Ok... so here's the deal... You can't lend in this market so you look to your investments to "bring home the bacon". After everyone has looked at every type of bond out there, the only one that makes any sense at all is the step-up bond. They start at 2% to 3% and move all the way up to 7% or 10% over 8, 10, even 15 years. Wow, you say. That long? Yes, and here's why... NONE OF THESE HAVE EVER GONE TO MATURITY. Somewhere along the way, the rate will step up above the market and the bond will be called. With the right broker you can get these at a discount. Even if the bond is called after the first lock-out period... you earn 4 to.5 TIMES what you would anywhere else. So it got called? So what? Go buy another. DUH!!!!
So why do I say NCUA is incompetent here? If you have these, you have to risk rate them to MATURITY (the % you must keep on hand in equity for a 10+ year bond is 20%).
Why is that incompetent? You see, when we fell victim to this scam by NCUA a bunch of years ago, I actually called NCUA and talked to the Alfred Henry who put that in place. I was told in glowing and fatherly terms that "NCUA is trying to make the call report easy to complete (I remember his exact words) and calculating average life on these would impose too much of a burden". After ADMITTING that NONE OF THESE EVER go to maturity, he stated that NCUA had to draw a line somewhere and "unfortunately" these fell on the "RISK RATE TO MATURITY" side of the equation... "We're NCUA and it sucks to be you" - paraphrase by me.
So now our UNDERSTANDING NCUA examiner came in to me (and I've heard of others as well) and said WE'VE FOUND YOU IN EXCESS OF YOUR RBNWR ON X-Date.... You are now under PCA. Ok, how did I get there? Too many long bonds I had carried at average life that put us over when they were rated to maturity. So, I sold one bond and WHAMO SMACKO... I was under the RBNWR. Cool huh?
NOT SO... NCUA said I had to serve our my 2 years under PCA for that transgression, even though it was corrected the same day the error was pointed out. Then another Alfred Henry from NCUA came in and had the nerve to want to talk to me about my earnings and how I was going to get back in their good graces and work myself out of PCA....I verbally threw him out of my office.
How do you get to PCA even if you have over 10% equity... your RISK BASED EQUITY REQUIREMENT MAY EXCEED YOUR EQUITY. Look on page 11 of your call report to see if that exceeds 7%. You can also look at page 12 to see the actual calculation (and do some "what if" scenarios to make sure you don't get sent to PCA Jail!!
Story as current as this week. Another cu in another state had step-ups and had them term-listed based upon average life on page 1 of the call report. Their examiner comes in and does a exam effective 3 or 4 months ago and finds that they should have been listing their step-ups at maturity... The examiner makes the changes and finds the cu has insufficient reserves for its RBNWR and slaps them with PCA.... Here's where it gets good. All those bonds have been called in the intervening time and they are currently under the RBNWR. Cool HUH? No... "I did the exam as of that date and on that date you were undercapitalized --- Go straight to PCA Hell for two years". They can expect a visit from another examiner in the near future wanting to "help" them with their earnings issues.
And you wonder why I rant? You can't make this stuff up!
Recently someone sent me an anonymous email (that's ok I'm kind of an anonymous kind of person here anyway) and stated I was a blow hard as evidenced by some perceived benchmark they held to. Well, Sir or Madame, it's not being a blow hard when you are right or you are pointing out a wrong being done. Perhaps this person was offended by characterization of the board members of WesCorp or of the action of NCUA. Get over it! WesCorp was a train wreck caused by management and enabled by incompetent board members. Just because they escaped going to trial, doesn't mean they were blameless.... it just shows how incompetent NCUA is in putting a case together when they co-enabled the debacle. If you don't like what I'm saying.... you must not be paying assessments... because everyone that is, HATES what happened to them and whether they say it or not... hold NCUA as accountable as anyone else for their pain and suffering.
If you have some facts that I gave that are wrong, let me know... I've been wrong before.... After all, this is 1st Thoughts.... not second or after the fact. But, whoever you are, I don't post snarky comments.... Go get your own blog and flame me there if you like. Expound upon what ever floats your boat.... it's a free country (for now).
If anyone has questions regard the RBNW and how it "REALLY" works, drop me a line with your cu name and I'll give you some more direction from your actual call report data. I could save you from unnecessarily going to PCA Hell!
You can now understand the compelling importance of a 300 rate shock to the investment portfolio. Can't you see the rates taking off like a pitbull on a poodle? It could sure as hell happen any time real soon. You got too much risk on that balance sheet. Best keep the money in the Federal Reserve over night account at say .10 bps. 300 rate shock - in todays environment. Has the NCUA gone completely mad? The short answer: YES. How are you going to pay the NCUA assessment when the drop the hammer on your investment income? Sell tickets to your annual meeting, charge for deposits, charge for parking. Think outside of the box.
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