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Hey everyone, this is Mark with a special Archive episode of With Flying Colors. I hope you enjoy. Hey everyone, this is Mark Treichel with another episode of With Flying Colors. It is April 4th and about, let's see, about 45 minutes ago, NCUA ended their liquidity webinar. And I listened to it and Todd Miller of my team listened to it.
If you've listened to this show before Todd, he talks a lot about a lot of different topics, but including liquidity as a former capital market specialist and supervisor of capital market specialists at NCOA. So Todd and I are going to basically give our take on what NCOA said relative to liquidity and maybe dive into some related issues to that. So Todd, how are you doing today?
I'm doing fine, Mark. Spring has finally come to Montana and winter is going to come back tomorrow, but for now, we've got some days in the 70s, which are quite nice for us. That's nice.
That's good. 70 degree days. That, that is, that doesn't seem like spring. That seems like summer in Montana. All right, so Todd, give it for, if anybody, there might be some new listeners listening for the first time. Why don't you give those folks a little synopsis of what you did at your time at NCUA.
Okay, I spent from 1987 through 2021 at NCUA. Started as an examiner in Montana, spent the early 90s as a problem case officer. From 2000 to 2010, I was a regional capital market specialist. I'm involved in a lot of training and policies that go on around capital markets issues at NCUA. Um, 2009, I had a lost year. I spent it at Westcorp while the agency had Westcorp in conservatorship, um, cleaning up at Westcorp and helping wind things down there.
And then from 2010 to the end of my career in 2011, I was the director of special actions supervising problem case officers and supervising regional capital market specialists. I enjoyed all of my 34 years with NCUA. I was short a couple months. But it was an enjoyable time. I really enjoyed working with Freddie Indians and all the people at NCUA.
Very good. Yeah. And you've been in a lot involved in a lot of podcasts. You've been involved in a lot of clients that we've been helping and it's nice. To be able to talk here about our take on what NCOA's take is, and, and they had a, an, an hour long webinar, it was about 50 percent questions, 50 percent presentation, which is a good mix, and I'll just throw it to you, uh, based on what you heard on NCOA's liquidity webinar, what's your takeaway from what they had to say today?
I'm going to throw out maybe three resources first, right at the beginning, because most of what NCUA talked about in the webinar really comes from these three source documents. And really, that's the 2010 Interagency Policy Statement on Funding and Liquidity Risk Management. If people listen to the webinar, that was brought up, especially in the question and answer session, on multiple times. Back in 2013, NCUA issued CU 10 guidance on how to comply with NCUA Regulation 741 12.
They mentioned that today. That was when NCUA came up with the regulation requiring different crowding needs to have policies, contingency funding plans. larger credit unions access to the Federal Reserve discount window or the CLF. And then last year in 2023 they issued, um, NCWA issued an interagency or an addendum to that 2010 interagency statement on funding and liquidity risk, just on the importance of contingency funding plans.
Everything in today's webinar is really just a subset of what was in one of those three documents, primarily that interagency statement. Policy statement on funding and liquidity risk management that was put out in 2010, right after the last financial crisis shortly after that, the OCC updated their liquidity handbook in 2012. Those are all really good source documents overall today's seminar or webinar the way I'd characterize it. This is a refresher course on those policy statements.
I think they were probably, it may have been more helpful to smaller credit unions than larger credit unions in my mind. They didn't really say anything new to us. There's some specifics we can talk about as we go here. My initial take, this was all primarily a review of Those guidance documents that NCUA has issued previously,
and I'll put in the show notes. I'll have links to those all 3 of those. So that if someone wants to get access to more details. And I'll also probably do a blog on my website that'll have links to that. So if someone's listening and wants to find a quick way to find all three of those, we'll provide that. Yeah, so let's get into the details. What's the first detail that you think's worth highlighting?
They talked a lot about cash flow statements in here and cash flow forecasts and triggers for contingency funding plans. They talked about using historical numbers. They talked about using stress numbers. I think that the interesting pieces of all of this is if you go back to the last recession in 2010 2009, we'll look at 2009, Credien's deposit space back then were about 1, 55 percent were money markets and CDs. And then another, that was money market CDs and wholesale funding.
Today we're at 52%. There was some big changes in 2022 when rates started rising. I think credit unions were maybe slow to react or the market changed so fast, they couldn't react. So there was these stresses placed on liquidity. We go from a low end rate environment, low cost shares are migrating to higher cost shares. Credit unions are using borrowings to manage that marginal cost of funds. And I think they did that in a very appropriate way.
So while the agency seems to be very stressed about liquidity pressures, I think they were right to be stressed about them in 2022. But if you look at what's going on in 2023, I think credit unions have adjusted to this rate environment. The migration from lower cost to higher cost shares is going to continue for another year, at least, maybe a little bit longer. And I think that's really just historical numbers tell us that's where it's going to go in terms of member behavior.
I think a lot of their sense of urgency here with this webinar was maybe needed in January or September of January of 2023 or September of 2022. I think right now the industry has done a really good job of managing this environment. And a lot of the liquidity stuff is behind us. NCUA is still nervous, but the numbers would indicate most of the credit unions have adjusted really well, uh, in the, you know, you
talk, you talk about that 55 and we're getting close to that. I think in some of our other conversations and maybe some client conversations, you've called that the reversion to the mean and. I have. Yeah. And the other times, when I think reversions to the mean, I think about the basketball player that just made 10 straight shots, which means that over time he's going to miss 10 more. Right. So you get back if he's a 50 percent shooter, but, but that was in the old days.
Now I think when I think about reversion to the mean, I think about that mix of deposits that that credit unions have and they, I might've missed something, but they did highlight, I'm going to probably get the phrase Roz, but they talked about. For deposits and the best sources of liquidity and they talked about member shares plus like borrowings being utilized. But did I if I write that? I don't think I heard a reference to like non member deposits at all.
They left non member deposits out. I don't remember them using that word at all. Even though non member deposits are up a little bit and you had me work with 38 different clients over the last two years. There's a good number of them that have been dinged on their usage of non member deposits and a lot of them have used non member deposits so they didn't have to raise their certificate rates.
Another thing that wasn't mentioned today, and this is a huge part of the whole liquidity risk management, is I never mentioned pricing today. They said, you got to have an appropriate share structure and an appropriate loan structure. And that's all created by pricing and catering to your members individual needs. Some members are going to chase rates. Some members, they want to keep a pool of liquid assets there. My wife calls it, she wants her 1. 99 in the bank.
And then in her term, that means that it has to be like right at that 100, 000. She kind of freaks out if it's less than that. Well, we're not going to put that in an account earning us two basis points, but we don't need a 5 percent certificate rate either. We want that somewhere in the middle, and I think our current bank's paying three and a half, not that it's germane. Pricing and creating an appropriate structure means meeting the needs of your members on both sides of the balance sheet.
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And loan demand is up and part of that is inflation and things of that nature. Borrowing requirements are a little bit higher amongst your members. And I think the credit unions overall, the industry, they've done a really good job of meeting those member needs. Maybe they were a little bit slow to price loans upwards, and that has to catch up a little bit before they can start creating these appropriate price products to grow these core deposits again.
In this high rate environment, it could be totally expected. that you're going to see this migration from low cost shares into higher cost CDs and higher cost money markets. And like I said, credit is going out and using borrowed funds and using non member deposits to keep that marginal cost down is a perfectly normal reaction for them to the marketplace. Yeah. So I think they've done really well with that.
Yeah, no, I would agree. Another word I wrote down was decay rates and decay rate assumptions. And it's like they, when I heard it, and, and again, this is an area that I'm far from an expert, but I know that it plays a big role in ALM and I know you've talked about it here and you've talked about it on our client with our clients, but they basically brought it up and then pivoted away from it and didn't give any background relative to it. But maybe any thoughts on.
The pay rates, how those are impacting credit unions, liquidity. How we're seeing NCUA maybe respond in some instances to clients. So I'm diverging from what was said in the letter into kind of a maybe what should have they said about decay rates?
I think this is one where they're still overreacting and responding late. The cash flow forecasts are very much tied to the same assumptions that go into an asset liability management model. I think they mentioned that during the webinar or during one of the questions. But if you go back in these stress tests and Even your 300 basis point shock in an ALM model, that whole thing is intended to get members to exercise the options in these financial instruments. Rates have went up 500 basis points.
All the options on the loan portfolio have been exercised. It's not going to get any slower. Even though they talk about stressing this, the loan assumptions are not really going to be stressed much more than they are now. They're already Those prepayments are as slow as they're going to go in most cases. So that's maybe why they backed away from it is because you can't stress it much farther than you already have.
On the share side of it, and coming up with decay rates, we're finding this with lots of clients. Parties used very conservative assumptions for a lot of years during the flat rates. Of course, when things start changing in 2022, the examiners, you need to update your assumptions. A lot of credit unions did that. Their vendors did it. What they found out is their previous assumptions were overly conservative. They're slowing them down and using more reasonable assumptions.
And the examiners don't like that because it makes them look better. And it's just a matter of when rates were low and interest rate risk were low and there wasn't stresses, there wasn't this impetus to put time and resources on getting those assumptions precise. And now it is, and they're making it more precise. And in many cases, the examiners don't like the results. Stressing share growth and share migration, that does become very much an individual thing for each credit union loans.
That's pretty much homogeneous across the industry loans behave the same. But shares are very different from credit union to credit union, and it has a lot to do with your field of membership and your whole pricing strategy for your whole product suite that is really not homogeneous across the industry. It's different for credit unions to credit unions, so a lot of your stress tests are going to be geared to changing your member behavior.
But I think most credit unions probably have a pretty good idea of what has occurred in the last year, how much money has migrated.
And there's going to be a little bit more to migrate, so I don't think the stress is, it's almost if NCUA is behaving, we have another 300 basis point upcoming when we don't, and we're going to be probably staying somewhat flat, or if you believe what everyone else says, rates will start coming down, and that will help folks, and it'll give time for Credien's investments to catch back up. Credien's really got caught in a trap. They're long term assets.
It's really peaked right at 2021, right before the rates started up. When all that COVID money came in during those flat rates, credit unions went long term with that either on their loans or their investments. And then rates shot up on them. And so it made them a little bit harder to reprice, price assets. But I think we're catching up to them now that. The repricing is starting to catch up when rates went up. Initially, cratings were slow to raise those loan rates.
They've started to catch that back up. So I think the future is looking good in terms of that. So, I guess the biggest variability that we see, and a person in the webinar asked a question about liquidity ratios and the basal coverage ratio. Their response was, well, there's lots of ratios out there and we have a data dictionary of them. And one thing I think we're finding with our clients is. On exams, what's important to the examiners varies a great deal from examiner to examiner.
We've got examiners from credit unions that are making up liquidity ratios that are not mentioned anywhere in NCUA's guidance. And we have examiners in larger credit unions think people should be using the Basel coverage ratio. The variations of that are extremely difficult to actually calculate that ratio. So that variations in examiner's impetus, that's a challenge for credit unions.
And so they better be just prepared to justify what they're using to measure liquidity versus how an examiner suggests maybe they should. So they should be able to defend what they're doing. They brought up the things with cash flow, and they brought up limits a lot. NCUA, they issue all these disclaimers at the start of it, and, hey, this is this person's opinion, not the agency's opinion, even though it's the agency's webinar. I find that interesting.
But for credit unions, I think one thing that we see that is consistent out there and is Where they get criticized for examiners legitimately is looking at liquidity in a rear view mirror. I'll use that term rear view mirror. What was our liquidity ratios last month? Or, or here's our last quarter end and now we're doing May. And looking at ratios that were 45 days old. Realistically, credit gains with your cash flow forecast, you need to be looking and computing your policy limits.
What do they look like in your cash flow forecast six months from now, nine months from now, and a year from now? If managing from a forward looking space than that. NCUA didn't really use that terminology, forward looking, but that's what liquidity management needs to be, is forward looking, not looking in a rear view mirror. And I noticed the one or two times they did quote ratios, they quoted ratios that were rear view mirror looks.
During the webinar, but they inferred with a lot of their emphasis on cash flow forecast is managing liquidity needs to be a forward looking process, not looking in our rear mirror.
Yeah, I wrote down some, I have liquidity measures. I wrote down some of the exact same things you did there. And then a couple other things you said, it's almost as if NCOA is thinking there's going to be another 300 basis point shock, which I would bet against right now, you don't want to bet on where rates are going, but I'm going to bet they're going to, they might not go down as quick as we thought they might inch up and probably NEV.
Which has, which, as we've discussed in other podcasts, NEV has weaknesses because it doesn't take into considerations a lot of positives. And it seems like what we're seeing with some of our clients is they're using that and saying, well, you know, if it goes up another 300 basis points, you're going to have these issues and you need to develop a plan. And then adding that to, was it two years ago now NCUA separated the S from the L. You used to have just camel and now it's camels.
And I think there was a reference to this topic where they just subtly brought it up in the podcast, but it, and then, so one last rambling part of this question, which, you know, the fed hat for large institutions, the fed has their shock test that they do. And I was looking at that the other day and the shock test they do right now is they're having credit unions.
Shocked their balance sheet with rates going down and then at the same time they got to do they got to look at the nev and i get i guess you should have a plan for both directions but even the fed is saying let's test it in this direction all right so that's a long rambling statement more than a question any anything you can you any did that trick Thoughts Todd.
They made one statement and I wrote it down. So this was the whole part of our webinar supposedly on liquidity, but in their discussions on liquidity, they brought up the fact that the NCUA supervisory test is not how credit unions should manage their interest rate risk. And I wrote it down because I don't know how many clients we have, but we have multiple clients that have gotten DOORS to reduce interest rate risk on the basis of that NCUA supervisory test measure.
That, those are the words that are in their document of resolution. And publicly they've said this on many webinars and last year when they got rid of the extreme interest rate risk, they said Freddie Eanes don't manage to our NCUA supervisory test. But they keep writing doors to credit unions that says that is going to be our measurement is our NCUA supervisory test. So no matter how many times they say it to the public, their examiners don't.
The message isn't filtering down to their field staff, put it that way.
That's what you'd always hear when I was at NSUA, you'd hear that from when you'd go to GAC and you'd get in a line, meet and greet line and the, the NSUA board would chat with them and saying, yeah, I heard you say this six months ago at the board table, but my examiner saying the exact opposite. And then they'd come back and we'd. We we'd have a little discussion on it, but, and the other thing too. So think about that statement and your earlier statement about the disclaimer at the front.
Right? So if a credit union is going to cite what was said at this webinar, the examiner might say at the beginning, we came to you, disclosure is just the opinion of those facts, those people at the table, and that's not really what it should be. They are the government, they are speaking for the government. And and the webinar was kicked off by the chairman of the agency who, if this was face to face, would be sitting right there and people should be able to rely on it.
But, like you said, their statement is incongruent with what we're seeing an exam. So I'll just leave it at that.
Yeah, and I'm sure there's more than a few examiners were listening to the webinar. I didn't keep track until they were like just about done with the questions. And then I looked up and there was 1220 participants on and some of them were probably dropping off already at the one time I chose to look. But I do know examiners, especially the subject matter type experts and the RCMSs, they're given time to listen to the webinars.
They don't all listen to them, but certainly a fair number of them do. They hear this, but there's lots of ways for it to trickle down and just sometimes it doesn't seem to be the case. They never said during this webinar that borrowing is bad. They never said non member deposits are bad, um, but amongst our clients, um, they certainly get treated as if borrowing and non member deposits are frowned upon.
We're getting findings indoors to reverse the trend in your core deposit migration and use less borrowings and use less non member deposits. And the examiners don't seem to think that there's a cost to that, but there is, because that means you're raising the cost to your whole entire deposit base, which is sometimes much more than the cost to borrow or use non member deposits. And yes, credit unions shouldn't be using those. Funding sources without a plan.
Um, but most of them, even our clients that we've talked to a lot of that is part of their plan. And it's an active strategy to not raise their funding costs and then maintain their capital and maintain their earnings and some examiner. They're still just nervous. And like I said, at the beginning. I think in some ways they're reacting to liquidity events in 2022 rather than what went on in 2023. The industry seems to have adjusted really well to this rising in rate environment over time.
And time heals a lot of wounds is I think something I've heard you say many times. It's not something I've said, but I've gotten that from you. And I think that's where we're at. Where the industry is at is they've adjusted to these high rates. And yes, there's going to be some more adjustments to come yet. And there is going to be some more migration from core deposits to other.
Share types, but I think that's all part of a reversion to historical means their members are still adjusting to these high rates as well. We're all adjusting to it a little bit slow, and I'm sure even when rates start going down, whatever date the Fed decides that's going to start to occur. I think you'll still see a lag where they're still going to be credit and they're going to be having to raise deposit rates even when rates start falling. Right. Just right sizes.
Themselves to their funding needs and their members needs.
Just as we were chatting, one of the federal reserve folks, one of the, one of the, one of the districts came out and said, I don't think we're going to drop rates at all this year. So, you know, and oh, by, oh, by the way, the market went down right after he said it, it'll impact rates a little bit. So
from a bank deposit side, I would be fine if rates don't go down,
right? Yeah. Yeah. I know all those
retirement account balances of growing really fast in the last six months
and that's that's part of the economic challenge Getting off topic here But the white collar worker and the and those who are well off Economically are doing better than the folks that are having to pay that their grocery bills gone up 10 percent then 20 percent and another 20% And then we get excited that it's only growing at 3%. But yeah, it's of that new inflated rate. And those folks are struggling right now. And it's going to impact credit unions in a lot of ways.
Like you, you've said in some other podcasts that, that one of the reasons share growth has disappeared is because they're paying, they're paying for their, their food, they're paying for their gas to get to work instead of putting it into the credit union.
Yeah, I see it just and I belong to a couple of volunteer clubs where you pay dues and we've seen over the last few years where people have. Stepped away or complained about just 150 a year for dues is wait, that's a big bill for me right now. So there is that segment of the population and I think it's bigger than a lot of people suspect.
It was last fall or maybe early this spring, the Federal Reserve had their annual little article out of how many people can meet an expense of, I don't know what it was, 400. 400,
yeah.
And it's a huge percentage of people can't. That's why that loan demand is out there in the industry is even though the inflation is down, it's real and it's impacted a lot of people's budgets.
No doubt. No doubt. I'm looking back to my list of notes. 1, 2 things. When we were talking about ratios, just cash to assets or cash to shares, there was reference to that. There was reference to loan to assets. Yeah, I've seen, we've become acquainted with some state laws that say you need to have X percent, which seems like a higher percent than any credit union might want to have on the books.
But I've also seen some situations where credit unions are being encouraged to increase their cash balance. Um, there is no perfect measure, but when I throw that out there, Todd, does it trigger anything in your head?
I think NCUA is a little nervous about it. In 2022, across the industry, cash and short term assets were down to 10%, which is I think the lowest I have numbers here in front of me going back to 2000. That's the lowest it was ever in 2022. And virtually the highest it ever was in 2020 at 18. So it dropped just tremendously. And then it ended 2023 at 11%, which is. Still below historical norms where it used to run 1315.
Part of that though is I think credit unions have actually just gotten more analytic about how much cash do you actually need. And we've seen that after the last recession from 2010 on, at least in the western region, there was a lot of credit unions were tracking daily deposit volatility and things of that nature.
And really when they go through those exercises, there's a lot of the larger credit unions, they really only need three to 6 percent to handle a couple standard deviations, a daily deposit. So in the absence of ways to measure how much liquidity they should have, I think the industry as a whole is just carried a lot of excess.
That's a great point. Yeah. The, the more credit unions. digest the data that they have, the more into a pushes the need to have a good estimate of what your needs are looking forward, the tighter you can get, the closer you can get to reality, which then allows you to trim a few percentages off the cash. That makes sense.
You can manage your risk a little bit more efficiently and allocate it where it Best generates rewards for you. And so a side effect of getting more analytical and being better at measuring numbers is you can ride closer to what the examiner might think is the edge of risk, right? Because they don't see the analytics. They have their different historical perspective of what they think is appropriate. Usually.
Based on exams they've done in their district over the year, and that could be smaller cardigans. It could be larger cardigans. It could be a wide divergence, but there's just a great deal of just even the risk acceptance amongst the exam staff. There's quite a variance as to what's acceptable from one examiner to the next. But, you know, when examiners get more analytical, they run things closer to the edge, a higher loan to share ratio, a lower level of liquidity.
Take on a little bit more operational risk here, a little bit more credit risk there. Those types of things make examiners nervous when they see credits changing their risk profile, even if they're doing it because they have better analytical tools to manage it. It still makes examiners nervous.
So the last word I had written down that I wanted to mention was in reference to underwater investments. They had a little bit of discussion of your sources of liquidity and with where rates are at. You've got a lot of credit unions that have investments that are upside down. And quite frankly, if they book loans that are fixed, they're upside down. And it reminds me of something you've said on here and the clients about liquidity. Liquidity can maybe turn into a liquid.
I'm going to get this wrong, but here's what it is in my head. Liquidity can be turned into some sort of liquidity event. If you have problems with your asset quality, right? So if you have, if you lose the ability to hold those underwater assets, or you start having loan losses in a way, Okay. That it's eating up your flexibility and your cash that can exacerbate a liquidity event or a liquidity.
With adequate capital, well capitalized, a decent asset quality are always going to be able to go to the wholesale markets and get liquidity. It's never going to be an issue. I mentioned the whole interagency policy statement that was issued back in 2010. That actually has a whole section on credit unions that are have falling capital and are fall into PCA that they need better contingency funding plans. So it breaks them out whole separately.
We do have, I think, at least one client that has some capital challenges that. Has to post physical collateral. They haven't been cut off, but they've been asked to post physical collateral just because of where they're at. That's a warning sign. But in general, a well capitalized credit union, you're sitting here eight, 9 percent and your delinquency and charge offs are under control. You are going to be able to go to the second wholesale markets and get liquidity at a reasonable market cost.
That's a good thing for that credit union. That's a good thing for the industry. It's good. The good thing for the insurance fund, because that's where most credit unions are at, there may be examiners who push, beat them up a little bit more than you and I would like from the side of the table that we sit on now, but you're right, they're going to be able to get access.
Like I said, overall, I think the industry in 2023 has responded to liquidity events and the current market conditions very well, and their liquidity is pretty well managed. Yes, core deposits are still going out the door. They're finding their way into certificates of deposit. Maybe they're going to another institution who's paying a higher CD rate.
Down the road, Cardigans have been able to utilize that wholesale funding, borrowings, and increasingly non member deposits to manage through that because they see this as something that we have to manage through for 18 months or 12 months or whatever the case may be. And so their whole utilization of those wholesale funding sources is perfectly reasonable. It helps them maintain profitability as they right size those member share offerings. I see it as a positive thing.
Yeah, me too. It's a tool in their toolbox. So, anything that else you want to highlight before we wrap up today, Todd? Anything we missed?
No, I'll just reiterate this whole webinar. It was just subsets of what was in that interagency policy statement issued back in 2010. There's really nothing new under the sun in terms of how you go and manage this. Yes, you can get more sophisticated.
with how you create these cash flows and you can get more sophisticated about your stress test, but really liquidity management about is really about these cash flow forecasts and managing down the road, not looking behind you, but having a forward looking mirror and how do you best. Serve your members. I thought overall the webinar was maybe better than some that NCUA have done. Um, I don't know that larger cardians would have benefited from listening it. Maybe some of the smaller ones have.
Um, I've seen it more as a good refresher course on some of these principles. They didn't give you a lot of specifics, but they tend to, regulators tend to not do that in webinars.
That's a fact. That's a fact. We've seen that, uh, we've, we lived it when we were there and we see it from a different angle right now. And I would agree it was better than the average as far as information.
I always ask at least one question on these webinars just to see if they'll answer it. I don't know. I may be about 1 for 10 right now over the last few.
Yeah, I think I'm, I think I'm like 1 for 15. I'm gonna, I'm gonna log in as, I don't know, Johnny Rockets or something next time so they can't tell it's me.
I haven't thought about doing that. Yeah, it might change the results. If we do that,
they figure if we ask the question, it might be a loaded one.
Yeah, sometimes I asked benign ones that should be easy to answer. And they still don't. They see my name. I'm saying, no, not you, Todd.
Yeah, that's right. Yeah, that's right. We're going to answer all the credit union questions first. All right, Todd, thank you so much for your time and listening to that, that, that hour and sharing your thoughts with, with our audience here today. I appreciate it. Have a great day, Mark. You too, Todd. And listeners, I want to thank you for listening. I hope you'll listen again soon. Mark Treichel signing off with Flying Colors.
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