Voluntary Prepaid Assessments Should Be Transferable

I have a suggestion that I believe would improve NCUA's proposed voluntary prepaid assessment program for the Temporary Corporate Credit Union Stabilization Fund -- allow federally-insured credit unions to transfer the prepaid assessments among themselves.

This prepaid assessment is just like any asset and credit unions should be able to buy or sell prepaid assessments if there is an economic reason to do so.

Additionally, allowing credit unions to transfer their prepaid assessments among themselves would be a useful liquidity management tool for some credit unions, particularly if there is significant variation between what they prepaid and what they will be actually assessed.

If credit unions are looking for precedent, they only need to look at what FDIC did in 2009. The FDIC allowed for the transferability of bank's prepaid assessments.