Today, CUNA filed a comment letter in support of NCUA’s proposal to
amend its regulation governing assessment of the annual operating fee to FCUs.
The proposal would primarily:
- For purposes of
calculating the annual operating fee, it would amend the current rule to
exclude from total assets any loan an FCU reports under the SBA’s Paycheck
Protection Program (PPP) or similar future programs approved for exclusion
by NCUA.
- It would also amend the
period used for the calculation of an FCU’s total assets. Currently, total
assets are calculated using the FCU’s December 31st Call Report
of the preceding year. Under the proposed rule, total assets would be
calculated as the average total assets reported on the FCU’s previous four
Call Reports.
We support the proposed exclusion of PPP loans from an FCU’s
total assets for purposes of calculating its operating fee. This change should
help ensure that FCUs interested in making PPP loans do not bear greater
financial burdens for doing so.
We also support the proposed change to a four-quarter
average of reported assets in calculating the operating fee. We agree with the
agency that this change will address seasonality and provide greater certainty
of upcoming operating fees.