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Treichel: Hey everyone, this
is Mark with a special Archive

episode of With Flying Colors.

I hope you enjoy.

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?

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.

Why don't you give those folks
a little synopsis of what

you did at your time at NCUA.

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.

I'm involved in a lot of training
and policies that go on around

capital markets issues at NCUA.

Um, 2009, I had a lost year.

I spent it at Westcorp while the
agency had Westcorp in conservatorship,

um, cleaning up at Westcorp and
helping wind things down there.

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

of special actions supervising
problem case officers and supervising

regional capital market specialists.

I enjoyed all of my 34 years with NCUA.

I was short a couple months.

But it was an enjoyable time.

I really enjoyed working with Freddie
Indians and all the people at NCUA.

Treichel: Very good.

Yeah.

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

You've been 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 NCOA's take is, and, and they

had a, an, 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,

uh, based on what you heard on NCOA's
liquidity webinar, what's your takeaway

from what they had to say today?

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, NCUA issued CU
10 guidance on how to comply

with NCUA Regulation 741 12.

They mentioned that today.

That was when NCUA came up with
the regulation requiring different

crowding needs 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,
um, NCWA 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.

This is 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 3 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?

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 1, 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 at what's going on
in 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, uh, in the, you know, you

Treichel: talk, you 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.

I have.

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.

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
have 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

an 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.

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Miller: 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.

And 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.

Yeah.

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,
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 pay rates, how those are
impacting credit unions, liquidity.

How we're seeing NCUA 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?

Miller: I think this is one where they're
still overreacting and responding late.

The 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.

Parties 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, and 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 member 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, and 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.

They're long term assets.

It's really peaked right at 2021,
right before the rates 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.

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 and the basal coverage ratio.

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 in 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.

So 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.

NCUA, 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 in a rear view mirror.

I'll use that term rear view mirror.

What was our liquidity ratios last month?

Or, or here's our last quarter
end 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, nine

months from now, and a year from now?

If 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 NCOA 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 NEV.

Which has, 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 two years
ago now NCUA 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 it,
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 did that trick Thoughts Todd.

Miller: They made one
statement and I wrote it down.

So this was the whole part of our webinar
supposedly on liquidity, but in their

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

test is not how credit unions 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 NCUA 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 Freddie Eanes don't

manage to our NCUA supervisory test.

But they keep writing doors to credit
unions that says that is going to be our

measurement is our NCUA 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 NSUA, you'd hear that from

when you'd go to GAC and you'd get in
a line, meet and greet line and the,

the NSUA board would chat with them
and 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'd.

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
you, 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 an exam.

So I'll just leave it at that.

Miller: 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
1220 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, um, but amongst our clients, um,

they certainly get treated as if borrowing
and non member deposits are frowned upon.

We're getting findings indoors 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.

Um, but most of them, even our
clients that we've talked to a

lot of 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 in

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 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

credit and they're going to be
having to raise deposit rates

even when rates start falling.

Right.

Just right sizes.

Themselves to their funding
needs and their members needs.

Treichel: Just as we were chatting, one
of the federal reserve folks, one of

the, one of the, 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, and oh, by, oh, by the
way, the market went down right after he

said it, it'll impact rates a little bit.

So

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

Treichel: right?

Yeah.

Yeah.

I know all those

Miller: 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 that their

grocery bills gone up 10 percent then 20
percent and 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 you, you've said in some other
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.

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 is 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 expense

of, I don't know what it was, 400.

400,

Treichel: yeah.

Miller: And 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.

1, 2 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.

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

does it trigger anything in your head?

Miller: I think NCUA 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

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.

Yeah.

The, 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.

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.

Usually.

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, you know, 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, a little bit more credit risk there.

Those types of things make examiners
nervous when they see credits 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 book 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.

Miller: With adequate capital, well
capitalized, a 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 have falling

capital and are 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

eight, 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.

The 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.

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.

Maybe they're going to another
institution who's paying a higher CD rate.

Down the road, Cardigans 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?

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.

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

Maybe some of the smaller ones have.

Um, 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.

Treichel: That's a fact.

That's a fact.

We've seen that, uh, we've, 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 as far as information.

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 1 for 10
right now over the last few.

Treichel: Yeah, I think I'm,
I think I'm like 1 for 15.

I'm gonna, I'm gonna log in as, I
don't know, Johnny Rockets or something

next time so they can't tell it's me.

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.

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

And they still don't.

They see my name.

I'm saying, 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.

Have a great day, 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.

Katie: Thank you for joining us on
this episode of With Flying Colors.

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