By Mark H. Smith CEO, Mark H. Smith Inc.
On January 10, 2013, the NCUA Board enacted changes which effectively modified the recently adopted IRR Regulation for over 2,000 federally insured credit unions. After a painful process lasting almost two years, NCUA has taken the long way around in the process of implementing its IRR Regulation.
For credit unions with assets greater than $50 million, nothing has changed. You are subject to the IRR regulation which was effective September 30, 2012.
For credit unions with total assets less than $50 million...
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By Mark H. Smith CEO, Mark H. Smith Inc.
Some of you may remember as a child the paint by numbers coloring books. The outlines were sectioned off into numbered areas, each corresponding to a color. It was easy to paint a picture but the outcome left a lot to be desired.
Occasionally we find the paint by numbers approach to credit union regulation. Recently it came to us in the form of the SIRRT Ratio. The Supervisory Interest Rate Risk Ratio Threshold (SIRRT) was manufactured by NCUA to determine if a small credit union were required to confirm with the NCUA IRR regulation. The objective was a one size fits all estimate of balance sheet complexity and risk. It was intended to apply to credit unions with assets from $10 million to $50 million and determine if they were to comply with the new IRR regulation.
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March 2013
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Client Corner
Best When Used By
By Cynthia R. Walker, COO, Mark H. Smith, Inc.
We all are familiar with the best when used by date marked on products we purchase. This date is useful for both the consumer and the retailer. For the consumer, the date helps us have a better idea of how long we can anticipate the item will last before going bad. For the retailer the date is helpful in inventory and product management.
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