As Prepared for Delivery on July 30, 2020
Thank you, Mr. Chairman.
When I joined the NCUA Board about six years ago, I began a detailed study of the Overhead Transfer Rate (OTR) and found it entirely opaque and incomprehensible. In my view, it also yielded inconsistent and problematic results.
We worked to completely revise the OTR methodology and finalized a restructured rule several years ago. The new OTR rule is far more intuitive, transparent, and inherently fair.
That said, there is always room for improvement. I welcome and encourage members of the credit union community and others to submit comments on the OTR and the Operating Fee Methodology for our analysis.
I have no questions regarding the OTR submission for comment or the Operating Fee Methodology proposal.