Friday, July 25, 2014

Prudent Capital Management Should Include a Buffer

In case you missed it, credit unions should read NCUA Board member Rick Metsger's column in the July 2014 NCUA Report.

Metsger believes that prudent capital management should include a capital buffer above the minimum requirement for being well-capitalized.

Metsger wrote:

Maintaining a buffer, like a reserve fuel source, is certainly prudent management—but how much of a buffer is actually needed? As currently written and using the most recent data, the proposed rule identifies 20 credit unions that are undercapitalized and an additional 210 credit unions in the “buffer zone” as adequately capitalized. In total, these 230 credit unions represent just 7.6 percent of credit union assets subject to the proposed rule. Another 15.5 percent of credit unions are well-capitalized, but with less than 20 percent cushion above the 10.5 percent threshold as shown in the
graph to the right.

The remaining 1,595 credit unions with more than $50 million in assets—which collectively hold 77 percent of covered credit union [assets] already have at least a 20 percent risk-based capital buffer. In fact, a quarter of a trillion dollars in assets reside in credit unions whose buffer is a whopping 50 percent or more than the well-capitalized standard.

Reasonable people can debate what constitutes a prudential buffer. But a 20 percent cushion above a credit union’s “yellow warning light” is a pretty big buffer.

So while Metsger is trying to tell most credit unions covered by the proposed rule that they are holding more than enough capital and should not worry about the proposed risk-based capital rule, I believe NCUA is signalling its expectations to credit unions that a risk-based capital ratio of 10.5 percent, which is the minimum requirement for being well-capitalized, is not enough.

7 comments:

  1. 7.6% of assets are less than well capitalized?
    And that's just the credit union w assets greater than $50 million.
    What is the FDIC number?
    This seems high.

    ReplyDelete
  2. Credit unions would be well capitalized except for the NCUA assessments imposed upon them because of the extraordinary incompetence from the NCUA. The NCUA failed to competently audit Telesis, CA State#9, WesCorp, USCentral, etc. and they were all placed into conservatorship. Huge losses. NCUA covers the losses by assessments on the credit unions still standing. Now the NCUA complains we don't have enough capital. Of course we don't. The NCUA stole it.

    ReplyDelete
    Replies
    1. Let us not forget NCUA "examiners" had their own offices at WesCorp and still couldn't stop the bleeding. As a 33 year credit union professional, I think it's time to merge NCUA into FDIC, keep the credit union industry intact but have a competent regulator oversee us.

      Delete
  3. Only 0.2 percent of the banking industry's assets reside in banks that do not meet the requirement of being well-capitalized.

    ReplyDelete
  4. I believe you are comparing the wrong numbers. Metsger was referring to the proposed ris based capital requirements to derive his numbers. The NCUA is applying much higher risk weights than FDIC so there is no way to correctly compare banks and credit unions. One thing is clear however, credit unions have a higher net worth ratio than banks.

    ReplyDelete
    Replies
    1. You are incorrect. Re-read his comments. AND the nw ratio of banks is higher. Its easy to look up

      Delete
  5. If this regulation pases as proposed, I predict a significant number of CU conversions to bank charters.

    ReplyDelete

 

The content is provided for educational purposes only, with the understanding that neither the authors, contributors, nor the publishers of this site are engaged in rendering legal, accounting or other expert or professional services. If legal or other expert assistance is required, the services of a competent professional should be sought.

Comments appearing in response to articles appearing on this site do not necessarily reflect the views of the ABA. ABA makes no representations regarding the truth or accuracy of commentary or opinions that may be posted in response to the articles that appear on this website.

The inclusion herein of any link to a website, either in the text of an article or in a comment, does not denote any approval, sponsorship, or endorsement by the ABA, and ABA is not responsible for the content or opinions expressed on those linked websites or related commentary. This content is not licensed to third parties sites and is not affiliated with any third party site. Any reference to the author or this content on any third party site on the Internet is not authorized by the ABA.

It is the policy of the American Bankers Association to comply fully with all antitrust laws. Certain discussions should be considered off-limits, including those that contain competitively sensitive data such as price and cost information, or statements that could be construed as reflecting an attempt or desire to control or influence a particular market or markets. Future pricing or other prospective competitive information should never be shared.