February 27, 2012 Mary Rupp, Esquire Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria,VA 22314-3428 Re: Proposed Amendments to 12 CFR Parts 742 Pertaining to the Regulatory Flexibility Program Dear Ms. Rupp: My comment is not in opposition to the proposed changes to the Regulatory Flexibility Program. My comment is to […]
THIS IS THE COMMENT LETTER SUBMITTED BY MESSICK & LAUER P.C. COMMENTS ARE DUE BY FEBRUARY 21, 2012. January 25, 2012 Mary Rupp, Esquire Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria,VA 22314-3428 Re: Proposed Amendments to 12 CFR Parts 701 and 741 Pertaining to Loan Participations Dear […]
We are at a critical juncture in the history of credit unions. Negative events seem to be piling up on us. There is enough denial, over-reaction, semi-panic, and name calling to fill our days. It is time for all of us to take a deep breath, reflect and consider where our behavior is leading credit […]
Loan participations are extensively used by credit unions, principally in member business loans and consumer mortgage loans. Loan participations provide an attractive investment alternative and help credit unions manage liquidity, lending risk and regulatory constraints. However, the loan participation regulation needs to be amended to keep up with the changing financial marketplace. In today’s environment, […]
The advantages of loan participations to an originating/seller credit union are that the seller obtains liquidity to serve other members, has a tool to manage regulatory loan caps and spreads its lending risks. The advantage of loan participations to a buying credit union is the ability to earn a good return on assets. Getting a […]
There was a day when credit unions relied on internal staff to perform most of their member services and backroom operations. This “internal model” has evolved into a “blended model,” where many functions are outsourced to third-party service providers, often to credit union service organizations (CUSOs). The National Credit Union Administration (NCUA) announced last year […]
What has the diminished role of corporate credit unions meant for CUSOs of natural person credit unions? The answer is some challenges but lots of opportunities. Some CUSOs benefited from corporate credit unions as investors and lenders. However, the loss of the corporate credit unions as a capital and liquidity source is not of great […]
Collaborations, through CUSOs and otherwise, hold the promise of earning non-interest income from non-traditional financial products and of significantly reducing operating costs. Both opportunities are welcomed in an industry where the average net interest income is less than the costs of running a credit union. If collaborations are not extensively used by credit unions, the […]
The stories we tell ourselves frame how we view the world, our place in it and how we respond to it. I call this internal viewpoint our myths, our prisms that interpret the world. The myths we create for ourselves have a profound impact on our ability to recognize and respond to change. The prism […]
Judge Christine M. Arguello has issued her decision in Bellco Credit Union versus the United States of America. This is one of the UBIT cases. The IRS assessed Bellco Unrelated Business Income Tax (“UBIT”) on certain income items and Bellco paid the tax and has sued for a refund. By doing so, Bellco is able […]
