CUNA Regulatory Comment Call


June 12, 2002

NCUA’s Draft Accounting Manual for Federal Credit Unions With Less than $10 Million in Assets

EXECUTIVE SUMMARY

DESCRIPTION OF THE DRAFT ACCOUNTING Manual

Other Than New Credit Unions New Credit Unions
(Less than 10 years in operation and less than $10 million in assets)
Net Worth Category Net Worth Ratio Net Worth Category Net Worth Ratio
Well Capitalized 7% or greater Well Capitalized 7% or greater
Adequately Capitalized 6% to 6.99 % Adequately Capitalized 6% to 6.99%
Undercapitalized 4% to 5.99% Moderately Capitalized 3.5% to 5.99%
   First Tier 5% to 5.99% Marginally Capitalized 2% to 3.49%
   Second Tier
    (and failed RBNW)
4% to 4.99% Minimally Capitalized 0% to 1.99%
Significantly Undercapitalized 2% to 3.99% Undercapitalized Less than 0%
Critically Undercapitalized Less than 2%    

Reasonable Timetable to Build Net Worth

Within # of Years in Operation Net Worth Ratio
3 Years 0% to 1.99%
5 Years 2% to 3.49%
7 Years 3.5% to 5.99%
10 Years 6% to 6.99%

QUESTIONS REGARDING THE DRAFT MANUAL

  1. If your credit union has assets under $10 million, it may continue to use the traditional chart of accounts numbering or it may design its own numbering system for its general ledger accounts. Do you think this flexibility will be helpful for your credit union for financial reporting?

    Yes ______ No ______

    Please explain.
















  2. NCUA has reorganized the draft Manual to track financial statement reporting; it is no longer organized according to chart of accounts numbers. Do you feel this new organization is more user-friendly?

    Yes ______ No ______

    If not, why not?
















  3. The section titled Topics of Special Accounting Interest is temporarily blank. NCUA plans to provide insertions in the future. Are there specific accounting topics you would like to see addressed in that section?

    Yes ______ No ______

    If so, what are those topics?

















  4. Do you agree with the discussion of PCA in the draft Manual?

    Yes ______ No ______

    If not, what changes should be made to make the PCA discussion more accurate?
















  5. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com