PowerComment®: A Valuable Tool


Created by the California Credit Union Leagues, PowerComment® is a valuable advocacy tool that lets your voice be heard by state and federal regulators. PowerComment provides you with access to executive summaries of proposed rules, discussion boards, and the ability to write your own comment letter and immediately submit it to regulators.

Currently in PowerComment you can learn about and take action on important rules, such as:

  • NCUA’s revised overhead transfer rate (OTR) methodology
    The NCUA Board is seeking comments on proposed changes to the OTR methodology. The proposed changes are intended to reduce the complexity of the OTR methodology and reduce the resources needed to administer the OTR. The proposed formula applies the following four underlying principles to the allocation of agency operating costs: 

1. Time spent examining and supervising FCUs is allocated as 50 percent insurance related.
2. All time and costs NCUA spends supervising or evaluating the risks posed by federally insured state-chartered credit unions (FISCUs) or other entities NCUA does not charter or regulate (for example, third-party vendors and CUSOs) is allocated as 100 percent insurance related.
3. Time and costs related to NCUA’s role as charterer and enforcer of consumer protection and other noninsurance based laws governing the operation of credit unions (like field of membership requirements) are allocated as 0 percent insurance related.
4. Time and costs related to NCUA’s role in administering federal share insurance and the Share Insurance Fund are allocated as 100-percent insurance related.

     Comments on the proposed OTR methodology are due by August 29, 2017.

  • NCUA’s plan to close the Temporary Corporate Credit Union Stabilization Fund (TCCUSF) and set the Share Insurance Fund’s normal operating level to 1.39 percent
    The NCUA issued a notice and request for comments on its proposed plan to close the TCCUSF in 2017, merge its assets, properties, and funds into the National Credit Union Share Insurance Fund (Share Insurance Fund), and raise the Share Insurance Fund’s normal operating level (NOL) from 1.30 percent to 1.39 percent. The notice outlines how the NCUA would merge the two funds. The Stabilization Fund would be shut down on October 1, 2017. The NCUA projects that when the funds are merged the Share Insurance Fund’s equity ratio would increase to between 1.45 percent and 1.47 percent, which would trigger an equity distribution in the second quarter of 2018. The projected 2018 distribution would be $600 to $800 million. The NCUA would also increase the NOL of the NCUSIF from 1.30 percent to 1.39 percent because of the additional risk to the Share Insurance Fund when it includes certain assets and liabilities of the Stabilization Fund. 

    Comments on the notice are due by Sept. 5
    ; however, Board Member Rick Metsger strongly encouraged credit unions to comment as soon as possible as NCUA is working against an end of September deadline to close the Stabilization Fund.

With PowerComment you are empowered to join the movement and help ensure a sustainable future.
To learn more about these and other proposals, log in to www.PowerComment.org and take action today!

Not a PowerComment user yet? Click here to sign up and let your voice be heard! 
Already a PowerComment user, but forgot your password? No problem, enter your email address, click on Reset My Password, and follow the prompts. 
For questions or assistance, please contact Sharon Lindeman at 909-212-6063, or sharonl@ccul.org

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