As Prepared for Delivery on June 22, 2023
The item we are considering today for publication in the Federal Register is part of our ongoing commitment to transparency in the NCUA’s budgeting and financial management practices.
Funds for NCUA programs come from two sources. Part is paid by the federal credit unions and other by federally insured, state-chartered credit unions through transfers from the Share Insurance Fund using the overhead transfer rate. And the rest is paid through operating fees collected from federal credit unions themselves. The document we have before us will provide the public with an explanation of the NCUA’s methodologies for computing the overhead transfer rate and annual operating fees.
Additionally, I support the proposed changes that increase the exemption in which a fee is not charged for federal credit unions. In today’s action, we are raising the exemption to $2 million, which is up from $1 million. I also like how we index this figure to inflation. I do have some questions:
- Are there other fees or figures that we, as a Board, use that we should also consider indexing to inflation?
- I realize we are moving the exemption to $2 million. But given that we use $10 million for the CECL exemption because that is what is considered a small credit union, should this figure be used here as well?
- Shifting gears, and for the record, how would you compare and contrast our fee structure to the FDIC’s?
Thank you. I have no further questions.