In letter to NCUA Board, NASCUS leader notes 16 states have already adopted – and more to come

ARLINGTON, Va. -- Two days before the NCUA Board hears a board briefing on including an “S” in federally insured credit unions’ CAMEL ratings, NASCUS President and CEO Lucy Ito has written to the board members urging the agency to adopt the component “earlier rather than later.”

Pointing out that 16 states have already adopted the “S” component (which stands for “sensitivity to market risk”) in their state CAMEL ratings – and at least five more are considering doing the same – Ito wrote that an adoption of the component before 2018 would be prudent.

“NASCUS and State supervisory agencies encourage NCUA to consider earlier adoption of ‘CAMELS,’” Ito wrote. “We again note that the separation of the “S” component does not require a credit union to develop additional management system enhancements where market risk is already appropriately identified, measured, monitored and managed as part of the ‘L’ component.”

The NASCUS leader wrote that in states that have adopted CAMELS, regulators and credit unions report positive outcomes with nearly no additional regulatory burden. She stated that, in practice, state supervisors have continued to use the same examination procedures for assessing liquidity and interest rate risks. However, she wrote, by rating the “L” and “S” components separately—rather than in a combined component—state regulators have been able to provide better information to credit unions to clearly delineate analysis between liquidity risk and interest-rate risks.

“From a credit union perspective, an ‘S’ rating is no longer masked by a stronger ‘L’ rating nor is an ‘L’ rating ‘dinged’ by a weaker ‘S’ rating; conversely, an ‘L’ rating is no longer masked by a weaker ‘S’ rating nor is an ‘S’ rating  ‘dinged’ by a weaker ‘L’ rating,” she wrote.

Noting that earlier rather than later adoption of “S” is prudent, Ito wrote that state examiners (“and NCUA examiners, to be sure”) have observed that the extended low-yield environment continues to encourage greater risk-taking by financial institutions. “Across the nation, historically low net interest margins have led some credit unions and their bank peers to ‘reach for yield’ by increasing their holdings of longer-duration assets or by engaging in other forms of increased risk-taking to maintain earnings,” she wrote.

Ito added that the anticipated rising rate environment may adversely affect earnings, net worth, net economic value as well as the market value of liabilities. “With investment income, loan income, and share dividends all being interest-sensitive, credit union earnings may be affected,” she stated. “In short, it behooves credit unions and their regulators to monitor ‘sensitivity to market risk’ separately from liquidity risk before rates start to rise—not after the fact,” Ito wrote.

Lucy Ito letter to NCUA Board members on ‘S’ in CAMEL (with list of CAMEL S states) available here.

Information Contact:
Patrick Keefe, Vice President, Communications, or (703) 528-5974

The National Association of State Credit Union Supervisors (NASCUS) is the primary resource and voice of the state governmental agencies that charter, regulate and examine the nation’s state-chartered credit unions. NASCUS membership is made up of state-chartered credit unions, state regulators and other supporters of the state credit union system. NASCUS is the only organization dedicated to the defense and promotion of the state credit union charter and the autonomy of state credit union regulatory agencies.