NAFCU questions whether NCUA has the statutory authority to institute individual minimum capital requirements. Under the proposed rule, NCUA introduces a new power to raise individual minimum capital requirements for credit unions “that varies from any of the risk-based capital requirement (s) that would otherwise apply to the credit union…”

When a credit union engages in any higher risk activity, it should be compatible with a credit union’s risk tolerance, administrative capabilities, and strategic goals. The projected and realized impact on a credit union’s financial performance should be analyzed regularly. Reasonable program limits should be established as well as on-going program monitoring and analysis.

This letter focuses on three higher risk lending activities – sub-prime lending, indirect lending, and outsourced lending relationships. Each of these lending activities can make good strategic business sense for credit unions when done with proper care. However, engaging in any of these lending activities exposes a credit union to a range of risks including credit, interest rate, liquidity, transaction, compliance, strategic, and reputation.

Risk-based lending benefits borrowers with strong credit histories by providing them lower interest rates. A properly planned risk-based lending program rewards borrowers based on how they manage their credit histories. As a member’s credit history improves, risk-based lending should recognize and reward the borrower’s financial improvement. To work properly, risk-based lending requires:

  • specialized expertise,
  • sound planning, and
  • reliable monitoring and control systems.

Risk-based lending is a means by which a credit union may be able to more effectively meet the credit needs of all its members. It involves setting a tiered pricing structure that assigns loan rates based upon an individual’s credit risk.

Risk-based lending generally has the most significant benefit for two broad categories of borrowers:

Pages