NCUA

NCUA Proposed Rule, Corporate Credit Unions - 11/09

DISCUSSION DOCUMENTS

Critical Issue #1 – Missing the treatment of legacy assets and NCUA’s prohibition on replenishing capital - from CUNA CFO Council Regulatory Committee

Critical Issue #2 – NCUA’s model for growth in retained earnings and the timeline to reach the required levels - from CUNA CFO Council Regulatory Committee

Critical Issue #3– Prohibition against redeeming certificates at a premium - from CUNA CFO Council Regulatory Committee

Critical Issue #4– NEV sensitivity analysis / credit risk shock and prepayment speed slowdown test - from CUNA CFO Council Regulatory Committee

Critical Issue #5– Weighted average asset life - from CUNA CFO Council Regulatory Committee

Discussion Framework - Critical Concern Issues Related to Proposed Rule 704 - from Association of Corporate Credit Unions (ACCU)

Proposed Regulations for Corporate Credit Unions - Summary of Key Issues - from Members United Corporate FCU

Summary of Proposed Regulatory Changes for Corporate Credit Unions - NCUA Regulation 704 - from First Carolina Corporate

Draft Response to NCUA Proposed Regulation of 12 CFR Parts 702, 703, 704, 709 & 747 - from Washington CU League

CORPORATE CREDIT UNIONS

Overview Information on Corporates - Includes:

• Corporate structure & governance
• Liquidity management
• Capital
• Regulatory framework
• Services & other information
• Glossary of accounting terms
• Map of Corporates
• Corporates' historical timeline

Corporate Credit Union, FHLB, and Federal Reserve Purpose, Structure and Governance Comparison (separate document)

Corporate Call Report Data:

• December 2008 - from Callahan & Associates
• December 2007 - from Callahan & Associates
• 12/08 Aggregate Analysis
• June 2008 - from CUNA (also includes other useful information on natural person CUs and more)
• December 2007 - from CUNA

Relevant Laws, Rules and Regulations:

• Federal Credit Union Act, Title III - Central Liquidity Facility (CLF)
• NCUA Rules and Regulations Part 704 - Corporate Credit Unions
• NCUA Rules and Regulations Part 725 - Central Liquidity Facility
• NCUA's Corporate Examiner's Guide - Chapter 201 and following chapters are a good starting place for understanding Corporates.

www.corporatenetwork.org - Website for Corporate Credit Union Network and ACCU

• Understanding OTTI - Slide Presentation, Background/FAQ Document, and Video

PROVIDE INPUT / TAKE ACTION

CUNA's Regulatory Comment Call

IMPORTANT LINKS

CUNA's Resource Page

Proposed Corporate Credit Union Stabilization Fund - NCUA

DISCUSSION GROUP

Discussion Group in CUNA Councils Connect - Have an idea, question, or resource to share with other council members on the new NCUA program? Post it in this cross council discussion group.

RESOURCES FOR THE 1/09 ANPR

CUNA's Comment Call - Includes Executive summary, background information and questions from NCUA to consider.

ANPR Questionnaire Template - To help prepare your credit union's comments.