Union Committee, said she has been part of CUNA’s work to raise awareness of having a strategic focus as a small credit union. 

Her op-ed details how Manchester Municipal FCU was able to launch the program, how it ties into the credit unions’ financial education efforts and how it led it to launch an equally successful student loan consolidation program. 

“It should come as no surprise that this program benefits the rest of the credit union as well. Members who have taken out student loans now have credit cards with us, auto loans and personal loans. We are their primary financial institution,” I certainly would encourage anyone to consider this program for their credit union. It’s clearly a need across the country. But for me, it’s not really even about the student loans. It’s about our original purpose, our original focus as a credit union – serving the needs of our members. For small credit unions, for all credit unions, it’s really as simple as that.”

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2019 Crash the CUNA America's Credit Union Conference (ACUC) 

Are you a credit union young professional (35 & under, or "35 at heart") interested in developing professionally? If so, the Crash program is for you!

WHAT'S A CRASHER?

Crashers are credit union young professionals who are sponsored to attend a conference at a lower cost and with additional content designed especially for them. You'll get professional development tools, meet with industry leaders, network with peers, and experience each event in a dynamic way. Applications are easy, and the entire experience is career-changing! 

YOU CAN APPLY ON THE NEXT PAGE FOR JUST ONE CRASH (see "Next" button below), OR YOU CAN APPLY FOR MULTIPLE CRASHES AT ONCE!

Click here to be taken to our Master Application instead - submit it to be considered for up to three Crash events!

WHAT IS THIS CRASH WE SPEAK OF?

We'll be Crashing CUNA's America's Credit Union Conference at the Walt Disney World® Resort in Florida from June 17-20! Crashers will receive complimentary conference registration to the conference! 

Applications for Crash ACUC are due by May 6 at 11:59PM CST

Any questions before applying? Email us at [email protected]. Good luck!

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Upcoming Events: Mark Your Calendars

Your League hosts several education and training opportunities throughout the year.  Don’t forget to mark the following dates in your calendars so you don’t miss out!

May 8-10: Leadership Conference (formerly Management Conference) Lawrenceburg, IN
June 5:    Compliance Mini-Workshop (AM & PM Sessions) Louisville, KY
June 7-14 Southeast CUNA Management School Athens, GA
June 12: CECL Roundtable (Separate from NASCUS) Louisville, KY
July 21-24: Southeast Regional Directors Conference Louisville, KY
October 2-4: KCUL Annual Meeting & Convention Lexington, KY
October 29-30: MLO Workshop TBD

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You can still register for the Leadership Conference!

May 8-10, 2019 | Doubletree by Hilton | Lawrenceburg, IN

Educational Investment: $450 per person 

We are co-hosting with the Indiana Credit Union League to offer valuable networking opportunities with peers across our state line.

The Leadership Conference (formerly known as the Management Conference) is specially designed to re-ignite passion in our credit union leaders.  This conference is open to CEOs, Executive Management Teams, Office Managers, Board Chairpersons, and Future Leaders.

This conference offers a top-notch speaker lineup that you won’t be able to find anywhere else for the money:

  • Cortney Angeley, Communities & Events Director, Filene Research Institute
  • Sam Das, Director of Corporate Development, CUNA Mutual Group
  • Andy Janning, Nationally-Recognized Credit Union Expert, President of NO NET Solutions
  • Michele Lawlis Shelton, Professional Speaker, Author, and Consultant on Human Relations in the workplace
  • Rolanda London, Fraud Investigator, Park Community Credit Union
  • David Smith, President, Baxter Capital Management, an SEC-registered investment firm

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Save the Date: Compliance Mini-Workshop

June 5, 2019 | League Office | Louisville, KY 

Regulatory compliance issues continue to create challenges for credit unions. This half-day workshop will discuss hot compliance topics and offer an in-depth analysis of the most current, proposed and final rules. Learn from a practical perspective what your credit union needs to do to comply.

Request to be notified when additional details become available.

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2019 Southeast Director’s Conference

July 21 – 24, 2019 | The Seelbach Hilton | Louisville, KY

Save the date and make plans to join your peers from credit union boards across the Southeast for two-and-a-half days of education designed for credit unions’ volunteer leaders. The 2019 Southeast Director’s Conference, set for July 21 – 24, 2019, features a full range of informative sessions on critical, timely issues, with first-rate speakers to address the economy, lending environment, and much more.

Click here for detailed conference information, including agenda, speakers, hotel information, and more!

Click here to reserve your room.

The Southeast Regional Directors’ Conference is designed for credit union directors and committee members. The conference location rotates among the ten Southeastern states, giving each state an opportunity to host their fellow credit union volunteers and showcase the best of what their state has to offer. This conference features a full range of informative educational sessions that provide a conduit for learning about critical issues important to today’s ever-changing financial industry.

The 2019 program will be hosted by the Kentucky Credit Union League and held at The Historic Seelbach Hilton, in the heart of Downtown Louisville, Kentucky; conveniently located 10 miles from Louisville International Airport.

At the Seelbach Hilton, you’ll experience modern amenities wrapped in a storied past that delivers distinct character. The Seelbach Hilton is equal parts historical landmark and architectural masterpiece. A stay at this grand luxury hotel appearing on the National Register of Historical Places will never be described as “ordinary.”

Louisville is home to iconic attractions that visitors can’t experience anywhere else. Here, you can bet on the ponies at Churchill Downs (home of the Kentucky Derby), get inspired at the Muhammad Ali Center, see the craftsmanship firsthand at the Louisville Slugger Museum & Factory, go back in time on the Belle of Louisville, tour Bourbon distilleries and more. 

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Commonwealth CU wins Diamond Awards

The CUNA Council recently held their Marketing and Business Development conference in Las Vegas, Nevada. They gave out their annual Diamond Awards, and Commonwealth Credit Union hit the jackpot! The Diamond Awards are the most prestigious annual credit union industry competition. They recognize creative excellence and outstanding results in credit union marketing.

CCU won awards in the categories of video commercial 30 seconds or less and membership marketing. CCU’s 30 second commercial was one of their new Inspire Big Change Home Equity commercials. The membership marketing award was for the LouChem merger materials including the brochure, website, text campaign, and info booklet.

Commonwealth is so excited and truly honored to receive these awards.

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Daviess County’s Hometown Credit Unions

Daviess County Chamber of Commerce held their annual Chamber Worx Expo on April 25th at the Owensboro Convention Center and Daviess County’s credit unions partnered to showcase Daviess County’s Hometown Credit Unions.

Their shared booth featured a display in the center detailing the credit union difference.  On either side, each credit union displayed information on their own credit union.

Several Expo attendees took notice of the shared booth.  “Banks don’t do stuff like this,” said one attendee.  “Aren't you guys supposed to be in competition with each other?” asked another attendee.  The shared booth also sparked many positive and interesting conversations.

As a booth door prize, Daviess County’s hometown credit unions gave away a mirror.  On the front, the mirror was framed by coins.  On the back, the winner’s name was printed along with a list of Owensboro credit unions. 

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Park Community Credit Union, and the Louisville Urban League Teaming Up for Girls’ Summit 2019

Park Community Credit Union, and the Louisville Urban League are hosting the 2019 Middle School Girls’ Summit on Thursday, June 20th, 2019.

This exciting event will center on the challenges girls (ages 11-14) face today, focusing on building healthy lifestyle, financial literacy, and personal responsibility skills. At the 2018 event, 50 girls participated in an incredible day of learning and connection. In 2019, Park Community Credit Union wants to share this experience with even more girls. The Summit will also celebrate the dynamic women making a difference in our community and promote their example as role models and mentors to the girls. Park Community Credit Union had over 70 women in the community participate in 2018!

The Summit this year will again draw on the insights of accomplished women in our community to help cultivate the attendees into future leaders, giving the girls the tools they need to do and to be their best.

Held at the Gheens Foundation Lodge at the Parklands on Thursday, June 20th from 8am to 4pm. Those interested in attending the summit should visit the Park Community Credit Union website at parkcommunity.com, the Louisville Urban League at lul.org or the Eventbrite registration page.

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Park Community teams up with Louisville nonprofit for loan program

LHOME, a Louisville nonprofit organization, and Park Community Credit Union are teaming up on a new loan program.

Earlier this week, LHOME — which is short for The Louisville Housing Opportunities and Micro Enterprise Community Development Loan Fund Inc. — closed on a $500,000 loan pool from Park Community. The money will be made available immediately.

Affordable housing nonprofits, homeowners in need of property tax assistance and small minority and women-owned businesses will be eligible for loans. At least 60 percent of all loans must go to low-to-moderate income census tracts in Jefferson County.

This loan fund is for LHOME to deploy directly to borrowers. It is the originator, lender and servicer of all of the loans.

LHOME got a 2.5 percent interest rate on the loan fund from Park Community.

"Park Community Credit Union shares our mission of providing and protecting ownership opportunities for our low-income community members across Louisville," Amy Shir, LHOME's president and CEO, said in a news release.

“We look forward to working with LHOME to build upon our impact in the Louisville community and particularly the underserved areas of the city," Jim Spradlin, president and CEO of Park Community Credit Union, said in the release. "At Park we are committed to having meaningful impact throughout the city regardless of geography or socio-economic standing. We feel strongly that everyone deserves to have access to fair and affordable financial services and we are working to make that a reality.”

Park also has installed an interactive teller machine inside St. Stephen Church on South 15th Street and is designated as official credit union of Simmons College of Kentucky and St. Stephen Church.

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Service One CU Hired Director of Learning and Development

Service One Credit Union is pleased to announce the appointment of Amy Goodson as Director of Learning and Development for the Credit Union.  Amy has 7 years of Human Resources, associate education, and training facilitator experience with 6 years in a leadership role.

Amy is a graduate of the University of Louisville.  She has served on the Steering Committee for Warren County Area Technical School and is presently serving as Vice Chair of the Training Consortium Board of SCK at the Chamber of Commerce and as a Council Member for the University of Louisville Alumni Women’s Council.  Amy is a Certified Life Coach as well as holds certifications for facilitation for Extended DISC, Four Rooms of Change and Strengths Genius. 

Her hobbies include traveling and spending time with her family and friends.  Amy is passionate about her volunteer work including such organizations as Wounded Warrior Project.  She also serves as an Advocate for the Cure SMA Foundation.

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University of Kentucky Ranked 38th Nationally in Best-Performing Credit Unions

S&P Global Market Intelligence has ranked the University of Kentucky Federal Credit Union 38th nationally, in its best-performing credit unions in the United States for 2018.

“S&P Global Market Intelligence ranked the nation’s credit unions using five core financial performance metrics: member growth, market growth, operation expense as a percentage of operation revenue, net charge-offs as a percentage of average loans and delinquent loans as a percentage of total loans. Each company’s standard deviation from the industry mean was calculated for every ranking metric, equally weighted, then added together to calculate a performance score.”
“To help normalize the data and mitigate the impact of outliers, caps and floors were applied for each metric. To be eligible for the ranking, a credit union had to report more than $500 million in total assets and a net worth ratio of at least 7.0% as of Dec. 31, 2018. Based on these criteria 552 credit unions qualified for ranking” (Khawaja & Pirazada, 2019).

 

The University of Kentucky Federal Credit Union (UKFCU) finished within the top 50 best-performing U.S. credit unions of 2018 with the following metrics:  $864.6M in assets, member growth 34.8%, market growth 12.9%, operating expense/operation revenue 64.80%, net charge-offs/average loans .71%, and total delinquent loans/total loans .49%.  

David Kennedy, CEO/President of UKFCU, notes that one of the reasons UKFCU has had such success has been their drive to focus on operation efficiency and the fact that their cost of operation is significantly lower than other credit unions their size.  Mr. Kennedy also states, “UKFCU is a leader in the credit union industry in terms of growth, safety, and financial performance for two simple reasons.  First, our membership is very supportive of us and recognizes the value we are able to deliver to them in comparison to other financial service providers.  Second, every decision the Board of Directors and Management Team makes has the overarching goal of providing even greater value to the membership.  These are very tangible values, such as providing the lowest loan rates, the highest deposit rates, and lowest fees for services we can deliver.  When we do this, we are able to impact our members’ lives in a positive way.  Nothing illustrates this impact better than our growth and the return we generate on our assets”.

As one of the fastest growing and highest performing credit unions in the country, UKFCU has been nationally recognized as an exceptional credit union that has consistently grown at a strong pace, and improved their safety and financial strength steadily for more than a decade. This progress is notable by placing 38th in S&P Global Market Intelligence’s 2018 ranking of the 50 top-performing U.S. credit unions.

Reference:

Khawaja, A. & Pirazada, U. (March 20, 2019) United States Senate FCU jumps 43 spots to lead 2018 union rankings. S&P Global Market Intelligence.

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FFIEC Issues 2019 HMDA Guide

The FFIEC has released the 2019 edition of its Guide to HMDA Reporting: Getting It Right! The 2019 version reflects amendments made to HMDA by the Economic Growth, Regulatory Relief, and Consumer Protection Act (SB 2155) and the 2018 HMDA interpretive and procedural rule issued by the CFPB.  FFEIC notes that the appendices provide additional implementation materials that credit unions may find useful. 

Click here to view the Guide to HMDA Reporting: Getting it Right!   

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NCUA Issues Final Rules on Loans and Lines of Credit to Members

On March 14, 2019, the NCUA approved a final rule amending NCUA’s Rules and Regulations regarding loans and lines of credit to members to reduce regulatory burden, improve clarity, and make compliance easier.

Summary

The final rule amends NCUA’s Rules and Regulations in the following three ways:

  1. Identifies the various maturity limits in one section. Currently, §701.21 addresses various loan maturity limits in paragraphs (c), (e), (f) and (g). To help with organization and clarity, the final rule moves the NCUA’s loan maturity requirements applicable to FCU loans within one section (§701.21(c)(4)), including cross-citations.
  1. Clarifies that the maturity for a new loan under GAAP is calculated from the new date of origination. The final rule clarifies that, in the case of any lending action qualifying as a new loan under GAAP, the maturity limit is calculated from the new date of origination. A lending action is described as a new origination or a modification. To accomplish this, the NCUA adds language to §701.21(c)(4), which articulates the general 15-year maturity limit.
  1. Clearly describing the limits for loans to a single borrower or group of associated borrowers. Three provisions of the NCUA’s regulations address limits on loans to a single borrower or group of associated borrowers:
  • §701.21(c)(5) addresses the general limit;
  • §701.22(b)(5)(iv) addresses the limit on loan participations; and
  • §723.4(c) addresses the limit on commercial loans.

To help identify the various limits, the final rule includes cross-citations to the more specific loan participation and commercial loan limits in the general limit section. 

The final rule also makes amendments to update cross-citations to the single borrower and group of associated borrower limits in § 701.20(c)(2) and §701.22(b)(1).

The final rule became effective April 24, 2019.

Click here to view the final rule.

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Regulators Released FAQs on CECL Standard

On April 3, 2019, the NCUA, together with other federal regulators, issued an updated FAQs document to assist credit unions in their implementation with the new current expected credit losses (CECL) accounting standard.  These FAQs expand on the June 2016 Joint Statement on the New Accounting Standard on Financial Instruments – Credit Losses.

Background

The agencies, including the NCUA, published FAQs in 2016 and 2017 to assist institutions, including credit unions, and examiners. The focus of the FAQs is on the application of CECL and related supervisory expectations.

CECL applies to all institutions, including credit unions, regardless of size, that files regulatory reports for which the reporting requirements conform to U.S. generally accepted accounting principles (GAAP). Moreover, until the CECL becomes effective, credit unions must continue to follow current U.S. GAAP on impairment and the allowance for loan and lease losses (ALLL). The agencies will not rescind existing supervisory guidance on the ALLL until CECL becomes effective for all institutions.

Summary

The recent updated FAQ document includes the following:

  • Updated four existing responses that:
    • Pertain to Questions #4, #18, #34, and #35.
    • For credit unions considered as nonpublic business entities (non-PBEs) under the standard, the credit losses standard is effective for fiscal years as of December 15, 2021, including interim periods within those fiscal years. 

For non-PBE with a calendar year fiscal year, the standard is effective January 1, 2022 with the application of CECL methodology applied in its financial statements and Call Reports for the quarter ended March 21, 2022.

Accordingly, responses to Questions #4, #34, and #35 have been updated to reflect the new effective date for non-PBEs.

  • Added nine additional FAQs (Questions #38- #46) that discusses:
    • Consideration of stress testing models, scenarios, and forecast periods when forecasting future economic conditions for CECL;
    • Clarification of the use of the term “smaller and less complex” related to the scalability of CECL;
    • Internal control considerations that are appropriate to the size of the institution for CECL implementation;
    • Accounting implementation issues; and
    • Concepts in existing interagency policy statements related to the allowance for loan and lease losses that remain relevant. 

Click here to view the FAQ document.

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Q&A Regarding Returned Mail

Q:  When sending out member correspondence and statements we have “return service requested” on envelopes so we get notified by the post office of any address changes.  When we receive these items back and a change of address label is attached with a new address we currently make the change and send an email to the member indicating a change has been made.  An employee went to a conference and heard that this practice should not be used when it comes to issuing credit and debit cards.  Why is this?

A:  The NCUA’s guidance states the following: 

III. Duties of Card Issuers Regarding Changes of Address (Card Issuers’ Rules) 8 A. IV. Duties of Users Regarding Address Discrepancies (Address Discrepancy Rules) 

Address validation requirements 

  1. Can a card issuer rely upon the US Postal Service’s change of address procedures to validate a change of address for purposes of the Card Issuers’ Rules?

The fact that a card issuer received a change of address notice from the US Postal Service is not sufficient to satisfy the validation requirements of the Card Issuers’ Rules. A card issuer that receives a notice of a change of address from the postal system regarding a cardholder’s address, and, within at least 30 days, a request for an additional or replacement card, may not issue the card unless it has validated the cardholder’s address using one of the procedures set forth in the Card Issuers’ Rules. 

Additionally, credit and debit card issuers must develop policies and procedures to verify a request for a change of address that is followed closely (within 30 days or a longer period established in a creditor's or a financial institution's procedures) by a request for an additional or replacement card. A card issuer cannot issue the additional or replacement card until it has verified the validity of the change of address request in accordance with the financial institution's policies and procedures. If a change of address request has been verified before a request for an additional or replacement card is received, it is not necessary to verify the address a second time before issuing the card. 

Source:  NCUA

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