NCUA Announces Central Liquidity Facility Investment Policy Changes
Alexandria, Va., July 31, 2009 The National Credit Union Administration (NCUA)
today announces that, effective August 3, 2009, the Central Liquidity Facility (CLF)
will transfer its funds from U.S. Central FCU (USC) to the U.S. Treasury and invest
them in a laddered portfolio of U.S. Treasury securities. Additionally, NCUA will
explore alternatives regarding the transfer of the primary ownership of CLF stock
from USC to other credit unions or groups of credit unions through the anticipated
reforms of the corporate network. This change is essential for CLF to implement
for operational purposes and is not based on a concern or diminished confidence
in NCUA’s conservatorship efforts to restore USC to financially strong operational
status.
Ultimately, CLF is taking these necessary actions to: 1) preserve its full borrowing
capacity; and 2) continue in its role uninterrupted as a stabilizing agent and contingent
liquidity provider to the credit union system.
Accounting for CLF investments and stock ownership: The existing interrelationships
between USC’s ownership stake in CLF, USC’s conservatorship, the corresponding National
Credit Union Share Insurance Fund (NCUSIF) assistance it receives, and the CLF liquidity
advances to NCUSIF on behalf of USC add complexity to the financial disclosure requirements
that in turn necessitate changes to CLF’s investments of capital stock proceeds
and its stock funding arrangements.
In consultation with its auditors, CLF has determined this change is necessary because
Generally Accepted Accounting Principles (GAAP) accounting rules may require the
funds invested in U.S. Central to be presented on CLF’s financial statement as a
contra equity account rather than an asset (as it had always previously been classified).
Since the investment in USC is equal to the sum of CLF’s paid-in capital stock and
retained earnings, this contra equity treatment would effectively result in total
member equity of zero. Because CLF’s borrowing authority is determined based on
a multiple of its equity, this treatment would effectively reduce CLF’s borrowing
amount to zero.
This accounting treatment leads to an untenable situation because of its corresponding
impact upon the CLF’s borrowing capacity. CLF’s borrowing capacity is based upon
its total subscribed stock and surplus (i.e., total capital). By transferring its
investable funds from the current U.S. Central accounts into Treasury securities,
the unfavorable accounting treatment is rectified as these funds are immediately
recorded as an investment asset on the balance sheet. This in turn means CLF’s equity
will not have to include a contra equity account and thus restores its borrowing
capacity to its full maximum potential of twelve times subscribed stock and surplus.
Role of CLF funding in corporate stabilization efforts: CLF funding has been a critical
component of NCUA’s ongoing efforts to stabilize liquidity in the credit union system,
and it remains an integral part of the agency’s transition plan to establish a strongly
reformed corporate credit union network. These contingency liquidity efforts, while
highly effective, are now impacted by the accounting implications described above.
Because of NCUA’s strong commitment to achieving lasting financial reform and the
central role that CLF will continue to play, the agency must take proactive steps
now to address these attendant matters.
Changing status of U.S. Central’s ownership interest: For its part, USC must similarly
reevaluate its role as a CLF stock owner. USC currently owns the vast majority of
CLF stock and the reinvestment of the stock proceeds back into USC is a circular
transaction in which no funds actually exchange hands and results in a self-funded
purchase of stock. This longstanding arrangement had permitted USC to acquire, and
bear the cost of, the CLF stock on behalf of the vast majority of natural person
credit unions that belong to the Agent Members of CLF. Now, with the requisite change
in how CLF funds are invested, the stock purchase is not self-funding and it does
not make economic sense for USC to hold the vast majority of stock on behalf of
credit unions.
Thus, it is necessary for CLF to consider ways for the orderly exchange of CLF stock
ownership from USC to other credit union owners in a manner that fully preserves
the CLF’s role as a stabilizing agent poised to meet the contingent liquidity needs
of its member credit unions.
During the next several months, NCUA will seek input and ideas from the credit union
industry to determine the future CLF stock ownership arrangement that is best suited
to achieve a seamless transfer of stock and most importantly, a continuation of
the important contingent liquidity resource that CLF provides.
Background: CLF is a mixed ownership government corporation that serves as a back-up
lender to meet the unexpected liquidity needs of its member credit unions when funds
are unavailable from standard credit sources. The two primary sources of funds for
the Facility are stock subscriptions from credit unions and borrowings from the
Federal Financing Bank.
CLF membership consists of 104 Regular Members and 1 Agent Group Representative,
U.S. Central FCU (USC), representing 27 Agent members. USC owns approximately 96
percent of CLF stock purchased on behalf of its 27 Agents and their member natural
person credit unions that do not belong directly to CLF.
For more information on the NCUA Central Liquidity Facility, please visit the NCUA
website:
http://www.ncua.gov/Resources/CLF/Index.aspx
The National Credit Union Administration is the independent federal agency that
charters and supervises federal credit unions. NCUA, with the backing of the full
faith and credit of the U.S. government, operates the National Credit Union Share
Insurance Fund (NCUSIF), insuring the savings of nearly 90 million account holders
in all federal credit unions and many state-chartered credit unions.