Friday, February 28, 2020

Event Center Named After American 1 CU Opens on February 28

American 1 Credit Union Event Center at Keeley Park opened on Friday, February 28.

The new 30,000 square foot American 1 Credit Union Event Center is a multi-use facility that can seat as many as 800 guests.

American 1 Credit Union (Jackson, MI) provided $4 million for the $6.4 million event center.

Read more.

Thursday, February 27, 2020

ABA: CRA Should Be Applied to Large CUs

Congress must do more to ensure that the nation’s largest credit unions are accountable to their statutory mission to serve individuals in low- to moderate-income areas, the American Bankers Association (ABA) said in a new ABA Data Bank post.

Citing data from S&P Global, ABA Chief Economist James Chessen noted that among large credit unions with more than $500 million in assets, the majority of branches—73%—are currently concentrated in middle- and upper-income communities, while just 6% are located in low-income areas.‌

“These largest credit unions receive the highest dollar benefit from the tax exemption, yet they have chosen to focus their resources on the well-to-do rather than using their tax advantage to help expand cheaper credit to those who need it most,” Chessen wrote. “Simply put, they are using their tax-exempt status to make profitable consumer and business loans to people who do not need taxpayer-subsidized financial services and can afford to shop around for financial products elsewhere.” By contrast, he noted that of all the credit union branches headquartered in low-income communities, two out of three are operated by small credit unions.‌

One way Congress could ensure greater accountability for large credit unions would be to require them to comply with the Community Reinvestment Act (CRA), as taxpaying banks are required to do, Chessen said. “If these credit unions are in fact meeting the needs of low- and moderate-income people, they should have no fear of demonstrating that explicitly as banks must do.”‌

ABA’s blog post echoed findings from a report issued last year by Federal Financial Analytics that highlighted the need to impose mission-related requirements on credit unions. In recent days, writings by the National Taxpayers Union and the Tax Foundation have also emphasized the immediate need for Congress to revisit the credit union tax exemption.

Read the blog post.

Wednesday, February 26, 2020

NCUA's Harper Discusses Liquidity, Consumer Debt, and Succession Planning

Speaking before the Credit Union National Association Government Affairs Conference on February 26, National Credit Union Administration Board Member Todd Harper discussed three issues on the horizon that will impact credit unions.

First, Harper focused on liquidity. Harper noted that the industry's loans-to-shares ratio bottomed out in 2012 and 2013 at approximately 66 percent, but it has since rebounded due to strong loan growth. The ratio now is about 84 percent nationally and in some states like Vermont and Wisconsin, it exceeds 90 percent. He cautioned that credit unions of all sizes need to maintain ample access to cash to withstand unexpected emergencies.

Second, Harper addressed the issue of consumer debt. He pointed out the total household debt is higher than before the Great Recession. While he stated that asset quality remains good at credit unions, there are some warning signs. The percentage of credit cards that are 90 days or more past due exceeded 5 percent. He warned that if a recession occurs, delinquencies and charge-offs will rise. He told the credit union attendees that they should be carefully evaluating new credit risk and taking steps to mitigate delinquencies in their consumer loan portfolios.

Third, Harper addressed the issue of succession planning. He stated that approximately 20 percent of credit unions do not have a succession plan. He commented the lack of succession plan is one of the top two reasons for credit union mergers. He then pointed out that a large proportion of credit union CEOs and executives are Baby Boomers, who will be part of a retirement wave. He encouraged the credit union officials to raise the issue of succession planning in board discussions to ensure the survival of their credit unions.

Other topics he discussed included diversity and inclusion and compliance with consumer financial protection.

Read the speech.

NCUA's Hood Discusses the Process for Selling Off Taxi Medallion Portfolio

National Credit Union Administration (NCUA) Board Chairman Rodney Hood on September 25 provided more insights into the agency's process in selling off its tax medallion portfolio it assumed from failed credit unions.

Addressing the Credit Union National Association Government Affairs Conference, Chairman Hood commented that NCUA evaluated a number of options, but came to the determination that a singular bulk sale would be in the best interest to the National Credit Union Share Insurance Fund.

Hood told the audience that NCUA received bids for a portion of the medallion portfolio from interested bidders, but concluded that the sum of the subset bids were less than the bids for the overall portfolio.

He noted that NCUA in consultation with its financial advisors reached out to 23 firms with experience in handling distressed commercial assets. Six of these firms submitted bids. NCUA allowed two firms go through to the final due diligence bid round and received two independent offers. The agency turned away some firms because it lacked confidence that the firms would treat borrowers in a fair way.

Hood cautioned credit unions that "[h]olding these medallion assets beyond a reasonable period" could result in the agency repeating past mistakes. The past mistake is referencing the properties in Florida that were assumed by NCUA with the failure of Norlarco and Huron River Area Credit Unions.

Read the speech.

Tuesday, February 25, 2020

NCUA's McWatters Defends Selling Taxi Medallion Portfolio

At the Credit Union National Association's Government Affairs Conference, National Credit Union Administration (NCUA) Board Member McWatters on February 24 defended the agency's decision to sell its portfolio of taxi medallion loans.

McWatters was responding to criticism the agency should have waited for a possible initiative from the New York Taxi Workers Alliance to form a public/private partnership to purchase the agency’s medallion loan portfolio.

However, McWatters stated that postponing the sale would have been inappropriate.

McWatters claims that if the agency postponed the sale, it would have lost the winning, least cost bidder.

The winning bidder, Marblegate Asset Management, was ready, willing, and able to close on the transaction, according to McWatters.

Postponing the sale would have most likely resulted in additional material losses for the National Credit Union Share Insurance Fund (NCUSIF), which would cause NCUA to "forgo distributions to credit unions for the intermediate future, if not longer."

McWatters told the crowd that NCUA "retained the services of outside consultants and investment advisors who assisted us in developing a plan to sell the taxi medallion loan portfolio pursuant to an open and transparent auction process."

In addition, McWatters addressed the topics of credit unions acquiring community banks and credit unions maintaining adequate capital and liquidity levels.

Read the speech.

Washington CU Regulator Expects CUs to Measure Consumer Complaints

The Washington Division of Credit Unions is expecting that credit union board of directors and senior management should receive periodic reports regarding consumer complaints.

The state regulator stated that these periodic reports should include the following:
  • The volume and types of complaints received;
  • The channels in which complaints are received (e.g. social media, email, in person);
  • The reimbursements paid for potential violations of consumer protection laws; and
  • Any identified trends.
In addition, credit unions should clearly define procedures for processing member complaints, including complaints pertaining to third party service providers.

Sunday, February 23, 2020

Congressman Meeks Critical of NCUA's Decision to Sell Taxi Medallion Loans

Representative Gregory Meeks (D - NY) on February 20 stated he stands strongly against the sale of taxi medallion loans by the National Credit Union Administration (NCUA) to Marblegate Asset Management LLC.

In a statement, Meeks commented that while "some banks are recognizing the unsustainable bubble of medallion debt and providing debt forgiveness, it is discouraging to see NCUA move in the opposite and wrong direction."

Read the press release.

Friday, February 21, 2020

There Were Fewer Problem CUs During Q4 2019

The number of problem credit unions fell during the fourth quarter of 2019, according to the National Credit Union Administration (NCUA).

At the end of 2019, there were 190 problem credit unions. In comparison, there were 200 problem credit unions at the end of the third quarter of 2019.

A problem credit union has a composite CAMEL rating of 4 or 5.

Total assets in problem credit unions were $10.8 billion at the end of the fourth quarter. Assets in problem credit unions were $11.2 billion at the end of the third quarter.

Shares (deposits) in problem credit unions declined during the fourth quarter to $9.7 billion from $10.1 billion as of September 2019. At the end of 2019, 0.79 percent of total insured shares were in problem credit unions. In comparison, 0.84 percent of total insured shares were in problem credit unions as of June 2019.

Most problem credit unions were small credit unions.

NCUA reported that almost 88 percent of the problem credit unions have less than $100 million in assets, while 1.6 percent of problem credit unions have more than $500 million in assets.

NCUA reported that there were only 2 credit unions failures in 2019 that resulted in a loss to the National Credit Union Share Insurance Fund, which was down from 8 in 2018.

Thursday, February 20, 2020

NCUA Completes Bulk Sale of Taxi Medallion Loans (updated at 8:19)

The National Credit Union Administration (NCUA) on February 19 announced the sale of the majority of its taxi-medallion loan portfolio to Marblegate Asset Management LLC.

After thorough research and careful consideration, NCUA determined this sale was the most appropriate action to meet its statutory obligation under the Federal Credit Union Act to achieve the least long-term cost to the National Credit Union Share Insurance Fund.

NCUA’s holdings included medallion loans from Melrose Credit Union and LOMTO Federal Credit Union, which supported the New York City taxi industry for nearly a century until their liquidations in 2018.

NCUA determined a single bulk sale was the best option to meet its statutory requirements and prevent any unnecessary volatility in the already stressed taxi medallion market.

The agency did not disclose the sale price.

However, the Wall Street Journal (subscription required) is reporting that Marblegate Asset Management was nearing a deal to buy almost 4,500 medallion loans for around $350 million, according to unnamed sources.

Read the press release.

Read the FAQ.

Wednesday, February 19, 2020

Taxpayer Group Calls on Congress to Take a Fresh Look at CU Tax Exemption

The National Taxpayers Union, a nonpartisan taxpayer advocacy group, is calling on Congress to re-examine the tax exemption of large, bank-like credit unions.

The issue briefing paper noted the trend of large credit unions acquiring community banks. For example, the National Taxpayers Union cited Lake Michigan Credit Union's acquisition of a southwest Florida bank, despite the credit union's headquarter being 1,000 miles away.

The National Taxpayers Union wrote: "Permanently taking taxpaying business entities off treasuries’ tax rolls and shrinking the tax base is a textbook example of poor tax policy."

The paper also pointed out the erosion of the credit union's field of membership as another reason for Congress to take a look at the credit union industry's preferential tax treatment.

In addition, federal credit unions are not required to file Form 990 to the Internal Revenue Service. The National Taxpayers Union believes that large federal credit unions should be subject to Form 990 filing requirements, just like other tax-exempt entities. Requiring large federal credit unions to files a Form 990 would result in greater transparency and accountability at these institutions.

Furthermore, the Form 990 "is the main enforcement mechanism to ensure compliance with Section 13602 of the Tax Cuts and Jobs Act, which requires a 21 percent excise tax on not-for-profit executive compensation above $1 million."

Moreover, the taxpayer group noted that federal credit unions are not subject to Unrelated Business Income Tax, because they are viewed as instrumentalities of the federal government. This allows federal credit unions to avoid paying taxes on profits that are not related to their core mission. For example, the paper notes that some federal credit unions have gotten into the commercial real estate business and are leasing out excess office space to other businesses. This activity is not part of the core business of federal credit unions and should be taxed.

The taxpayer group concluded that "[w]ith many credit unions growing significantly in both size and scope, it is time for Congress to reevaluate the tax exemption and other tax-related provisions governing credit unions."

Read the paper.

Tuesday, February 18, 2020

IG: Examiners Could Have Done More to Detect Fraud at C B S Employees FCU

The National Credit Union Administration's Inspector General (IG) is critical of examiners for losses to the National Credit Union Share Insurance Fund (NCUSIF) arising from the failure of C B S Employees Federal Credit Union.

According to the Material Loss Review, the failure of the credit resulted in an estimated loss of $39.5 million to the NCUSIF.

The IG determined that the failure was due to the misappropriation of $42.2 million in cash, due to fraud. The credit union's former CEO concealed the losses by understating member share balances, primarily share certificates, on the financial statements. The embezzlement occurred unabated for almost 20 years.

The IG noted that the lack of segregation of duties and dual control allowed the former CEO to perpetrate and conceal the fraud. The former CEO possessed all of the following:
  • Access to official credit union checks, which enabled him to alter the physical records of credit union checks;
  • "Super-user" access to the credit union's accounting system, which enabled him to alter both the check payee information and file maintenance reports, which concealed this action; and
  • Sole responsibility for financial reporting, which gave him the ability to prepare fraudulent financial statements.
While the IG report stated that while examiners recognized the risk posed by the lack of segregation of duties, it did not result in a Document of Resolution or any other formal or informal enforcement action.   The IG believed that if these responsibilities had been separated, it would have been more difficult for the former CEO to perform the fraudulent activities.

In addition, if dual controls had been in place, credit union staff could have discovered the former CEO’s embezzlement long before they eventually discovered it.

Furthermore, the IG report noted that to perpetrate the fraud, the former CEO needed a reliable source of funds. The former CEO had authority to set interest rates on share certificates. For example, the former CEO set the interest rate on one-year share certificate at 3.1 percent as of December 31, 2018, which was significantly above the market rate of approximately 1.3 percent. Despite these above-market rates, the credit union reported approximately $3.5 million in share certificates at the end of 2018. This small dollar amount of share certificates given the above-market rates should have triggered questions among the examiners; but the IG found no evidence of this in their Examination Report.

Moreover, the IG concluded that the supervisory committee audits and member account verification procedures were unacceptable.

The IG made two recommendations, which National Credit Union Administration management agreed with. Management should:
  • "revise examination procedures to prioritize assessing and developing a risk response for credit unions that do not segregate certain key duties and that require dual controls. These revisions should include a framework that examiners can complete an assessment of those characteristics that indicate lack of segregation of duties at a credit union and additional procedures that examiners should perform when a lack of segregation of duties is apparent";  and 
  • "amend guidance related to member account verifications. Specifically, the amended guidance should require reconciliation from the print processor to the share and loan subsidiaries when a statement verification is performed."
Read the Material Loss Review.

Monday, February 17, 2020

NCUA's Harper: NCUA's Consumer Compliance Oversight Lacks Robustness

In an opinion piece appearing in CU Today, National Credit Union Administration (NCUA) Board Member Todd Harper wrote that customers of a bank acquired by a credit union will not have the same level of consumer financial protection oversight in their new credit union.

He pointed out in the column that the Federal Deposit Insurance Corporation (FDIC) has a more robust consumer compliance program than NCUA.

He noted that FDIC regularly conducts dedicated consumer compliance reviews that are separate and apart from safety and soundness exams, while NCUA with the exception of fair lending exams combines consumer compliance exams as part of the agency's safety and soundness exams performed NCUA's regional offices.

The agency has only budgeted for 30 fair lending examines in 2020. Also, the consumer compliance exams conducted by NCUA's regional offices will only cover some of the many consumer financial protection laws on the books.

He further stated that the agency has only 15 or so regional examiners, who are consumer compliance subject matter experts. In comparison, the FDIC has hundreds of examiners committed to performing these exams.

Despite his reservations about the agency's consumer compliance oversight gap, he still supports the agency's proposed rule on combination transactions.

Read the opinion piece.

Sunday, February 16, 2020

Washington CU Regulator Releases 2020 Examination Focus

The Washington Division of Credit Unions released its examination focus for 2020.

The state credit union regulator dropped the following areas from its 2019 examination focus -- Internal Controls & Fraud Prevention and Interest Rate Risk.

The state regulator added Business Continuity/Disaster Recovery Testing to its 2020 focus.

Other areas that the state credit union regulatory will target include Cybersecurity, Compliance with Consumer Protection Laws, and Liquidity.

Under Compliance with Consumer Protection Laws, the state regulator will examine consumer complaint processing, Bank Secrecy Act, Regulation E (Electronic Funds Transfer Act), Regulation CC, and Equal Credit Opportunity Act.

Read the Bulletin.

Friday, February 14, 2020

Rio Grande CU Buys Naming Rights to Isotopes Park

Rio Grande Credit Union (Albuquerque, NM) has bought the naming rights to Isotopes Park.

The ballpark will now be called Rio Grande Credit Union Field at Isotopes Park.

The naming rights agreement is for 10-years.

Rio Grande also became the club’s official credit union, debit card and credit card partner.

The price tag of the naming rights deal was not disclosed.

Isotopes Park is the home field of the Albuquerque Isotopes of the Pacific Coast League, the Triple-A affiliate of the Colorado Rockies.

Read more.

Thursday, February 13, 2020

Labor Union Files Complaint Against Municipal Credit Union

A labor union has filed a complaint against Municipal Credit Union (New York, NY) with the National Labor Relations Board on January 16, 2020.

The Office & Professional Employees International Union, Local 153 alleged that Municipal Credit Union unilaterally repudiated or modified contracts of union members.

The labor union also accused the credit union of refusing to bargain or bargaining in bad faith.

The labor union represents 375 employees at Municipal Credit Union.

Municipal Credit Union was placed into conservatorship with the National Credit Union Administration on May 17, 2019.

Read more.

Retiring Illinois Bankers Exec Says Brazen CU Behavior Is Getting Noticed by Lawmakers

In an article appearing in BankBeat, Linda Koch, who will retire this summer as the president and CEO of the Illinois Bankers Association, had some interesting comments about credit unions and taxation.

Koch noted that the behavior of large credit unions has become more brazen with the acquisition of community banks and purchasing the naming rights to sports and entertainment venues.

She commented that these actions are getting the attention of lawmakers.

She believes that these actions by the credit union industry will ultimately force Congress and state legislatures to do the right thing and tax credit unions.

Read the article.

Wednesday, February 12, 2020

Trade Groups Urge Swift Action by FCC to Reform TCPA

The U.S. Chamber of Commerce and other industry trade groups, including bank and credit union trade groups, in a February 5 letter urged the Federal Communications Commission (FCC) to issue without delay a re-interpretation of a key term in the Telephone Consumer Protection Act (TCPA): the definition of an “automatic telephone dialing system (ATDS),” commonly known as an “autodialer.”

The FCC is considering issuing new TCPA rules in light of a federal appellate court’s decision in 2018 to strike down the FCC’s expansive definition of that statutory term.

The groups asserted that “consumers are harmed when they do not receive time-critical, non-telemarketing communications” from banks and other companies “because the business is discouraged from placing the call due to litigation risk.”

The groups also claim that ongoing uncertainty surrounding the definition of ATDS continues to fan the flames of abusive TCPA litigation.

Read the letter.

Tuesday, February 11, 2020

CU Tax Expenditure Is Almost $22 Billion over Next 10 Fiscal Years

The Office of Management and Budget estimated that the tax expenditure arising from the credit union industry's corporate income tax exemption is $21.878 billion for fiscal years 2020 thru 2029. The information appears in the Analytical Perspectives of the President's Budget.

Virginia Bill Would Allow CUs to Pay Board of Directors

A bill (HB813) in the Virginia legislature will permit Virginia state chartered credit unions to pay members of the board of directors and credit and supervisory committees.

The bill would require the board of directors to develop a written policy regarding compensation.

Total annual compensation to individual board or committee members cannot exceed $6,000.

The bill excludes accident, health, and term life insurance for a director or committee member will not be considered compensation.

Also, directors and committee members may be reimbursed for expenses, while on official credit union business.

The bill unanimously passed the Virginia House of Delegates.

Read more.

Monday, February 10, 2020

Wings Financial CU to Acquire Minnesota Community Bank

Wings Financial Credit Union (Apple Valley, MN) and Neighborhood National Bank (Mora, MN) announced on February 7 that the two organizations have reached an agreement for Wings Financial to acquire the bank.

The transaction, which requires approval by state and federal regulators, is expected to close during the third quarter.

Wings Financial Credit Union is the largest credit union in Minnesota with over $5.6 billion in assets.

Neighborhood National Bank has more than $216 million in assets and six branches, which are located in Mora (2 offices), North Branch, Aitkin, Brainerd and Alexandria, Minnesota.

The price tag of the deal was not disclosed.

Read more.

Sunday, February 9, 2020

Affinity Plus CU Buys Naming Rights to Concert Venue

Affinity Plus Credit Union (Saint Paul, MN) on February 5 bought the naming rights to a new concert venue in Minneapolis.

As part of the seven-year sponsorship agreement, the venue’s official name will change to “The Fillmore Presented by Affinity Plus Federal Credit Union.”

The $2.4 billion credit union’s name will also be stamped on everything from tickets to social media posts.

The credit union will have several ATMs at the venue.

The concert venue has a seating capacity of 1,850 people.

The price tag for the naming rights to the concert venue was not disclosed.

Read more.

Friday, February 7, 2020

Outstanding Consumer Credit at CUs Up for December, But Down for 4th Quarter

The Federal Reserve reported on February 7 that outstanding consumer credit at credit unions rose during December 2019, but fell for the fourth quarter of 2019, according to the G.19 report.

During December, outstanding consumer credit at credit unions increased by approximately $400 million to $482.4 billion. However, during the fourth quarter of 2019, outstanding consumer credit declined by almost $1.2 billion.

Revolving credit at credit unions was $67.8 billion in December. Revolving credit grew in December and in the fourth quarter by $2.7 billion and $3.4 billion respectively.

On the other hand, outstanding nonrevolving credit at credit unions fell during December and the fourth quarter. Nonrevolving credit fell by $2.2 billion during December and $4.5 billion during the fourth quarter to $414.7 billion.

Review the G.19 Report.

Thursday, February 6, 2020

Housing Policy Group Calls for Delay of ‘QRM’ Definition Review

The Coalition for Sensible Housing Policy -- a broad group of financial, housing and community development stakeholders -- wrote on January 30 to the federal banking agencies urging them to delay the conclusion of a mandated review of the “qualified residential mortgage” definition and related provisions of the credit risk retention rule.

The groups called for a delay until the Consumer Financial Protection Bureau (CFPB) finalizes and implements the changes it is currently considering to the Qualified Mortgage definition. “It is only after the CFPB has made its final determination on the definition of QM, and following some period of experience under the new QM configurations, that the agencies would be in a position to evaluate and seek comment on the market and consumer impacts of QM/QRM equivalency versus divergence of the definitions,” the groups wrote.

The agencies were required to begin the review no later than Dec. 24, 2019, pursuant to the timeline set forth in the original rule.

Read the letter.

Wednesday, February 5, 2020

NCUA's Combination Transaction with a Non-Credit Union Proposal

The National Credit Union Administration (NCUA) on January 30 published in the Federal Register a proposed rule regarding a credit union's combination transaction with a non-credit union, including a bank.

The proposed rule provides clarity about the processes and requirements for a federally insured credit union with respect to this transaction.

The proposed rule requires NCUA's advance approval of all these transactions. In the case of federally insured state chartered credit unions, the advance approval of the state regulator is also required.

NCUA also identifies the factors that it will review regarding this transaction. Four factors involve safety and soundness issues, while the last two factors examine the impact of this proposed transaction on credit union members and potential members and whether the proposed transaction is in keeping with the credit union's mission.

The minimum amount of information to be part of an application includes the balance sheet and income statements for both institutions; a combined financial statement showing the transaction's potential impact on the credit union's net worth; information about the due diligence assessment of the proposed transaction; a delinquent loan summary; analysis of the adequacy of the allowance for loan and lease losses; and a list of the other institution's assets that would be impermissible by law.

The proposed rule requires a credit union's board of directors must vote to approve a proposed combination transaction before the credit union submits its application package. The board of directors must certify that management has explained how the transaction would affect the credit union's balance sheet and net worth and how the purchase prices was determined. Furthermore, board members must certify that they do not have a personal or pecuniary interest in the transaction.

The credit union must address how the potential members fall within the credit union's field of membership and how the credit union plans to convert potential members into actual members.

The comment period is for 60 days and must be received by March 30, 2020.

Read the proposed rule.

Tuesday, February 4, 2020

Six CUs Fined for Late Filing Quarterly Call Report for Q2 2019

The National Credit Union Administration reported on February 3 that six federally insured credit unions agreed to civil money penalties for filing late Call Reports for the second quarter of 2019.

Individual penalties ranged from $150 to $757. The median penalty was $330.

All six credit unions had assets of $50 million or less.

All six credit unions had previously failed to file a Call Report in a timely manner.

Read more.

Monday, February 3, 2020

NCUA: CUs Cannot Count Adjusted Retained Earnings from Bank Mergers as Net Worth

A Call Report change for the fourth quarter of 2019 by the National Credit Union Administration could adversely impact the net worth of some credit unions that have acquired a bank.

The NCUA changed line 7 of its PCA Worksheet (see page 56 of the Call Report Instructions) dealing with Adjusted Retained Earnings acquired through Business Combinations.

NCUA in the fourth quarter wrote in its Call Report instructions that this provision only applies to "business combinations with another credit union. This provision does not extend to a credit union that acquires a bank through merger."

This change will hit the net worth for any credit union that had included adjusted retained earnings from a bank merger in its net worth.

For example, IBM Southeast Employees Credit Union (Delray Beach, FL) saw a $31 million decline in its net worth between the third and fourth quarters.

Also, this Call Report change may affect the number of credit union deals for banks going forward.

According to Peter Duffy, Managing Director at Piper Sandler, "we believe this change, while not surprising, will result in fewer and smaller deals."

However, Michael Bell, who is a lawyer at Howard and Howard and has done a majority of bank mergers into credit unions, said: "None of the transactions I have been working on have been negatively affected by this Call Report change."

Bell further stated, "Personally I think the change in treatment is mathematically incorrect but we continue to plow ahead."

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