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Stress Test Comment Deadline Approaching, CUNA Says
ALEXANDRIA, Va. (12/26/13)--The Dec. 31 deadline for comments on the National Credit Union Administration Board's proposed stress testing regulations is rapidly approaching, the Credit Union National Association says in this week's Regulatory Advocacy Report.

Under the NCUA proposal, federally insured credit unions with assets exceeding $10 billion would be required to develop and maintain capital plans, and undergo annual stress tests.

The stress test requirements, drafted by the agency's Office of National Examinations and Supervision, would require impacted credit unions to conduct specific capital analyses to evaluate how changes in variables, parameters and inputs used by credit unions in their capital plans could affect their capital. Credit unions would also need to test how interest rate shocks of at least plus or minus 300 basis points would impact their net economic value.

CUNA has encouraged all interested credit unions and leagues to comment. Among other issues, CUNA is focusing on:
  • Whether a rule is needed;
  • Whether NCUA should assess a credit union's stress testing instead of developing and utilizing its own;
  • Whether the results of stress testing should be made public; and
  • Whether elements of the proposal such as the nine-quarter horizon, the +/- 300 basis point shock, and the two-year assumption of the maturity of non-maturity shares are appropriate.
CUNA will share a draft of key concerns regarding the proposal with state credit union leagues, the CUNA Examination and Supervision Subcommittee, CUNA Council members, and others shortly.

Other issues addressed in the Regulatory Advocacy Report include:
  • CUNA's work to address issues created by the recent Target stores data breach;
  • Extension of the comment period until February 7, 2014 for a joint agency diversity proposal;
  • The Consumer Financial Protection Bureau's mortgage rule education campaign; and
  • CUNA's comments on the Federal Reserve Banks' payment system improvement paper.
A resource chart with information on current CUNA comment calls is also provided in the Report.

For this week's Regulatory Advocacy Report, CUNA members can use the resource link.


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