Board Action Bulletin
Revises Operating Fee Schedule Methodology
ALEXANDRIA, Va. (Dec. 14, 2023) – The National Credit Union Administration Board held its eleventh open meeting of 2023 and approved four items:
- The agency’s budget for 2024 and 2025.
- The Central Liquidity Facility budget for 2024.
- The issuance of a final notice on the Operating Fee Schedule Methodology.
- The issuance of a notice and request for comment on the existing Overhead Transfer Rate Methodology.
Budget Approved for 2024 & 2025
The NCUA Board unanimously approved the agency’s Operating, Capital, and National Credit Union Share Insurance Fund administrative budgets for 2024 and 2025.
“The recommended budget before us represents a consensus. It includes compromises by all of us at the table,” Chairman Todd M. Harper said. “Give and take is essential to any organization’s policymaking and budgeting process, and the budget before us reflects that principle in action. This funding plan provides sound financial stewardship and will allow the NCUA to execute its financial stability and consumer financial protection missions over the next two years.”
Combined, the 2024 Operating, Capital, and Share Insurance Fund administrative budgets will be $385.7 million and 1,247 staff positions. This is $8.8 million less than in the staff draft budget. The combined budget for 2025 is $433.3 million, with 1,251 staff positions.
| Budget | 2024 | 2025 |
|---|---|---|
| Operating | $374.5 million | $418.4 million |
| Capital | $6.1 million | $10.0 million |
| Share Insurance Fund Administrative | $5.1 million | $4.9 million |
| Grand Total* | $385.7 million | $433.3 million |
Information on the NCUA’s budget can be found on the Budget and Supplementary Materials page on NCUA.gov.
Central Liquidity Facility Budget Approved
The Board unanimously approved the 2024 Central Liquidity Facility Budget of $2,199,065.
Said Chairman Harper, “In this current economic environment of heightened interest rates and liquidity risk for credit unions, including several with over $1 billion in assets, the role of the Central Liquidity Facility as a liquidity backstop has assumed even greater importance. The saying, “there’s strength in numbers,” is especially applicable to the CLF because the more members it has, the more effective it is as a liquidity facility.”
The NCUA Board, in its capacity as the CLF Board, must approve the CLF’s budget. In prior years, the CLF’s expenditures were accounted for in the NCUA operating budget. This request for approval of the CLF budget reflects the recent NCUA Board decision to strengthen the independence of the CLF and separate its budget from the NCUA operating budget.
The 2024 CLF budget justification is available on the NCUA website. The document includes information on the spending categories, sources and uses of funds, and planned activities.
Board Approves Final Notice on Operating Fee Schedule Methodology
The NCUA Board unanimously approved the issuance of a final notice making the following revisions to the Operating Fee Schedule methodology:
- Increasing the fee exemption asset threshold below which federal credit unions are not required to pay the operating fee from $1 million to $2 million.
- Increasing the fee exemption asset threshold in future years by the aggregate growth rate for federal credit union assets.
“Raising the operating fee exemption threshold to $2 million and indexing that threshold for inflation will provide a measure of relief to these institutions, bring the threshold back into alignment with where it once was, and keep it there going forward,” said Harper. “As I said when this rule was proposed, that’s a positive and welcome change for our smallest institutions.”
At its June 2023 meeting, the NCUA Board unanimously approved the issuance of a notice and request for comment about adjustments to the methodology the NCUA uses to determine how it apportions operating fees charged to federal credit unions. The Board uses these operating fees to fund part of the NCUA’s annual budget. The proposal provided for a 60-day comment period that ended on September 5, 2023.
Board Approves Request for Comment on Overhead Transfer Rate Methodology
The NCUA Board unanimously approved the issuance of a notice and request for comment on the existing Overhead Transfer Rate (OTR) methodology. The Board is inviting comment on the NCUA’s methodology to determine the OTR. The request for comment clarifies the four principles for calculating the OTR and the various cost allocations associated with the calculation.
Said Chairman Harper, “Calculating the OTR is complicated. It’s a classic Goldilocks-style dilemma. Adjust it too low, and federal credit unions must pay a greater portion of the agency’s budget. Calculate it too high, and funding the agency could fall disproportionately on state-chartered credit unions and insufficiently reflect the contribution of state supervisory agencies. Therefore, it is incumbent on the NCUA to get it just right. I encourage stakeholders in both the federal and state-chartered systems to provide their feedback.”
In 2017, the NCUA published in the Federal Register a request for comment regarding a revised OTR methodology based on the Board’s internal assessment and comments received from a 2016 request for comment. The primary goal of the proposed changes to the OTR methodology at that time was to simplify the methodology and reduce the resources needed to administer the OTR. The Board committed to subjecting the four principles to public comment every three years and in the event the Board proposes a change to one or more of the principles.
Comments are due 60 days after the notice’s publication in the Federal Register.
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