CLF, FOM enhancements would help credit unions meet needs

November 15, 2022

CUNA wrote in support of several credit union priorities for the record of the hearing with NCUA Chairman Todd Harper’s testimony before the Senate, Banking, Housing, and Urban Affairs Committee Tuesday. Harper testified as part of a panel of federal financial regulators.

CUNA strongly supports extension of Central Liquidity Facility enhancements made by the CARES Act in 2020 that are scheduled to expire at the end of 2022. The CARES Act gives borrowing and membership requirement flexibility to make it easier for credit unions to access liquidity.

The CARES Act provisions represent a recognition that existing law does not afford credit unions sufficient access to emergency liquidity during times of crisis. It is inefficient and could prove unsafe to allow the CLF to return to its previous level of borrowing authority and credit union access, which will happen if this legislation is not enacted,” the letter reads.

“Upon expiration of these enhancements, the over 3,600 credit unions with CLF memberships through their corporate credit unions will no longer have access to the emergency liquidity backstop provided by the CLF,” it adds. “Extension of these enhancements will better protect credit unions from unexpected liquidity issues now and in the future as our economy faces recession and record inflation.”

CUNA also:

  • Supports H.R. 7003 and S. 4879, the Expanding Financial Access for Underserved Communities Act, would enable credit unions to provide financial services to more communities, which are often areas banks have abandoned or show little interest in serving.
  • Encourages NCUA to work with the FHFA to waive the regulatory requirement for the FHLBanks to treat negative tangible equity as a disqualifying metric of credit worthiness when considering new advances to members.
  • Strongly objects to any suggestion that the NCUA may need to charge a premium in the near future and/or that statutory changes to the NCUSIF funding guidelines are needed.
  • Noted concern with NCUA’s proposed 2023 budget reflects an 8.1% increase in expenditures overall compared to the 2022 budget.

Harper and the other regulators will testify before the House Financial Services Committee Wednesday.