CUNA Regulatory Comment Call


December 27, 2001

STUDY OF THE VALUATION OF NON-MATURITY SHARES


(NOT A MAJOR RULE)

EXECUTIVE SUMMARY

Comments are due to NCUA by April 24, 2002. Please send your comments to CUNA by April 12, 2002. Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Senior Regulatory Counsel Catherine Orr at corr@cuna.coma; or mail them to Mary or Catherine in c/o CUNA's Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, 6th Floor - South Building, Washington, DC 20004. You may also contact us if you could like a copy of the request or you may access it by clicking here. You may obtain a copy of the study from CUNA or from the NCUA website at the following Internet address: http://www.ncua.gov/news/draftboardactions/BAM-01-12-13-6.pdf.

DESCRIPTION OF THE PROPOSAL/STUDY

NCUA commissioned the National Economic Research Associates (n/e/r/a) to conduct a study of methods to value non-maturity shares. The n/e/r/a study provides recommendations for the most suitable valuation approaches. The study proposes effective maturities that may reasonably be used for credit union shares in which the cash flows are not explicitly documented and modeled by the credit union. The study proposes a method to value these shares, and discusses the appropriate discount rate for these funds. Recommendations are also provided where credit unions analyze their cash flows from these shares. NCUA believes this study will be most relevant to those credit unions that assume non-maturity shares materially mitigate the risk of a high level of long-term assets.

The n/e/r/a study may be useful in evaluating net economic value (NEV) analysis. NEV analysis measures the potential effect of changes in interest rates on net economic value. NEV means the fair value of assets minus the fair value of liabilities. Valuation techniques used to estimate fair values require assumptions about maturities and interest rates to calculate the present value of cash flows of non-maturity shares. As with gap analysis and review income simulation models, NCUA examiners judge whether these assumptions are reasonable.

Some of the main conclusions reached in the n/e/r/a report are as follows:

  Min (Years) Mid (Years) Max (Years)
Share Drafts
(Transaction Accounts)
2.0 2.5 2.8
Regular Shares
(Passbook)
2.5 3.0 3.5
NMDAs
(Non-Maturity Share Assumptions)
0.5 1.0 1.5

QUESTIONS ON THE PROPOSAL/STUDY

  1. Please provide specific comments on the study. If there are points with which you disagree or you believe are incorrect, please provide both the specific citations in the study and the support for your conclusion.













  2. NCUA is considering establishing a “safe harbor” for non-maturity share assumptions, such as a maturity of 1 year for money market shares, 3.0 years for regular shares, and 2.5 years for share drafts. Examiners would judge these, or shorter, terms to be acceptable maturity assumptions for non-maturity shares. Do you think this approach is reasonable?

    Yes ______ No ______

    Why or why not?













  3. The characteristics of a non-maturity account, not its labeling, are important determinants of value. For example, two credit unions may have accounts labeled regular shares: the first credit union may rarely change the interest rate; in contrast, the second may reset the rate frequently, similar to a money market share account at the first credit union. What documentation, if any, would be appropriate to use “safe harbor” assumptions?













  4. A credit union might choose to use its own empirical analysis to demonstrate a risk mitigation value larger than a “safe harbor” assumption. NCUA examiners would expect a statistically valid empirical analysis to justify such values. Should NCUA use the validation guidelines addressed in Chapter VIII of the report?

    Yes ______ No ______

    If not, please provide alternative guidelines you believe are appropriate and provide the specific evidence to support your recommendation.













  5. Is there background information from sources other than those covered in the n/e/r/a study that NCUA should consider?

    Yes ______ No ______

    If so, please indicate the source of the information and the results. If possible, please provide complete copies of the studies or the analysis.













  6. NCUA is contemplating whether to conduct an empirical study of credit union non-maturity share behavior. Please provide specific recommendations on what should be included in such a study.













  7. Are there other considerations in the valuation of shares, beyond those discussed in the n/e/r/a study, which should be taken into account?

    Yes ______ No ______

    If yes, what are the other considerations?













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