Navigating NCUA's Liquidity Expectations; Insights and Strategies with Expert Todd Miller

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Treichel: Hey everyone.

This is Mark Treichel with another
episode of With Flying Colors.

It is April 4th and about, let's
see, about 45 minutes ago, NCUA

ended their liquidity webinar.

And I listened to it and Todd
Miller of my team listened to it.

If you've listened to this show
before, Todd, he talks a lot about

A lot of different topics, but
including liquidity as a former capital

market specialist and supervisor of
capital market specialists at NCOA.

So Todd and I are going to basically
give our take on what NCOA said

relative to liquidity and maybe dive
into, some related issues to that.

So Todd, how are you doing today?

Todd Miller: I'm doing fine, Mark.

Spring has finally come to Montana and
winter is going to come back tomorrow,

but for now, we've got some days in
the 70s, which are quite nice for us.

That's nice.

Treichel: That's good.

70 degree days.

That, that is, that
doesn't seem like spring.

That seems like summer in Montana.

All right.

So Todd, give it for, if anybody,
there might be some new listeners

listening for the first time.

Give, why don't you give those
folks a little synopsis of what

you did at your time at NCUA.

Todd Miller: Okay.

I spent from 1987 through 2021 at NCUA.

Started as an examiner in Montana, spent
the early 90s as a problem case officer.

From 2000 to 2010, I was a regional
capital market specialist, and involved

in a lot of training and policies that go
on around capital markets issues at NCUA.

2009 I had a lost year.

I spent it at West Corps while the
agency had West Corps in conservatorship,

cleaning up at West Corps and
helping wind things down there.

And then from 2010 to the end of
my career in 2011, I was a director

of special actions, supervising
problem case officers and supervising

regional capital market specialists.

I enjoyed all of my 34 years with NCOA.

I was short a couple months.

But it was an enjoyable time.

I really enjoyed working with credit
unions and all the people at NCUA.

Treichel: Very good.


And you've been in a lot,
involved in a lot of podcasts.

You've been in, in involved in a lot
of clients that we've been helping

and it's nice, to be able to talk here
about our take on what NCUA take is.

And, they had a, an hour long webinar,
it was about 50 percent questions, 50

percent presentation which is a good mix.

And I'll just throw it to
you based on what you heard

on NCUA's liquidity webinar.

What's your takeaway from
what they had to say today?

Todd Miller: I'm going to throw out
maybe three resources first, right at

the beginning, because most of what
NCUA talked about in the webinar really

comes from these three source documents.

And really that's the 2010 interagency
policy statement on funding

and liquidity risk management.

If people listen to the webinar
that was brought up, especially in

the question and answer session.

On multiple times back in 2013,
NCOA issued CU10 guidance on how

to comply with NCOA regulation 741.


They mentioned that today.

That was when NCOA came up with
the regulation requiring different

credit unions to have policies,
contingency funding plans, larger

credit unions, access to the Federal
Reserve discount window or the CLF.

And then last year in 2023, they issued
NCBI issued an interagency, or an addendum

to that 2010 interagency statement on
funding and liquidity risk, just on the

importance of contingency funding plans.

Everything in today's webinar is
really just a subset of what was

in one of those three documents,
primarily that interagency statement.

policy statement on funding
and liquidity risk management.

That was put out in 2010, right
after the last financial crisis.

Shortly after that, the OCC updated
their liquidity handbook in 2012.

Those are all really
good source documents.

Overall, today's seminar or webinar
the way I'd characterize it.

It's a refresher course on
those policy statements.

I think they were probably, it may have
been more helpful to smaller credit unions

than larger credit unions in my mind.

They didn't really say anything new to us.

There's some specifics we can talk about
as we go here, my initial take, this was

all primarily a review of Those guidance
documents that NCUA has issued previously.

Treichel: And I'll put in the show
notes, I'll have links to those, all

three of those, so that if someone
wants to get access to more details

and I'll also probably do a blog on
my website that'll have links to that.

So if someone's listening and wants
to find a quick way to find all

three of those we'll provide that.

Yeah, so let's get into the details.

What's the first detail that
you think's worth highlighting?

Todd Miller: They talked a lot about,
cash flow statements in here and

cash flow forecasts and triggers
for contingency funding plans.

They talked about using
historical numbers.

They talked about using stress numbers.

I think that the interesting pieces
of all of this is if you go back

to the last recession in 2010 2009,
we'll look at 2009 Credien's deposit

space back then were about 55
percent were money markets and CDs.

And then another, that was money
market CDs and wholesale funding.

Today we're at 52%.

There was some big changes in
2022 when rates started rising.

I think credit unions were maybe
slow to react or the market changed

so fast they couldn't react.

So there was these stresses
placed on liquidity.

We go from a low end rate
environment, low cost shares are

migrating to higher cost shares.

Credit unions are using borrowings to
manage that marginal cost of funds.

And I think they did that
in a very appropriate way.

So while the agency seems to be
very stressed about liquidity

pressures, I think they were right
to be stressed about them in 2022.

But if you look 2023, I think
credit unions have adjusted

to this rate environment.

The migration from lower cost to
higher cost shares is going to continue

for another year at least maybe a
little bit longer and I think that's

really just historical numbers.

Tell us that's where it's going
to go in terms of member behavior.

I think a lot of their sense of
urgency here with this webinar.

Was maybe needed in January or September
of January of 2023 or September of 2022.

I think right now the industry has
done a really good job of managing

this environment and a lot of
the liquidity stuff is behind us.

NCUA is still nervous, but the numbers
would indicate most of the credit

unions have adjusted really well
to it in the big scheme of things.

You talk, you

Treichel: talk about that 55%.

And we're getting close to that.

I think in some of our other conversations
and maybe some client conversations you've

called that the reversion to the mean.

And yeah.

And the other times when I think
reversions to the mean, I think about

the basketball player that just made 10
straight shots, which means that over

time he's going to miss 10 more, right?

So you get back if he's a
50 percent shooter, but.

But that was in the old days.

Now, I think when I think about reversion
to the mean, I think about that mix of

deposits that, that credit unions have.

And, they, I might've missed
something, but they did highlight

I'm going to probably get the
phrase Roz, but they talked about.

For deposits and the best
sources of liquidity.

And they talked about, member
shares plus like borrowings being

utilized, but did I, if I write that,
I don't think I heard a reference

to like non member deposits at all.


Todd Miller: They left
non member deposits out.

I don't remember them using that
word at all, even though non member

deposits are up a little bit.

And, you had me work with 38 different
clients over the last two years.

There's a good number of them
that had been dinged on their

usage of non member deposits.

And a lot of them have used non
member deposits, so they didn't have

to raise their certificate rates.

Another thing that wasn't mentioned
today, and this is a huge part of the

whole liquidity risk management, is I
never mentioned pricing today, they said

you got to have an appropriate share
structure and appropriate loan structure

and, that's all created by pricing and
catering to your members individual needs.

Some members are going to chase rates.

Some members, they want to keep
a pool of liquid assets there.

My wife calls it, she wants her 1.

99 in the bank.

And then in her term, that means that it
has to be like right at that 100, 000.

She kind of freaks out
if it's less than that.

Well, we're not going to put that
in an account earning us two basis

points, but we don't need a 5
percent certificate rate either.

We want that somewhere in the middle.

And I think our current bank's
paying three and a half.

Not that it's germane, pricing and
creating an appropriate structure means

meeting the needs of your members on
both sides of the balance sheet and

loan demand is up and part of that is
inflation and things of that nature.

Borrowing requirements are a little
bit higher amongst your members.

And I think the credit unions overall,
the industry, they've done a really

good job of meeting those member needs.

Maybe they were a little bit slow to
price loans upwards and that has to catch

up a little bit before they can start
creating these appropriate price products

to grow these core deposits again.

In this high rate environment, it
could be totally expected that you're

going to see this migration from
low cost shares into higher cost

CDs and higher cost money markets.

Like I said, credit is going
out and using borrowed funds.

And using non member deposits to keep that
marginal cost down is a perfectly normal

reaction for them to the marketplace.


So I think they've done
really well with that.

Treichel: Yeah, no I would agree.

Another word I wrote down was decay
rates and decay rate assumptions.

And it's like they, when I heard it,
I and, and again, this is an area

that I'm far from an expert, but I
know that it plays a big role in ALM.

And I know you've talked about it here and
you've talked about it on our client with

our clients but they basically brought
it up and then pivoted away from it and

didn't give any background relative to it.

But maybe any thoughts on the K
rates, how those are impacting

credit unions, liquidity, Okay.

How we're seeing NCOA maybe respond
in some instances to clients.

So I'm diverging from what was said in
the letter into kind of a, maybe what

should have they said about decay rates?

Todd Miller: I think this
is one where they're still

overreacting and respond in late.


Cash flow forecasts are very much tied
to the same assumptions that go into

an asset liability management model.

I think they mentioned that during the
webinar or during one of the questions.

But if you go back in these stress tests
and, even your 300 basis point shock

in an ALM model, that whole thing is
intended to get members to exercise the

options in these financial instruments.

Rates have went up 500 basis points.

All the options on the loan
portfolio have been exercised.

It's not going to get any slower,
even though they talk about,

stressing this, the loan assumptions
are not really going to be stressed

much more than they are now.

They're already, those prepayments are as
slow as they're going to go in most cases.

So that's maybe why they backed away
from it is because you can't stress

it much farther than you already have.

On the share side of it and
coming up with decay rates, we're

finding this with lots of clients.

Harding's used very conservative
assumptions for a lot of

years during the flat rates.

Of course, when things start
changing in 2022, the examiners,

you need to update your assumptions.

A lot of credit unions did that.

Their vendors did it.

What they found out is their previous
assumptions were overly conservative.

They're slowing them down and
using more reasonable assumptions.

And the examiners don't like that
because it makes them look better.

And it's just a matter of when rates
were low and interest rate risk were low

and there wasn't stresses, there wasn't
this impetus to put time and resources

on getting those assumptions precise.

And now it is, and they're
making it more precise.

And in many cases, the examiners
don't like the results.

Stressing share growth and share
migration, that does become very much an

individual thing for each credit union.

Loans, That's pretty much
homogeneous across the industry.

Loans behave the same, but
shares are very different from

credit union to credit union.

It has a lot to do with your field
of membership and your whole pricing

strategy for your whole product suite.

That is really not homogeneous
across the industry.

It's different for credit
unions to credit unions.

So a lot of your stress tests
are going to be geared to

changing your memory behavior.

But I think most credit unions probably
have a pretty good idea of what has

occurred in the last year, how much
money has migrated, and there's going

to be a little bit more to migrate.

So I don't think the stress is, it's
almost if NCUA is behaving, we have

another 300 basis point upcoming when
we don't, we're going to be probably

staying somewhat flat or If you believe
what everyone else says, rates will

start coming down, and that will
help folks, and it'll give time for

Credien's investments to catch back up.

Credien's really got caught in a trap.

Their long term assets
really peaked right at 2021.

Right before the rate started up.

When all that COVID money came in
During those flat rates credit unions

went long term with that either on
their loans or their investments

And then rates shot up on them.

And so it made them a little bit
harder to reprice Price assets, but

I think we're catching up to them now
that and the repricing is starting

to catch up when rates went up.

Initially, cratings were slow
to raise those loan rates.

They've started to catch that back up.

So, I think the future is looking good.

In terms of that.

So I guess the biggest variability that
we see and a person in the webinar asked

a question about liquidity ratios in the
basal coverage ratio and their response

was well, there's lots of ratios out there
and we have a data dictionary of them.

And one thing I think we're
finding with our clients is.

On exams, what's important to
the examiners varies a great

deal from examiner to examiner.

We've got examiners from credit
unions that are making up liquidity

ratios that are not mentioned
anywhere in NCUA's guidance.

And we have examiners and larger
credit unions think people should

be using the Basel coverage ratio.

The variations of that
are extremely difficult to

actually calculate that ratio.

So that variations in examiner's impetus,
that's a challenge for credit unions.

And so they better be just prepared
to justify what they're using to

measure liquidity versus how an
examiner suggests maybe they should.

They should be able to
defend what they're doing.

They brought up the things with
cash flow and they brought up limits

a lot, NCOA, they issue all these
disclaimers at the start of it, and

hey, this is this person's opinion,
not the agency's opinion, even

though it's the agency's webinar.

I find that interesting.

But for credit unions, I think one
thing that we see that is consistent

out there and is Where they get
criticized for examiners legitimately

is looking at liquidity mirror.

I'll use that term rearview mirrors.

What was our liquidity ratios last month?

Or, where here's our last quarter in
and now we're doing May and looking

at ratios that were, 45 days old.

Realistically, credit gains with your
cash flow forecast, you need to be

looking and computing your policy limits.

What do they look like in your cash flow
forecast six months from now, and nine

months from now, and a year from now?

Managing from a forward
looking space than that.

NCUA didn't really use that
terminology forward looking, but

that's what liquidity management
needs to be, is forward looking,

not looking in a rear view mirror.

And I noticed the one or two times they
did quote ratios, they quoted ratios

that were rear view mirror looks.

During the webinar but they inferred
with a lot of their emphasis on cash

flow forecast is managing liquidity
needs to be a forward looking process,

not looking in our rear mirror.

Treichel: Yeah, I wrote down
some, I have liquidity measures.

I wrote down some of the exact
same things you did there.

And then a couple other things you said.

It's almost as if NC way is thinking
there's going to be another 300 basis

point shock which I would bet against
right now, you don't want to bet on

where rates are going, but I'm going
to bet they're going to, they might

not go down as quick as we thought
they might inch up and probably not,

but they're going to go down yet the
NEV, which has, which, which, as we've

discussed in other podcasts, NEV has
weaknesses because it doesn't take into

considerations a lot of positives and.

It seems like what we're seeing with
some of our clients is they're using

that and saying, well, you know, if
it goes up another 300 basis points,

you're going to have these issues
and you need to develop a plan.

And then adding that to, was it 2 years
ago now, NCOA separated the S from the L.

You used to have just camel and
now it's camels and I think there

was a reference to this topic where
they just subtly brought it up.

In the podcast but, and then, so one last
rambling part of this question which you

know the Fed hat for large institutions,
the Fed has their shock test that they do.

And I was looking at that the other
day and the shock test they do right

now is they're having credit unions.

Shocked their balance sheet
with rates going down.

And then at the same time, they got
to do, they got to look at the NEV.

And I get, I guess you should have a plan
for both directions, but even the fed is

saying let's test it in this direction.

All right.

So that's a long rambling
statement, more than a question.

Any, anything you can, you, any of that.

They made one statement

Todd Miller: and I wrote it down.

So this was the whole pot or webinar
supposedly on liquidity, but in their

discussions on liquidity, they brought
up the fact that the NCOA supervisory

test is not how crediting should
manage their interest rate risk.

And I wrote it down because I don't know
how many clients we have, but we have

multiple clients that have gotten doors
to Reduce interest rate risk on the basis

of that NCOA supervisory test measure.

That, those are the words that are
in their document of resolution.

And, publicly they've said this on
many webinars and last year when they

got rid of the extreme interest rate
risk, they said credit unions don't

manage to our NCOA supervisory test,
but they keep writing doors To credit

unions that says that is going to be our
measurement is our NCU a supervisory test.

So no matter how many times
they say it to the public, their

examiners don't the message isn't
filtering down to their field staff.

Put it that way.

Treichel: That's what you'd always hear.

When I was at NCA, you'd hear
that from, when you'd go to G.



And you get in a line meet and greet line
and the the insulate board would chat

with them is saying, Yeah, I heard you say
this, six months ago at the board table,

but my examiner saying the exact opposite.

And then they'd come back and we,
we'd have a little discussion on it.

But and the other thing too.

So think about that statement.

And your earlier statement about
the disclaimer at the front, right?

So if a credit union is going to cite what
was said at this webinar, The examiner

might say at the beginning we came to
a disclosure is just the opinion of

those facts, those people at the table.

And that's not really what it should be.

They are the government, they
are speaking for the government.

And and the webinar was kicked off by the
chairman of the agency who if this was

face to face would be sitting right there,
and people should be able to rely on it.

But like you said their
statement is incongruent with

what we're seeing in exams.

I'll just leave it

Todd Miller: at that.

Yeah, and I'm sure there's more than a few
examiners were listening to the webinar.

I didn't keep track until they were
like just about done with the questions.

And then I looked up and, there was 1,
220 participants on, and some of them

were probably dropping off already at
the one time I chose to look, but, I do

know examiners, especially the subject
matter type experts and the RCMSs,

they're given time to listen to the
webinars, they don't all listen to them,

but, certainly a fair number of them do.

They hear this but there's lots
of ways for it to trickle down and

just sometimes it doesn't seem to
be the case they never said during

this webinar that borrowing is bad.

They never said non member deposits
are bad but amongst our clients They

certainly get treated as if borrowing
And non member deposits are frowned

upon we're getting findings in DOORS
to, reverse the trend in your core

deposit migration and use less borrowings
and use less non member deposits.

And, the examiners don't seem to think
that there's a cost to that, but there

is, because that means you're, Raising the
cost to your whole entire deposit base,

which is sometimes much more than the
cost to borrow or use non member deposits.

And yes, credit unions shouldn't be using
those funding sources without a plan.

But most of them, even our clients
that we've talked to a lot of

them, that is part of their plan.

And it's an active strategy to
not raise their funding costs and

then maintain their capital and
maintain their earnings and some

examiner they're still just nervous.

And like I said, at the beginning, I
think in some ways they're reacting to

liquidity events in 2022, rather than
what went on in 2023, the industry seems

to have adjusted really well to this
rising and rate environment over time.

And, time heals a lot of wounds
is, I think, something I've

heard you say many times.

It's not something I've said, but I've
gotten that from you, and I think that's

where we're at, where the industry is
at, is they've adjusted to these high

rates, and yes, there's going to be some
more adjustments to come yet, and there

is going to be some more migration from
core deposits to other share types, but

yeah, I think that's where we're at.

I think that's all part of a
reversion to historical means.

Their members are still adjusting
to these high rates as well.

We're all adjusting to
it a little bit slow.

And I'm sure even when rates start
going down, whatever date the Fed

decides that's going to start to occur,
I think you'll still see a lag where

they're still going to be crediting.

They're going to be having
to raise deposit rates, even

when rates start falling.

Treichel: Right,

Todd Miller: just right sizes
themselves to their funding

needs and their members needs

Treichel: Just as we were chatting
that one of the Federal Reserve folks,

one of the one of one of the districts
came out and said, I don't think we're

going to drop rates at all this year.

So you know that it Oh, by Oh,
by the way, the market went

down right after he said it.

It'll impact rates a little bit.


Todd Miller: from a bank deposit side
I would be fine if rates don't go down,

Treichel: right?



I know all

Todd Miller: those retirement
account balances of growing really

fast in the last six months.

Treichel: And that's, that's part of
the economic challenge getting off topic

here, but the white collar worker and the,
and those who are well off economically.

Are doing better than the folks
that are having to pay, their

grocery bills got up 10 percent then
20 percent and then another 20%.

And then we get excited that
it's only growing at 3%.

But yeah, it's of that new inflated rate.

And those folks are struggling
right now and it's going to impact

credit unions in a lot of ways.

Like podcasts that, that one
of the reasons share growth has

disappeared is because they're
paying, they're paying for their.

their food, they're paying for
their gas to get to work instead of

putting it into the credit union.

Todd Miller: Yeah, I see it just and
I belong to a couple of volunteer

clubs where you pay dues and we've
seen over the last few years where

people have, stepped away or complained
about, just 150 a year for dues.

It's wait, that's a big
bill for me right now.

So there is that segment of the
population, and I think it's bigger than

a lot of people suspect it was last fall
or maybe early this spring, the Federal

Reserve had their annual little article
out of, how many people can meet an

expensive, I don't know what it was, 400,

Treichel: and

Todd Miller: it's a huge percentage
of people can't, that's why that

loan demand is out there, in
the industry is, Even though the

inflation is down, it's real and it's
impacted a lot of people's budgets.

Treichel: No doubt.

No doubt.

I'm looking back to my List of notes.

One, two things.

When we were talking about ratios
just cash to assets or cash to

shares, there was reference to that.

There was reference to loan to assets.

Yeah, I've seen, we've become acquainted
with some state laws that say you need

to have X percent, which seems like a
higher percent than any credit union

might want to have on the books, but
I've also, seen some situations where

credit unions are being encouraged
to increase their cash balance.

There is no perfect measure, but when
I throw that out there, Todd, does

it trigger anything in your head?

Todd Miller: I think NCA is
a little nervous about it.

In 2022 across the industry, cash and
short term assets were down to 10%, which

is I think the lowest I have numbers
here in front of me going back to 2000.

That's the lowest it was ever in
2022 and virtually the highest

it ever was in 2020 at 18.

So it dropped.

just tremendously.

And then it ended 2023 at 11%,
which is still below historical

norms, where it used to run 1315.

Part of that, though, is I think
credit unions have actually just

gotten more analytic about how
much cash do you actually need.

And we've seen that after the last
recession from 2010 on, at least in

the Western region, there was a lot of
credit unions were tracking daily deposit

volatility and things of that nature.

And really when they go through those
exercises, there's a lot of the larger

credit unions, they really only need
three to 6 percent to handle, a couple

of standard deviations, a daily deposit.

So in the absence of ways to measure
how much liquidity they should have,

I think the industry as a whole
is just carried a lot of excess.

Treichel: That's a great point.


The more credit unions Digest the data
that they have the more into a pushes

the need to have a good estimate of
what your needs are looking forward, the

tighter you can get the closer you can
get to reality, which then allows you

to trim a few percentages off the cash.

That makes sense.

Todd Miller: You can manage your
risk a little bit more efficiently

and allocate it where it best
generates rewards for you.

And so a side effect of getting
more analytical and being better at

measuring numbers is you can ride
closer to what the examiner might

think is the edge of risk, right?

Because they don't see the analytics.

They have their different
historical perspective of what

they think is appropriate.


Based on exams they've done in their
district over the year, and that

could be smaller cardigans, it could
be larger cardigans, it could be a

wide divergence, but there's just
a great deal of just even the risk

acceptance amongst the exam staff.

There's quite a variance as to what's
acceptable from one examiner to the next.

But I think, when examiners get more
analytical, they run things closer

to the edge, a higher loan to share
ratio, a lower level of liquidity.

Take on a little bit more
operational risk here or a little

bit more credit risk there.

Those types of things make examiners
nervous when they see credit

unions changing their risk profile.

Even if they're doing it because they
have better analytical tools to manage

it, it still makes examiners nervous.

Treichel: So the last word I had written
down that I wanted to mention was in

reference to underwater investments.

They had a little bit of discussion
of your sources of liquidity and

with where rates are at, you've got
a lot of credit unions that have

investments that are upside down.

And quite frankly, if they
booked loans that are fixed.

They're upside down.

And it reminds me of something you've said
on here and the clients about, liquidity.

Liquidity can maybe turn into a liquid.

I'm going to get this wrong, but
here's what it is in my head.

Liquidity can be turned into some
sort of liquidity event if you have

problems with your asset quality, right?

So if you have, if you lose the ability
to hold those underwater assets, or you

start having loan losses in a way, Okay.

That it's eating up your flexibility
and your cash that can exacerbate

a liquidity event or a liquidity.

Todd Miller: Credit unions with
adequate capital, well capitalized

and decent asset quality are always
going to be able to go to the

wholesale markets and get liquidity.

It's never going to be an issue.

I mentioned the whole interagency policy
statement that was issued back in 2010.

That actually has a whole
section on credit unions that.

Are how falling capital and our
fall into PCA that they need better

contingency funding plans, so it
breaks them out whole separately.

We do have, I think at least one
client that has some capital challenges

that has to post physical collateral.

They haven't been cut off, but they've
been asked to post physical collateral

just because of where they're at.

That's a warning sign.

But in general, a well capitalized
credit union, you're sitting here

8 9 percent and your delinquency
and charge offs are under control.

You are going to be able to
go to the second wholesale

markets and get liquidity.

at a reasonable market cost.

Treichel: That's a good
thing for that credit union.

That's a good thing for the industry.

It's good, a good thing for the
insurance fund because that's

where most credit unions are at.

There may be examiners who push, beat
them up a little bit more than you and

I would like, from the side of the table
that we sit on now, but you're right.

They're going to be able to get access.

Todd Miller: Like I said, overall, I
think the industry in 2023 has responded

to liquidity events and the current
market conditions very well, and their

liquidity is pretty well managed.

Yes, core deposits are still going out
the door, they're finding their way

into certificates of deposit, and maybe
they're going to another institution

who's paying a higher CD rate.

Down the road, Cardenas have been able to
utilize that wholesale funding borrowings

and increasingly non member deposits
to manage through that because they see

this as something that we have to manage
through for, 18 months or 12 months or

Whatever the case may be and so their
whole utilization of those wholesale

funding sources Is perfectly reasonable it
helps them maintain profitability As they

right size those member share offerings.

I see it as a positive thing.

Treichel: Yeah, me too.

It's a tool in their toolbox.

So anything that else you want
to highlight before we wrap up

today, Todd, anything we missed?

Todd Miller: No, I'll just reiterate,
this whole webinar, it was just

subsets of what was in that interagency
policy statement issued back in 2010.

There's really nothing new under the sun
in terms of how you go and manage this.

Yes, you can get more sophisticated
with how you create these cash flows

and you can get more sophisticated about
your stress test, but really liquidity

management about is really about these
cash flow forecasts and managing down

the road, not looking behind you, but
having a forward looking mirror and

how do you best serve your members.

I thought overall the webinar was maybe
better than some that NCUA have done.

I don't know that larger cardians
would have benefited from listening it.

Maybe some of the smaller ones have.

I've seen it more as a good refresher
course on some of these principles.

They didn't give you a lot of
specifics, but They tend to regulators

tend to not do that in webinars.

That's a fact.

That's a fact.

We've seen

Treichel: that.

We lived it when we were there and we
see it from a different angle right now.

And I would agree it was
better than the average

Todd Miller: as far

Treichel: as information.

Todd Miller: I always ask at least
one question on these webinars

just to see if they'll answer it.

I don't know.

I may be about one for 10
right now over the last.

Treichel: Yeah, I think I'm,
I think I'm like one for 15.

I'm going to, I'm going to
log in as I don't know, Johnny

Rockets or something next time.

So they can't tell it's me.

Todd Miller: I haven't
thought about doing that.

Yeah, it might change the
results if we do that.

Treichel: They figure if we ask the
question it might be a loaded one,

Todd Miller: Yeah, sometimes I asked
benign ones that should be easy to

answer and they still don't, they
see my name and say no, not you Todd.

Treichel: Yeah, that's right.

Yeah, that's right.

We're going to answer all the
credit union questions first.

All right, Todd, thank you so much for
your time and listening to that, that,

that hour and sharing your thoughts.


With with our audience here today.

I appreciate it.

Todd Miller: Have a great day,

Treichel: Mark.

You too, Todd and listeners.

I want to thank you for listening.

I hope you'll listen again soon.

Mark Treichel signing
off with flying colors.

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Navigating NCUA's Liquidity Expectations; Insights and Strategies with Expert Todd Miller
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