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Financial Services Law Insights and Observations

NCUA Proposes Rule to Enhance Emergency Liquidity Standards

NCUA Bank Compliance

Consumer Finance

On July 30, the NCUA proposed a rule that would alter the emergency liquidity requirements applicable to all federally-insured credit unions. For those credit unions with assets of $10 million or more, the rule would require a contingency funding plan with strategies for addressing liquidity under an emergency scenario. The rule would require institutions with assets of $100 million or more to have access to backup federal liquidity. Institutions with less than $10 million in assets would have to establish a board-approved framework for managing liquidity under emergency circumstances, including a list of contingent liquidity sources. The proposal reminds credit unions that their access to the Central Liquidity Facility is expected to close in October 2012. Comments on the proposal are due by September 28, 2012.

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