With regard to interest rate risk, Chairman Matz stated:
Given the refinancing activity that typically occurs during a period of low interest rates, NCUA has observed an increasing level of fixed rate real estate loans … NCUA is concerned with the increasing interest rate risk associated with a high level of fixed rate, long-term assets should rates rise rapidly.
As for member business lending, she testified:
NCUA has been monitoring the increasing level of member business loans within the credit union community, presently at $27.1 billion. While this figure represents only 3.11 percent of total credit union industry assets, NCUA is concerned with the increasing levels of delinquent member business loans, as well as an increasing concentration of large credit unions with supervisory concerns which are holding member business loans. As an example, a review of 71 credit unions with identified supervisory concerns was conducted as of June 30, 2009. These credit unions averaged $1.1 billion in assets and 62 of them reported member business loans. By way of contrast, in 2005, only 50 of these same credit unions held member business loans. These credit unions hold higher levels of member business loans than the industry as a whole, both in 2005 and today… For this group, delinquent member business loans increased from 0.17 percent to 8.34 percent in the last 42-month period, compared to the credit union trend of 0.47 percent to 3.19 percent during this same timeframe… NCUA is concerned with the additional risks to operations member business loans can pose when coupled with other operational concerns. NCUA will be proactively monitoring member business loan exposure and plans to issue additional guidance in the near future.
The agency is also concerned about the growing number of problem credit unions. A problem credit union has a CAMEL 4 or 5 rating. Chairman Matz noted:
There are currently 326 troubled credit unions holding $42.2 billion in assets, representing 4.2 percent of all credit unions and 4.9 percent of all credit union assets. While the number of troubled credit unions increased in the current year, the pace of that growth was slightly lower than in 2008. Troubled credit unions with over $100 million in assets have grown at a faster rate than those with assets under $100 million.
As of September 30, 2009, 66 credit unions with assets over $100 million were considered troubled credit unions, compared to 12 in 2007. NCUA anticipates the overall number of troubled credit unions is likely to increase through the end of 2010 and into 2011.
Later in her testimony, she expressed concern about the number and size of CAMEL 3 credit unions is increasing. A CAMEL 3 credit union exhibits some degree of supervisory concern. These credit unions exhibit a combination of weaknesses that may range from moderate to severe and generally are less capable of withstanding business fluctuations and are more vulnerable to outside influences.
The number of CAMEL 3 credit unions with assets greater than $100 million represented only 7.30 percent of total credit unions as of year-end 2007; however, this ratio increased to 13.48 percent as of September 30, 2009. Similarly, total assets for this group of credit unions increased to 10.43 percent of aggregate industry assets as of September 30, 2009, up from only 3.97 percent in 2007. While credit unions rated a CAMEL 3 have not quite reached the threshold of a troubled credit union, … they require enhanced and timely supervision to ensure corrective measures are implemented.
In response to these emerging trends, NCUA has shortened the examination cycle from 18 months to 12 months. It also has hired an additional 50 field examiners in 2009 and plans to hire 57 more examiners in 2010.
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