updated 05/17/13 01:54 PM
DERIVATIVES PROPOSAL; FASB DEADLINE
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Last week the National Credit Union Administration (NCUA) board approved a proposed rule that would allow eligible credit unions limited authority to purchase simple derivatives, interest rate swaps, and interest rate caps as a hedge against interest rate risk (IRR).
Additionally, the deadline for comments on the Financial Accounting Standards Board's (FASB) proposed accounting standards update is May 31, 2013.
NCUA Derivatives Proposal
The proposed rule would apply to eligible federal credit unions and federally insured state-chartered credit unions that are permitted under state law to engage in derivatives, and that meet NCUA's criteria.
The proposal requires credit unions seeking derivatives authority to apply for one of two levels of authority and demonstrate how derivatives will be part of an overall interest rate risk management plan. Level I and Level II authority differ on the permissible levels of transactions, as well as the application, expertise, and systems requirements associated with operating a derivatives program.
Under the proposal, eligible credit unions include credit unions with a CAMEL rating of 1, 2, or 3 and a management component of 1 or 2, and have assets of at least $250 million. Credit unions seeking Level II authority must also show why the limits under Level I are insufficient to effectively mitigate IRR under their plan.
The proposed rule calls for application fees. Level I application fees would start at $25,000 and Level II applications would range from $75,000 to $125,000. The NCUA board is also considering, and is requesting specific comments on, whether there should be additional fees assessed, such as an annual licensing fee to offset the costs of enhanced supervision for participating credit unions.
The Leagues are reviewing the proposal and will post a summary and related documents on PowerComment soon. There will be a 60-day comment period once the proposed rule is published in the Federal Register.

Click here to view NCUA's question-and-answer sheet on the proposed derivatives rule.

FASB Proposal on Credit Losses
FASB's proposal establishes a single “current expected credit loss (CECL)” model for the recognition of credit losses that includes forecasting the future. This model would replace the multiple existing impairment models in U.S. Generally Accepted Accounting Principles (GAAP) that primarily use an "incurred loss" approach.
The Leagues’ summary of the proposed update and more information are currently posted on PowerComment—and the Leagues’ comment letter will be posted soon. Credit unions can use PowerComment to submit their comment letter!
What is PowerComment?
PowerComment is an innovative and comprehensive online advocacy tool geared to assist every credit union in California and Nevada take an active role in helping shape proposed federal and state regulations. It lets users find up-to-date and easily digestible information on current proposed rules; participate in discussion boards with other users and the Leagues’ staff to increase their understanding of proposed rules; and write comment letters to regulators and immediately submit them.
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