Loan Participations; Purchase, Sale and Pledge of Eligible Obligations; Purchase of Assets and Assumption of Liabilities, 79548-79553 [2011-32719]
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79548
Proposed Rules
Federal Register
Vol. 76, No. 246
Thursday, December 22, 2011
This section of the FEDERAL REGISTER
contains notices to the public of the proposed
issuance of rules and regulations. The
purpose of these notices is to give interested
persons an opportunity to participate in the
rule making prior to the adoption of the final
rules.
NATIONAL CREDIT UNION
ADMINISTRATION
12 CFR Parts 701 and 741
RIN 3133–AE00
Loan Participations; Purchase, Sale
and Pledge of Eligible Obligations;
Purchase of Assets and Assumption of
Liabilities
National Credit Union
Administration (NCUA).
ACTION: Proposed rule with request for
comments.
AGENCY:
The NCUA Board (Board)
requests public comment on its proposal
to amend its loan participation
regulation and relevant provisions in
the eligible obligations rule and the rule
governing the purchase of assets and
assumption of liabilities. NCUA has
received many questions about the loan
participation rule, indicating confusion
about its application and its relationship
to these other rules. The proposed rule
reorganizes the current rule and directs
its regulatory provisions to the purchase
of a loan participation. It aims to
improve understanding of the
transactions covered under the rule, as
well as the requirements for purchase
and ongoing monitoring and the
applicability of related provisions. The
proposed rule also expands loan
participation requirements to federally
insured, state-chartered credit unions
(FISCUs).
SUMMARY:
Send your comments to reach us
on or before February 21, 2012. We may
not consider comments received after
the above date in making our decision
on the proposed rule.
ADDRESSES: You may submit comments
by any of the following methods (Please
send comments by one method only):
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• Email: Address to
regcomments@ncua.gov. Include ‘‘[Your
name] Comments on ‘‘Proposed Rule on
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DATES:
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Loan Participations’’ in the email
subject line.
• Fax: (703) 518–6319. Use the
subject line described above for email.
• Mail: Address to Mary Rupp,
Secretary of the Board, National Credit
Union Administration, 1775 Duke
Street, Alexandria, Virginia 22314–
3428.
• Hand Delivery/Courier: Same as
mail address.
• Public Inspection: You can view all
public comments on NCUA’s Web site
at https://www.ncua.gov/Resources/
RegulationsOpinionsLaws/
ProposedRegulations.aspx as submitted,
except for those we cannot post for
technical reasons. NCUA will not edit or
remove any identifying or contact
information from the public comments
submitted. You may inspect paper
copies of comments in NCUA’s law
library at 1775 Duke Street, Alexandria,
Virginia 22314, by appointment
weekdays between 9 a.m. and 3 p.m. To
make an appointment, call (703) 518–
6546 or send an email to
OGCMail@ncua.gov.
FOR FURTHER INFORMATION CONTACT:
Linda Dent, Staff Attorney, Office of
General Counsel, (703) 518–6540;
Vincent Vieten, Member Business Loan
Program Officer, Office of Examination
and Insurance, (703) 518–6618.
SUPPLEMENTARY INFORMATION:
I. Background
II. The Rule as Proposed
III. Section-by-Section Analysis
IV. Regulatory Procedures
II. The Rule as Proposed
I. Background 1
Why is NCUA proposing this rule?
The Board believes that involvement
in loan participations strengthens the
credit union industry. Loan
participations are a useful way for
federally insured credit unions to
diversify their loan portfolios, improve
earnings, generate loan growth and
manage their balance sheets and comply
with regulatory requirements. Credit
unions also use excess liquidity through
the sale of participations to increase the
availability of credit to small businesses
and consumers. The Board recognizes,
1 President Obama signed the Plain Writing Act
of 2010 (Pub. L. 111–274) into law on October 13,
2010 ‘‘to improve the effectiveness and
accountability of federal agencies to the public by
promoting clear Government communication that
the public can understand and use.’’ This preamble
is written to meet plain writing objectives.
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however, that loan participations also
create more systemic risk to the share
insurance fund (NCUSIF) due to the
resulting interconnection between
participants. For example, large
volumes of participated loans in the
system tied to a single originator,
borrower, or industry or serviced by a
single entity have the potential to
impact multiple credit unions if a
problem arises. Additionally, as both
federal credit unions (FCUs) and
federally insured state-chartered credit
unions (FISCUs) actively engage in loan
participations, it is important to the
safety and soundness of the NCUSIF
that all federally insured credit unions
(FICUs) adhere to the same minimum
standards for engaging in loan
participations. The Board believes such
standards are necessary to ensure the
NCUSIF consistently recognizes and
accounts for the risks associated with
the purchase of loan participations.
Finally, during examinations and other
FICU contacts, the agency has
encountered confusion concerning the
application of the current loan
participation rule regarding the entities
and transactions subject to the rule. For
these reasons, NCUA proposes to amend
§ 701.22, as well as relevant provisions
in § 701.23 and § 741.8. Interpretive
Ruling and Policy Statement (IRPS) 87–
2, Developing and Reviewing
Government Regulations, 52 FR 35231
(Sept. 18, 1987), as amended by IRPS
03–2, 68 FR 31949 (May 29, 2003).
a. How would the proposed rule change
the loan participation rule?
NCUA proposes to change the rule to
address only the requirements for a
FICU purchasing a loan participation.
The proposed rule also would better
detail regulatory expectations regarding
key aspects of a loan participation
purchase: the loan participation policy,
the loan participation agreement, and
ongoing monitoring of the loan
participation.
b. Does this rule create greater
restrictions than the current rule?
Yes, the proposed rule prescribes
certain concentration limits and
encourages a FICU to establish others.
The proposed rule also requires that a
loan participation agreement include
certain provisions to assist the
purchasing FICU in conducting its due
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diligence. The Board is proposing these
actions to ensure that loan participation
activity is conducted in a safe and
sound manner.
III. Section-by-Section Analysis
a. § 701.22—Introductory Text
The Board believes the addition of
introductory text to the rule clarifies the
scope of the rule and helps distinguish
a participation loan from an eligible
obligation under § 701.23. As proposed,
the introductory text clarifies that the
rule applies to a natural person federal
credit union’s purchase of a loan
participation where the borrower is not
a member of that credit union. An FCU’s
purchase of its member’s loan, in whole
or in part, is covered by NCUA’s eligible
obligations rule at § 701.23.
Additionally, by a cross-reference to
Part 741, the Board proposes to apply
the rule to natural person FISCUs.
Corporate credit unions are subject to
the loan participation requirements set
forth in Part 704 and, therefore, are not
subject to § 701.22.
b. § 701.22(a)—Definitions
The Board proposes to revise the
definitions for ‘‘originating lender’’ and
‘‘participation loan’’ to clarify that the
originating lender must participate in
the loan throughout the life of the loan.
The Board also proposes to add a
definition of associated borrower. The
proposed definition is self-explanatory
and is used in the provision on
concentration limits in § 701.22(b)
below. Additionally, the Board proposes
to change the paragraph’s format by
listing the definitions in alphabetical
order and removing the numeric
designations. These changes are
consistent with the format
recommended by the Federal Register.
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c. § 701.22(b)—Requirements for Loan
Participation Purchases
The Board proposes to revise this
paragraph by reorganizing and revising
the requirements for a loan participation
included in paragraphs (b), (c) and (d)
of the current rule. In the proposed rule,
information from these paragraphs is
organized into a revised paragraph (b),
with specific details added to improve
clarity and to address safety and
soundness concerns.
Revised paragraph (b) provides that a
FICU may only purchase a loan
participation if the seller is an eligible
organization and if the loan is one the
FICU is empowered to grant under
regulation and its loan policies.
Empowered to grant means a FICU’s
authority to make the type of loan
permitted by the Federal Credit Union
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Act or applicable state law, NCUA
regulations, and its bylaws and own
internal policies. Accordingly, the
Board proposes to remove the current
exception in § 701.22(c)(4), which
permits an FCU to purchase a loan
participation that was originated with
different underwriting standards than
its own. Removing this provision
prevents a FICU from purchasing a loan
participation originated with less
stringent underwriting standards than
the FICU uses in making its own loans.
The proposed rule, however, does not
prevent a FICU from purchasing a loan
participation with more stringent
underwriting standards than it uses in
originating its own loans.
Other requirements for purchasing a
loan participation include a written loan
participation agreement, a continuing
participation interest by the originating
lender of at least 10 percent for the
loan’s duration, and the borrower’s
membership in a participating FICU
before the purchase occurs. While the
proposed rule continues to require a
written loan participation policy, the
Board proposes to require specific
provisions to include in such policy.
For example, provisions would be
added to the rule addressing the
maximum limit on loan participations
outstanding and various concentration
limits. The Board recognizes there may
be other factors based on a credit
union’s size, complexity of operations,
and lending experience that should be
considered in formulating a loan
participation policy. The Board expects
a FICU to consider these factors in
establishing its policy. For example, a
FICU purchasing a loan participation
pool might perform statistical sampling
in evaluating the underwriting
standards of the pool. Conversely, a
large purchase representing a significant
portion of the FICU’s net worth should
require a full review of the loan
documentation before approval. The
Board expects a FICU to establish the
parameters for review, including a
periodic review for appropriateness, and
adhere to such parameters.
1. Concentration Limits on Loan
Participations
In establishing appropriate
concentration limits for loan
participations, the Board is seeking to
mitigate risk without discouraging
continued growth. The Board proposes
to use net worth, rather than
unimpaired capital and surplus, as the
means for striking this balance. Net
worth cushions fluctuations in earnings,
supports growth, and provides
protection against insolvency. As such,
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the Board believes establishing limits
tied to this measure is appropriate.
The Board also recognizes the need
for FICUs to identify and manage
various concentrations on their balance
sheet. Key among these are
concentrations involving the same
originator, one borrower or a group of
associated borrowers, and types of
loans, for example, by industry or loan
product. The Board proposes to limit
loan participation purchases involving a
single originator to a maximum of 25
percent of a FICU’s net worth. No
waiver provision is proposed for the 25
percent limitation. It also proposes to
limit loan participation purchases
involving one borrower or a group of
associated borrowers to 15 percent of a
FICU’s net worth, unless the appropriate
regional director grants a waiver. These
limits consider that a FICU purchasing
a loan participation generally does not
directly manage the risks associated
with the loan relationship, including
borrower contact and collection control.
The 15 percent limitation is consistent
with the 15 percent limitation on
member business loans to one member
or group of associated members set forth
in § 723.8 of the member business loan
rule. Part 723 allows members to apply
for a waiver from the 15 percent
limitation (as well as other regulatory
limitations). Waiver procedures are set
forth in § 723.11. It has come to NCUA’s
attention that many credit unions
believe the waiver process in Part 723
is not working efficiently and is often
not a viable, practical option. NCUA
seeks comment as to how the waiver
process in this regulation can be
structured to satisfy credit unions’
practical concerns while ensuring
prudent loan participation practices.
The Board expects to grandfather
credit unions that exceed the 25 percent
and 15 percent concentration limits at
the percentage rates of concentration on
the effective date of a final rule. The
grandfathered rates will diminish down
to the approved regulatory rates set as
participations are paid off or sold. The
Board is not establishing specific limits
for other concentrations identified
within a FICU’s loan participation
policy. It is important, however, for a
FICU to identify such concentrations
and apply a reasonable, supportable
concentration limit. Consistent with
agency guidance on the evaluation of
concentration risk, concentration limits
must be established commensurate with
net worth levels.2
The Board is particularly interested in
receiving comments on how these caps
should be structured, the
2 Letter
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f. Related Regulatory Provisions
appropriateness of these caps, and
suggested alternative approaches to
mitigating the inherent risks of loan
participations.
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d. § 701.22(c)—Minimum Requirements
for a Loan Participation Agreement
The proposed rule revises current
§ 701.22(b)(2), which requires loan
participation agreements to be in
writing, and moves requirements for the
agreement to revised paragraph
§ 701.22(c). The Board recognizes that a
successful participated loan relationship
depends, in large part, on the quality
and completeness of the participation
agreement. A well-written agreement
can minimize inter-creditor conflicts
during the life of the loan, especially if
the loan becomes delinquent and needs
to be worked out. The Board also
believes that any participation
agreement must clearly delineate the
roles, duties, and obligations of the
originating lender, servicer, and
participants.
As proposed, revised paragraph (c)
establishes minimum provisions that
any loan participation agreement must
address. For example, the loan
participation agreement must include a
provision requiring the originating
lender to retain at least a ten percent
interest in the loan throughout its
duration. This requirement mirrors the
current statutory requirement for FCUs.
Other provisions require the agreement
to identify each participated loan,
enumerate servicing responsibilities for
the loan, and include notice and
disclosure requirements regarding the
ongoing financial condition of the loan,
the borrower, and the servicer.
The Board is proposing these
minimum provisions to emphasize the
need for adequate documentation and
due diligence from the time of purchase
throughout the life of the participation.
Additionally, under proposed
§ 701.22(c)(1), a loan participation
agreement must specify the loan or
loans in which a credit union is
purchasing an interest. Where a
participation agreement involves
multiple loans, the documentation, for
example, can be as simple as an
addendum or schedule for identifying
each loan and a participant’s interest in
that loan. This provision clarifies the
existing prohibition against an FCU
purchasing a participation certificate in
a pool of loans.
e. § 701.22(d)—Remove and Reserve
The Board proposes to address the
contents of this paragraph in other
portions of the rule.
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1. § 701.23—Purchase, Sale, and Pledge
of Eligible Obligations
The Board proposes to add
introductory text to this section to
clarify the rule’s scope and to
distinguish it from transactions covered
by § 701.22.
2. § 741.8—Purchase of Assets and
Assumption of Liabilities
Section 741.8 is a safety and
soundness provision requiring
supervisory approval before a federally
insured credit union may purchase a
loan from an entity that is not insured
by the NCUSIF. No approval is
necessary, however, for the following
transactions:
• An FCU’s purchase of student loans
or real estate secured loans pursuant to
§ 701.23(b)(iii) or (iv);
• An FCU’s purchase of its member
loans pursuant to § 701.23(b)(i); or
• A FISCU’s purchase of its member
loans under state law comparable to the
provisions in § 701.23.
Currently, there are no exclusions under
§ 741.8 for loan participation purchases.
In practice, however, as long as an
FCU’s purchase complies with § 701.22
requirements the FCU is not required to
obtain separate regional director
approval for the transaction. The Board
proposes to add language to § 741.8 to
specifically state that Regional Director
approval is not required for a loan
participation purchase that complies
with § 701.22 requirements. The
exclusion would apply to both FCUs
and FISCUs.
3. § 741.225—Loan Participations
Section 201 of the Federal Credit
Union Act states the Board is authorized
to insure the member accounts of statechartered credit unions that have
applied to, and been approved by,
NCUA for federal insurance coverage.
Credit unions receiving federal
insurance must agree to comply with
the requirements of Title II and any
regulations prescribed by the Board
pursuant to this title. Pursuant to this
authority, the Board proposes to amend
Part 741 by adding a new § 741.225 to
extend the participation rule’s coverage
to federally insured, state-chartered
credit unions. Since 2007, FISCUparticipated loan balances have
increased 27 percent, from $5.7 billion
in 2007 to $7.2 billion in 2010 and have
consistently accounted for the majority
of outstanding loan participations.
Similarly, since 2007, FISCUs- overall
experienced a higher delinquency rate
in their loan participation portfolios. At
year-end 2010, the delinquency rate for
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the FISCU-participated portfolio was
4.11 percent, compared to 3.74 percent
for all FICUs.
Based on June 30, 2011, Call Report
data, FISCUs hold 56 percent of
outstanding loan participations and are
responsible for approximately 55
percent of participation loans purchased
and 68 percent of participation loans
sold. Among the 20 FICUs with the
highest amount of outstanding
participation loans, 16 are FISCUs. The
June 30 data also indicates that FISCUs
continue to have a higher delinquency
rate in their loan participation
portfolios, 3.97 percent compared to
3.59 percent for all FICUs and 3.09
percent for FCUs. Of the 123 credit
unions reporting over 10 percent
delinquency on participation loans, 68,
or 56 percent, are FISCUs.
With regard to actual losses, chargeoff data for the last few years indicates
FISCUs have experienced a higher level
of losses in participation loans than
FCUs, with the FISCU charge-off ratio
steadily increasing from year to year.
For example, the 2008 FISCU net
charge-off ratio increased 71 percent
from 2007 with an average increase of
31 percent in both 2009 and 2010. As
of June 30, 2011, the year-to-year
average remained 31 percent. Over these
same periods, FCUs experienced an
average increase of 2 percent, with a 28
percent spike in 2009 and decreases in
net charge-offs for all other years. As of
June 30, 2011, annualized net charge
offs for FCUs show an annualized
decrease of 10 percent.
The Board notes that, despite the
indications of risk to the NCUSIF from
FISCUs’ loan participation activity,
FISCU involvement in loan
participations currently is subject only
to state law. State regulatory
requirements for loan participation
transactions may vary from NCUA
regulation and from state to state. The
Board believes certain requirements
should be consistent among all FICUs to
minimize systemic risk. Increasing
numbers and balances in loan
participation portfolios, among both
federal credit unions and FISCUs,
indicate such a regulatory approach is
warranted.
IV. Regulatory Procedures
a. Regulatory Flexibility Act
The Regulatory Flexibility Act
requires NCUA to prepare an analysis to
describe any significant economic
impact any regulation may have on a
substantial number of small entities. 5
U.S.C. 603(a). For purposes of this
analysis, NCUA considers credit unions
having under $10 million in assets small
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entities. Interpretive Ruling and Policy
Statement 03–2, 68 FR 31949 (May 29,
2003). As of June 30, 2011, of
approximately 7,200 federally insured
credit unions, approximately 2,700 had
less than $10 million in assets.
NCUA does not believe the proposed
rule, if adopted, would have a
significant impact on a substantial
number of small credit unions. Loan
participations are a means for
institutions to diversify risk and to
employ excess lending capacity.
Generally, smaller credit unions are not
actively involved in loan participation
transactions.
b. Paperwork Reduction Act
The Paperwork Reduction Act of 1995
(PRA) applies to rulemakings in which
an agency by rule creates a new
paperwork burden on regulated entities
or modifies an existing burden. 44
U.S.C. 3507(d); 5 CFR part 1320. For
purposes of the PRA, a paperwork
burden may take the form of either a
reporting or a recordkeeping
requirement, both referred to as
information collections.
The proposed rule contains an
information collection in the form of a
written policy requirement and a
transaction documentation requirement.
Any federally insured credit union
purchasing loan participations must
have a written loan participation policy.
In addition, before purchasing a loan
participation, it must enter into a
written loan participation agreement
that specifically identifies the subject
loan(s) and other material information.
As required by the PRA, NCUA is
submitting a copy of this proposed rule
to OMB for its review and approval.
Persons interested in submitting
comments with respect to the
information collection aspects of the
proposed IRPS should submit them to
OMB at the address noted below.
Based on NCUA’s experience, credit
unions generally maintain written loan
participation policies and enter into
written agreements when purchasing
loan participations. As such, they will
only need to modify their practices to
comply with the proposed rule. It is,
therefore, NCUA’s view that
maintaining a written loan participation
policy and executing written
participation purchase agreements are
not burdens created by this regulation.
Rather, they are usual and customary
operating practices of a prudent
financial institution. Based on the
current volume of federally insured
credit unions reporting loan
participation activity, NCUA estimates
approximately 2,000 federally insured
credit unions will need to modify a
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written loan participation policy. NCUA
further estimates it should take a credit
union an average of 4 hours to modify
its loan participation policy. The total
annual burden imposed is
approximately 8,000 hours. With regard
to executing a written loan participation
agreement, NCUA estimates the
regulation will cause no additional
burden.
NCUA considers comments by the
public on this proposed collection of
information in:
• Evaluating whether the proposed
collection of information is necessary
for the proper performance of the
functions of the NCUA, including
whether the information will have a
practical use;
• Evaluating the accuracy of the
NCUA’s estimate of the burden of the
proposed collection of information,
including the validity of the
methodology and assumptions used;
• Enhancing the quality, usefulness,
and clarity of the information to be
collected; and
• Minimizing the burden of collection
of information on those who are
required to respond, including through
the use of appropriate automated,
electronic, mechanical, or other
technological collection techniques or
other forms of information technology;
e.g., permitting electronic submission of
responses.
The Paperwork Reduction Act requires
OMB to make a decision concerning the
collection of information contained in
the proposed regulation between 30 and
60 days after publication of this
document in the Federal Register.
Therefore, a comment to OMB is best
assured of having its full effect if OMB
receives it within 30 days of
publication. This does not affect the
deadline for the public to comment to
NCUA on the proposed regulation.
Comments on the proposed
information collection requirements
should be sent to: Office of Information
and Regulatory Affairs, OMB, New
Executive Office Building, 725 17th
Street, NW., Washington, DC 20503;
Attention: NCUA Desk Officer, with a
copy to Mary Rupp, Secretary of the
Board, National Credit Union
Administration, 1775 Duke Street,
Alexandria, Virginia 22314–3428.
c. Executive Order 13132
Executive Order 13132 encourages
independent regulatory agencies to
consider the impact of their actions on
state and local interests. In adherence to
fundamental federalism principles,
NCUA, an independent regulatory
agency as defined in 44 U.S.C. 3502(5),
voluntarily complies with the Executive
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79551
Order. The proposed rule, if adopted,
will also apply to federally insured,
state-chartered credit unions. By law,
these institutions are already subject to
numerous provisions of NCUA’s rules,
based on the agency’s role as the insurer
of member share accounts and the
significant interest NCUA has in the
safety and soundness of their
operations. The proposed rule may have
an occasional direct effect on the states,
the relationship between the national
government and the states, or on the
distribution of power and
responsibilities among the various
levels of government. The proposed rule
may supersede provisions of state law,
regulation, or approvals. The proposed
rule could lead to conflicts between the
NCUA and state financial institution
regulators on occasion, so NCUA
requests comments on ways to
eliminate, or at least minimize, potential
conflicts in this area. Commenters may
wish to provide recommendations on
the potential use of delegated authority,
cooperative decision-making
responsibilities, certification processes
of federal standards, adoption of
comparable programs by states
requesting an exemption for their
regulated institutions, or other ways of
meeting the intent of the Executive
Order.
d. The Treasury and General
Government Appropriations Act, 1999—
Assessment of Federal Regulations and
Policies on Families
NCUA has determined that this
proposed rule would not affect family
well-being within the meaning of
section 654 of the Treasury and General
Government Appropriations Act, 1999,
Public Law 105–277, 112 Stat. 2681
(1998).
List of Subjects
12 CFR Part 701
Credit unions, Fair housing,
Individuals with disabilities, Insurance,
Marital status discrimination,
Mortgages, Religious discrimination,
Reporting and recordkeeping
requirements, Sex discrimination, Signs
and symbols, Surety bonds.
12 CFR Part 741
Credit, Credit unions, Reporting and
recordkeeping requirements, Share
insurance.
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By the National Credit Union
Administration Board, on December 15,
2011.
Mary F. Rupp,
Secretary of the Board.
For the reasons stated above, NCUA
proposes to amend 12 CFR parts 701
and 741 as follows:
PART 701—ORGANIZATION AND
OPERATIONS OF FEDERAL CREDIT
UNIONS
1. The authority for part 701
continues to read as follows:
Authority: 12 U.S.C. 1752(5), 1755, 1756,
1757, 1758, 1759, 1761a, 1761b, 1766, 1767,
1782, 1784, 1786, 1787, 1789. Section 701.6
is also authorized by 15 U.S.C. 3717. Section
701.31 is also authorized by 15 U.S.C. 1601
et seq.; 42 U.S.C. 1981 and 3601–3610.
Section 701.35 is also authorized by 42
U.S.C. 4311–4312.
2. Revise § 701.22 to read as follows:
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§ 701.22
Loan participations.
This section applies only to loan
participations as defined in paragraph
(a). It does not include the purchase of
an investment interest in a pool of
loans. This section establishes the
requirements a federally insured credit
union must satisfy in order to purchase
a participation in a loan. This section
applies only to a federally insured credit
union’s purchase of a loan participation
where the borrower is not a member of
that credit union. Generally, a federally
insured credit union’s purchase of all or
part of a loan made to one of its own
members, where no continuing
contractual obligation between the seller
and purchaser is contemplated, is
governed by section § 701.23 of this
chapter. Federally insured, statechartered credit unions must comply
with these loan participation
requirements as provided in § 741.225
of this chapter. This section does not
apply to corporate credit unions.
(a) For purposes of this section, the
following definitions apply:
Associated borrower means any
borrower with a shared ownership,
investment, or other pecuniary interest
in a business or commercial endeavor
with the borrower. This includes
guarantors, co-signors, major
stakeholders, owners, investors,
affiliates and other parties who have
influence on the management, control,
or operations of the borrower.
Credit union means any Federal or
State-chartered credit union.
Credit union organization means any
credit union service organization
meeting the requirements of part 712 of
this chapter. This term does not include
trade associations or membership
VerDate Mar<15>2010
19:15 Dec 21, 2011
Jkt 226001
organizations principally composed of
credit unions.
Eligible organizations means a credit
union, credit union organization, or
financial organization.
Financial organization means any
federally-chartered or federally insured
financial institution; and any state or
federal government agency and its
subdivisions.
Loan participation means a loan
where one or more eligible
organizations participate pursuant to a
written agreement with the originating
lender, and the written agreement
requires the originating lender’s
continuing participation throughout the
life of the loan.
Originating lender means the
participant with which the member
initially or originally contracts for a loan
and who, thereafter or concurrently
with the funding of the loan, sells
participations to other lenders.
(b) A credit union may purchase a
loan participation from an eligible
organization only if the loan is one the
credit union is empowered to grant and
the following conditions are satisfied:
(1) The purchase complies with all
regulations to the same extent as if the
credit union had originated the loan,
including, for example, the loans-toone-borrower rule in § 701.21(c)(5) of
this chapter for federal credit unions
and the member business loan rule in
part 723 of this chapter for all federally
insured credit unions;
(2) The credit union has executed a
written loan participation agreement
with the originating lender and the
agreement meets the minimum
requirements for a loan participation
agreement as described in this section;
(3) The originating lender retains at
least a 10 percent interest in the
outstanding balance of the loan through
the life of the loan;
(4) The borrower is a member of a
participating credit union before the
credit union purchases a loan
participation; and,
(5) The purchase complies with the
credit union’s written loan participation
policy, which, among its provisions,
must:
(i) Establish underwriting standards
for loan participations which, at a
minimum, meet the same underwriting
standards the credit union uses when it
originates a loan;
(ii) Establish a limit on the aggregate
amount of loan participations that may
be purchased from any one originating
lender, not to exceed 25 percent of the
credit union’s net worth;
(iii) Establish limits on the amount of
loan participations that may be
purchased by each loan type, not to
PO 00000
Frm 00005
Fmt 4702
Sfmt 4702
exceed a specified percentage of the
credit union’s net worth; and
(iv) Establish a limit on the aggregate
amount of loan participations that may
be purchased with respect to a single
borrower, or group of associated
borrowers, not to exceed 15 percent of
the credit union’s net worth, unless
granted a waiver by its Regional
Director.
(c) A loan participation agreement
must:
(1) Be properly executed;
(2) Be acted on by the credit union’s
board of directors or, if the board has so
delegated in its policy, a designated
committee or senior management
official(s);
(3) Be retained in the credit union’s
office; and
(4) Include provisions addressing the
following:
(i) Prior to purchase, the
identification, either directly in the
agreement or through a document which
is incorporated by reference into the
agreement, of the specific loan
participation(s) being purchased;
(ii) The percent of the loan
participation retained by the originating
lender throughout the life of the loan,
which must be at least 10 percent;
(iii) The location and custodian for
original loan documents;
(iv) Access to periodic financial and
other performance information about
the loan, the borrower, and the servicer
so participants can monitor the loan;
(v) Enumerated duties and
responsibilities of the originating
lender, servicer, and participants in
respect of servicing, default, foreclosure,
collection, and other matters involving
the ongoing administration of the loan;
and
(vi) Circumstances and conditions
under which participants may replace
the servicer.
3. Amend § 701.23 to add
introductory text before paragraph (a) as
follows:
§ 701.23 Purchase, sale, and pledge of
eligible obligations.
This section governs a federal credit
union’s purchase, sale, or pledge of all
or part of a loan to one of its own
members, where no continuing
contractual obligation between the seller
and purchaser is contemplated. For
purchases of eligible obligations, the
borrower must be a member of the
purchasing federal credit union before
the purchase is made. A federal credit
union may not purchase a non-member
loan to hold in its portfolio.
*
*
*
*
*
E:\FR\FM\22DEP1.SGM
22DEP1
Federal Register / Vol. 76, No. 246 / Thursday, December 22, 2011 / Proposed Rules
PART 741—REQUIREMENTS FOR
INSURANCE
Subpart A—Regulations That Apply to
Both Federal Credit Unions and
Federally Insured State-Chartered
Credit Unions and That Are Not
Codified Elsewhere in NCUA’s
Regulations
4. The authority citation for part 741
continues to read as follows:
Authority: 12 U.S.C. 1757, 1766(a), 1781–
1790, and 1790d; 31 U.S.C. 3717.
5. Add paragraph (b)(4) to § 741.8 to
read as follows:
§ 741.8 Purchase of assets and
assumption of liabilities.
*
*
*
*
*
(b) * * *
*
*
*
*
*
(4) Purchases of loan participations as
defined in and meeting the
requirements of § 701.22 of this chapter.
*
*
*
*
*
6. Add new § 741.225 to read as
follows:
§ 741.225
Loan participations.
Any credit union that is insured
pursuant to Title II of the Act must
adhere to the requirements stated in
§ 701.22 of this chapter with the
exception of § 701.22(b)(4).
[FR Doc. 2011–32719 Filed 12–21–11; 8:45 am]
BILLING CODE 7535–01–P
NATIONAL CREDIT UNION
ADMINISTRATION
12 CFR Part 741
Lisa
Henderson, Staff Attorney, Office of
General Counsel, at the address above or
telephone (703) 518–6540; or J. Owen
Cole, Jr., Director, Division of Capital
Markets, Office of Examination and
Insurance, at the address above or
telephone (703) 518–6620.
SUPPLEMENTARY INFORMATION:
FOR FURTHER INFORMATION CONTACT:
RIN 3133–AD96
Maintaining Access to Emergency
Liquidity
National Credit Union
Administration (NCUA).
ACTION: Advance notice of proposed
rulemaking with request for comment
(ANPR).
AGENCY:
The NCUA Board (Board)
requests public comment on the scope
and requirements of a regulation to
require federally insured credit unions
(FICUs) to have access to backup federal
liquidity sources for use in times of
financial emergency and distressed
economic circumstances. The Board
also seeks comment on how such a
regulation could be implemented to
maximize economic benefit while
minimizing regulatory burden on credit
unions.
DATES: Send your comments to reach us
on or before February 21, 2012. We may
jlentini on DSK4TPTVN1PROD with PROPOSALS
SUMMARY:
VerDate Mar<15>2010
19:15 Dec 21, 2011
not consider comments received after
the above date in making our decision
on the ANPR.
ADDRESSES: You may submit comments
by any one of the following methods
(Please send comments by one method
only):
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• Email: Address to
regcomments@ncua.gov. Include ‘‘[Your
name]—Comments on Advance Notice
of Proposed Rulemaking for Part 741,
Maintaining Access to Emergency
Liquidity’’ in the email subject line.
• Fax: (703) 518–6319. Use the
subject line described above for email.
• Mail: Address to Mary Rupp,
Secretary of the Board, National Credit
Union Administration, 1775 Duke
Street, Alexandria, Virginia 22314–
3428.
• Hand Delivery/Courier: Same as
mail address.
Public Inspection: You can view all
public comments on NCUA’s Web site
at https://www.ncua.gov/Legal/Regs/
Pages/PropRegs.aspx as submitted,
except for those we cannot post for
technical reasons. NCUA will not edit or
remove any identifying or contact
information from the public comments
submitted. You may inspect paper
copies of comments in NCUA’s law
library at 1775 Duke Street, Alexandria,
Virginia 22314, by appointment
weekdays between 9 a.m. and 3 p.m. To
make an appointment, call (703) 518–
6546 or send an email to
OGCMail@ncua.gov.
Jkt 226001
I. Background
II. General Discussion
III. Potential Regulatory Requirement
IV. Request for Comment
I. Background
a. Why may a rule be necessary?
The recent financial crisis and
lingering economic uncertainties require
NCUA and credit unions to closely
examine the adequacy of risk
management programs and practices in
FICUs, including liquidity. One of the
vital lessons learned from recent events
is that institutions, both financial and
otherwise, need to have an inviolable
liquidity backstop that is over and above
PO 00000
Frm 00006
Fmt 4702
Sfmt 4702
79553
primary sources of funding such as
tapping market sources of credit or
selling highly liquid assets. Absent a
reliable backstop, institutions can
suddenly be affected by unforeseen
systemic liquidity events that render
them incapable of funding normal daily
operations and facing a rapidly
accelerating risk of operational
disruption and even failure. With the
advent of corporate credit union
(corporate) system reforms resulting
from the crisis, the Board sees the
changing role of corporates as a major
impetus to revisit the manner in which
emergency liquidity for the credit union
system is maintained and accessed.
Currently, virtually all FICUs have
access to the Central Liquidity Facility
(CLF or facility) by belonging to a
corporate credit union that is in turn
part of the agent group headed by U.S.
Central Bridge Corporate Federal Credit
Union (USC Bridge).1 USC Bridge
temporarily holds CLF stock on behalf
of the whole agent group, but USC
Bridge will soon be winding down and
closing.2 In the absence of an alternative
arrangement, when USC Bridge redeems
the CLF stock as part of its closure
process, the majority of credit unions
that enjoyed access to CLF through this
agent relationship will no longer have
the CLF as a source of backup liquidity.
The corresponding reduction in the
CLF’s borrowing capacity would also
reduce the credit union system’s
capacity to address a systemic liquidity
event.
Based on June 30, 2011, Call Report
data, most FICUs have no emergency
liquidity source beyond indirect CLF
membership by virtue of being a
member of a corporate and USC Bridge
holding the CLF capital stock. Only 1.3
percent of FICUs have direct
membership in CLF, and only 4.5
percent of FICUs are set up to access the
Federal Reserve Discount Window
(Discount Window). While 14.6 percent
of FICUs report being members of a
Federal Home Loan Bank (FHLB), 27
percent do not hold any mortgage assets
and would be unlikely to be able to rely
upon the FHLB for wholesale funding or
liquidity needs. More troubling, over 90
percent of FICUs do not currently hold
any U.S. Treasury obligations. Shorter
1 NCUA established USC Bridge to provide an
orderly transition in resolving the failure of U.S.
Central Corporate Federal Credit Union, which had
historically held the CLF capital stock on behalf of
the majority of the credit union system.
2 The closure of USC Bridge and corresponding
redemption of CLF stock is expected to occur
sometime in 2012. Though member institutions did
contemplate creating a successor to USC Bridge, the
plans for a potential successor never included
holding the CLF stock and these plans are no longer
being pursued.
E:\FR\FM\22DEP1.SGM
22DEP1
Agencies
[Federal Register Volume 76, Number 246 (Thursday, December 22, 2011)]
[Proposed Rules]
[Pages 79548-79553]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-32719]
========================================================================
Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
========================================================================
Federal Register / Vol. 76, No. 246 / Thursday, December 22, 2011 /
Proposed Rules
[[Page 79548]]
NATIONAL CREDIT UNION ADMINISTRATION
12 CFR Parts 701 and 741
RIN 3133-AE00
Loan Participations; Purchase, Sale and Pledge of Eligible
Obligations; Purchase of Assets and Assumption of Liabilities
AGENCY: National Credit Union Administration (NCUA).
ACTION: Proposed rule with request for comments.
-----------------------------------------------------------------------
SUMMARY: The NCUA Board (Board) requests public comment on its proposal
to amend its loan participation regulation and relevant provisions in
the eligible obligations rule and the rule governing the purchase of
assets and assumption of liabilities. NCUA has received many questions
about the loan participation rule, indicating confusion about its
application and its relationship to these other rules. The proposed
rule reorganizes the current rule and directs its regulatory provisions
to the purchase of a loan participation. It aims to improve
understanding of the transactions covered under the rule, as well as
the requirements for purchase and ongoing monitoring and the
applicability of related provisions. The proposed rule also expands
loan participation requirements to federally insured, state-chartered
credit unions (FISCUs).
DATES: Send your comments to reach us on or before February 21, 2012.
We may not consider comments received after the above date in making
our decision on the proposed rule.
ADDRESSES: You may submit comments by any of the following methods
(Please send comments by one method only):
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
Email: Address to regcomments@ncua.gov. Include ``[Your
name] Comments on ``Proposed Rule on Loan Participations'' in the email
subject line.
Fax: (703) 518-6319. Use the subject line described above
for email.
Mail: Address to Mary Rupp, Secretary of the Board,
National Credit Union Administration, 1775 Duke Street, Alexandria,
Virginia 22314-3428.
Hand Delivery/Courier: Same as mail address.
Public Inspection: You can view all public comments on
NCUA's Web site at https://www.ncua.gov/Resources/RegulationsOpinionsLaws/ProposedRegulations.aspx as submitted, except
for those we cannot post for technical reasons. NCUA will not edit or
remove any identifying or contact information from the public comments
submitted. You may inspect paper copies of comments in NCUA's law
library at 1775 Duke Street, Alexandria, Virginia 22314, by appointment
weekdays between 9 a.m. and 3 p.m. To make an appointment, call (703)
518-6546 or send an email to OGCMail@ncua.gov.
FOR FURTHER INFORMATION CONTACT: Linda Dent, Staff Attorney, Office of
General Counsel, (703) 518-6540; Vincent Vieten, Member Business Loan
Program Officer, Office of Examination and Insurance, (703) 518-6618.
SUPPLEMENTARY INFORMATION:
I. Background
II. The Rule as Proposed
III. Section-by-Section Analysis
IV. Regulatory Procedures
I. Background 1
---------------------------------------------------------------------------
\1\ President Obama signed the Plain Writing Act of 2010 (Pub.
L. 111-274) into law on October 13, 2010 ``to improve the
effectiveness and accountability of federal agencies to the public
by promoting clear Government communication that the public can
understand and use.'' This preamble is written to meet plain writing
objectives.
---------------------------------------------------------------------------
Why is NCUA proposing this rule?
The Board believes that involvement in loan participations
strengthens the credit union industry. Loan participations are a useful
way for federally insured credit unions to diversify their loan
portfolios, improve earnings, generate loan growth and manage their
balance sheets and comply with regulatory requirements. Credit unions
also use excess liquidity through the sale of participations to
increase the availability of credit to small businesses and consumers.
The Board recognizes, however, that loan participations also create
more systemic risk to the share insurance fund (NCUSIF) due to the
resulting interconnection between participants. For example, large
volumes of participated loans in the system tied to a single
originator, borrower, or industry or serviced by a single entity have
the potential to impact multiple credit unions if a problem arises.
Additionally, as both federal credit unions (FCUs) and federally
insured state-chartered credit unions (FISCUs) actively engage in loan
participations, it is important to the safety and soundness of the
NCUSIF that all federally insured credit unions (FICUs) adhere to the
same minimum standards for engaging in loan participations. The Board
believes such standards are necessary to ensure the NCUSIF consistently
recognizes and accounts for the risks associated with the purchase of
loan participations. Finally, during examinations and other FICU
contacts, the agency has encountered confusion concerning the
application of the current loan participation rule regarding the
entities and transactions subject to the rule. For these reasons, NCUA
proposes to amend Sec. 701.22, as well as relevant provisions in Sec.
701.23 and Sec. 741.8. Interpretive Ruling and Policy Statement (IRPS)
87-2, Developing and Reviewing Government Regulations, 52 FR 35231
(Sept. 18, 1987), as amended by IRPS 03-2, 68 FR 31949 (May 29, 2003).
II. The Rule as Proposed
a. How would the proposed rule change the loan participation rule?
NCUA proposes to change the rule to address only the requirements
for a FICU purchasing a loan participation. The proposed rule also
would better detail regulatory expectations regarding key aspects of a
loan participation purchase: the loan participation policy, the loan
participation agreement, and ongoing monitoring of the loan
participation.
b. Does this rule create greater restrictions than the current rule?
Yes, the proposed rule prescribes certain concentration limits and
encourages a FICU to establish others. The proposed rule also requires
that a loan participation agreement include certain provisions to
assist the purchasing FICU in conducting its due
[[Page 79549]]
diligence. The Board is proposing these actions to ensure that loan
participation activity is conducted in a safe and sound manner.
III. Section-by-Section Analysis
a. Sec. 701.22--Introductory Text
The Board believes the addition of introductory text to the rule
clarifies the scope of the rule and helps distinguish a participation
loan from an eligible obligation under Sec. 701.23. As proposed, the
introductory text clarifies that the rule applies to a natural person
federal credit union's purchase of a loan participation where the
borrower is not a member of that credit union. An FCU's purchase of its
member's loan, in whole or in part, is covered by NCUA's eligible
obligations rule at Sec. 701.23. Additionally, by a cross-reference to
Part 741, the Board proposes to apply the rule to natural person
FISCUs. Corporate credit unions are subject to the loan participation
requirements set forth in Part 704 and, therefore, are not subject to
Sec. 701.22.
b. Sec. 701.22(a)--Definitions
The Board proposes to revise the definitions for ``originating
lender'' and ``participation loan'' to clarify that the originating
lender must participate in the loan throughout the life of the loan.
The Board also proposes to add a definition of associated borrower. The
proposed definition is self-explanatory and is used in the provision on
concentration limits in Sec. 701.22(b) below. Additionally, the Board
proposes to change the paragraph's format by listing the definitions in
alphabetical order and removing the numeric designations. These changes
are consistent with the format recommended by the Federal Register.
c. Sec. 701.22(b)--Requirements for Loan Participation Purchases
The Board proposes to revise this paragraph by reorganizing and
revising the requirements for a loan participation included in
paragraphs (b), (c) and (d) of the current rule. In the proposed rule,
information from these paragraphs is organized into a revised paragraph
(b), with specific details added to improve clarity and to address
safety and soundness concerns.
Revised paragraph (b) provides that a FICU may only purchase a loan
participation if the seller is an eligible organization and if the loan
is one the FICU is empowered to grant under regulation and its loan
policies. Empowered to grant means a FICU's authority to make the type
of loan permitted by the Federal Credit Union Act or applicable state
law, NCUA regulations, and its bylaws and own internal policies.
Accordingly, the Board proposes to remove the current exception in
Sec. 701.22(c)(4), which permits an FCU to purchase a loan
participation that was originated with different underwriting standards
than its own. Removing this provision prevents a FICU from purchasing a
loan participation originated with less stringent underwriting
standards than the FICU uses in making its own loans. The proposed
rule, however, does not prevent a FICU from purchasing a loan
participation with more stringent underwriting standards than it uses
in originating its own loans.
Other requirements for purchasing a loan participation include a
written loan participation agreement, a continuing participation
interest by the originating lender of at least 10 percent for the
loan's duration, and the borrower's membership in a participating FICU
before the purchase occurs. While the proposed rule continues to
require a written loan participation policy, the Board proposes to
require specific provisions to include in such policy. For example,
provisions would be added to the rule addressing the maximum limit on
loan participations outstanding and various concentration limits. The
Board recognizes there may be other factors based on a credit union's
size, complexity of operations, and lending experience that should be
considered in formulating a loan participation policy. The Board
expects a FICU to consider these factors in establishing its policy.
For example, a FICU purchasing a loan participation pool might perform
statistical sampling in evaluating the underwriting standards of the
pool. Conversely, a large purchase representing a significant portion
of the FICU's net worth should require a full review of the loan
documentation before approval. The Board expects a FICU to establish
the parameters for review, including a periodic review for
appropriateness, and adhere to such parameters.
1. Concentration Limits on Loan Participations
In establishing appropriate concentration limits for loan
participations, the Board is seeking to mitigate risk without
discouraging continued growth. The Board proposes to use net worth,
rather than unimpaired capital and surplus, as the means for striking
this balance. Net worth cushions fluctuations in earnings, supports
growth, and provides protection against insolvency. As such, the Board
believes establishing limits tied to this measure is appropriate.
The Board also recognizes the need for FICUs to identify and manage
various concentrations on their balance sheet. Key among these are
concentrations involving the same originator, one borrower or a group
of associated borrowers, and types of loans, for example, by industry
or loan product. The Board proposes to limit loan participation
purchases involving a single originator to a maximum of 25 percent of a
FICU's net worth. No waiver provision is proposed for the 25 percent
limitation. It also proposes to limit loan participation purchases
involving one borrower or a group of associated borrowers to 15 percent
of a FICU's net worth, unless the appropriate regional director grants
a waiver. These limits consider that a FICU purchasing a loan
participation generally does not directly manage the risks associated
with the loan relationship, including borrower contact and collection
control. The 15 percent limitation is consistent with the 15 percent
limitation on member business loans to one member or group of
associated members set forth in Sec. 723.8 of the member business loan
rule. Part 723 allows members to apply for a waiver from the 15 percent
limitation (as well as other regulatory limitations). Waiver procedures
are set forth in Sec. 723.11. It has come to NCUA's attention that
many credit unions believe the waiver process in Part 723 is not
working efficiently and is often not a viable, practical option. NCUA
seeks comment as to how the waiver process in this regulation can be
structured to satisfy credit unions' practical concerns while ensuring
prudent loan participation practices.
The Board expects to grandfather credit unions that exceed the 25
percent and 15 percent concentration limits at the percentage rates of
concentration on the effective date of a final rule. The grandfathered
rates will diminish down to the approved regulatory rates set as
participations are paid off or sold. The Board is not establishing
specific limits for other concentrations identified within a FICU's
loan participation policy. It is important, however, for a FICU to
identify such concentrations and apply a reasonable, supportable
concentration limit. Consistent with agency guidance on the evaluation
of concentration risk, concentration limits must be established
commensurate with net worth levels.\2\
---------------------------------------------------------------------------
\2\ Letter to Credit Unions 10-CU-03 (Mar. 2010).
---------------------------------------------------------------------------
The Board is particularly interested in receiving comments on how
these caps should be structured, the
[[Page 79550]]
appropriateness of these caps, and suggested alternative approaches to
mitigating the inherent risks of loan participations.
d. Sec. 701.22(c)--Minimum Requirements for a Loan Participation
Agreement
The proposed rule revises current Sec. 701.22(b)(2), which
requires loan participation agreements to be in writing, and moves
requirements for the agreement to revised paragraph Sec. 701.22(c).
The Board recognizes that a successful participated loan relationship
depends, in large part, on the quality and completeness of the
participation agreement. A well-written agreement can minimize inter-
creditor conflicts during the life of the loan, especially if the loan
becomes delinquent and needs to be worked out. The Board also believes
that any participation agreement must clearly delineate the roles,
duties, and obligations of the originating lender, servicer, and
participants.
As proposed, revised paragraph (c) establishes minimum provisions
that any loan participation agreement must address. For example, the
loan participation agreement must include a provision requiring the
originating lender to retain at least a ten percent interest in the
loan throughout its duration. This requirement mirrors the current
statutory requirement for FCUs. Other provisions require the agreement
to identify each participated loan, enumerate servicing
responsibilities for the loan, and include notice and disclosure
requirements regarding the ongoing financial condition of the loan, the
borrower, and the servicer.
The Board is proposing these minimum provisions to emphasize the
need for adequate documentation and due diligence from the time of
purchase throughout the life of the participation. Additionally, under
proposed Sec. 701.22(c)(1), a loan participation agreement must
specify the loan or loans in which a credit union is purchasing an
interest. Where a participation agreement involves multiple loans, the
documentation, for example, can be as simple as an addendum or schedule
for identifying each loan and a participant's interest in that loan.
This provision clarifies the existing prohibition against an FCU
purchasing a participation certificate in a pool of loans.
e. Sec. 701.22(d)--Remove and Reserve
The Board proposes to address the contents of this paragraph in
other portions of the rule.
f. Related Regulatory Provisions
1. Sec. 701.23--Purchase, Sale, and Pledge of Eligible Obligations
The Board proposes to add introductory text to this section to
clarify the rule's scope and to distinguish it from transactions
covered by Sec. 701.22.
2. Sec. 741.8--Purchase of Assets and Assumption of Liabilities
Section 741.8 is a safety and soundness provision requiring
supervisory approval before a federally insured credit union may
purchase a loan from an entity that is not insured by the NCUSIF. No
approval is necessary, however, for the following transactions:
An FCU's purchase of student loans or real estate secured
loans pursuant to Sec. 701.23(b)(iii) or (iv);
An FCU's purchase of its member loans pursuant to Sec.
701.23(b)(i); or
A FISCU's purchase of its member loans under state law
comparable to the provisions in Sec. 701.23.
Currently, there are no exclusions under Sec. 741.8 for loan
participation purchases. In practice, however, as long as an FCU's
purchase complies with Sec. 701.22 requirements the FCU is not
required to obtain separate regional director approval for the
transaction. The Board proposes to add language to Sec. 741.8 to
specifically state that Regional Director approval is not required for
a loan participation purchase that complies with Sec. 701.22
requirements. The exclusion would apply to both FCUs and FISCUs.
3. Sec. 741.225--Loan Participations
Section 201 of the Federal Credit Union Act states the Board is
authorized to insure the member accounts of state-chartered credit
unions that have applied to, and been approved by, NCUA for federal
insurance coverage. Credit unions receiving federal insurance must
agree to comply with the requirements of Title II and any regulations
prescribed by the Board pursuant to this title. Pursuant to this
authority, the Board proposes to amend Part 741 by adding a new Sec.
741.225 to extend the participation rule's coverage to federally
insured, state-chartered credit unions. Since 2007, FISCU-participated
loan balances have increased 27 percent, from $5.7 billion in 2007 to
$7.2 billion in 2010 and have consistently accounted for the majority
of outstanding loan participations. Similarly, since 2007, FISCUs-
overall experienced a higher delinquency rate in their loan
participation portfolios. At year-end 2010, the delinquency rate for
the FISCU-participated portfolio was 4.11 percent, compared to 3.74
percent for all FICUs.
Based on June 30, 2011, Call Report data, FISCUs hold 56 percent of
outstanding loan participations and are responsible for approximately
55 percent of participation loans purchased and 68 percent of
participation loans sold. Among the 20 FICUs with the highest amount of
outstanding participation loans, 16 are FISCUs. The June 30 data also
indicates that FISCUs continue to have a higher delinquency rate in
their loan participation portfolios, 3.97 percent compared to 3.59
percent for all FICUs and 3.09 percent for FCUs. Of the 123 credit
unions reporting over 10 percent delinquency on participation loans,
68, or 56 percent, are FISCUs.
With regard to actual losses, charge-off data for the last few
years indicates FISCUs have experienced a higher level of losses in
participation loans than FCUs, with the FISCU charge-off ratio steadily
increasing from year to year. For example, the 2008 FISCU net charge-
off ratio increased 71 percent from 2007 with an average increase of 31
percent in both 2009 and 2010. As of June 30, 2011, the year-to-year
average remained 31 percent. Over these same periods, FCUs experienced
an average increase of 2 percent, with a 28 percent spike in 2009 and
decreases in net charge-offs for all other years. As of June 30, 2011,
annualized net charge offs for FCUs show an annualized decrease of 10
percent.
The Board notes that, despite the indications of risk to the NCUSIF
from FISCUs' loan participation activity, FISCU involvement in loan
participations currently is subject only to state law. State regulatory
requirements for loan participation transactions may vary from NCUA
regulation and from state to state. The Board believes certain
requirements should be consistent among all FICUs to minimize systemic
risk. Increasing numbers and balances in loan participation portfolios,
among both federal credit unions and FISCUs, indicate such a regulatory
approach is warranted.
IV. Regulatory Procedures
a. Regulatory Flexibility Act
The Regulatory Flexibility Act requires NCUA to prepare an analysis
to describe any significant economic impact any regulation may have on
a substantial number of small entities. 5 U.S.C. 603(a). For purposes
of this analysis, NCUA considers credit unions having under $10 million
in assets small
[[Page 79551]]
entities. Interpretive Ruling and Policy Statement 03-2, 68 FR 31949
(May 29, 2003). As of June 30, 2011, of approximately 7,200 federally
insured credit unions, approximately 2,700 had less than $10 million in
assets.
NCUA does not believe the proposed rule, if adopted, would have a
significant impact on a substantial number of small credit unions. Loan
participations are a means for institutions to diversify risk and to
employ excess lending capacity. Generally, smaller credit unions are
not actively involved in loan participation transactions.
b. Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (PRA) applies to rulemakings in
which an agency by rule creates a new paperwork burden on regulated
entities or modifies an existing burden. 44 U.S.C. 3507(d); 5 CFR part
1320. For purposes of the PRA, a paperwork burden may take the form of
either a reporting or a recordkeeping requirement, both referred to as
information collections.
The proposed rule contains an information collection in the form of
a written policy requirement and a transaction documentation
requirement. Any federally insured credit union purchasing loan
participations must have a written loan participation policy. In
addition, before purchasing a loan participation, it must enter into a
written loan participation agreement that specifically identifies the
subject loan(s) and other material information. As required by the PRA,
NCUA is submitting a copy of this proposed rule to OMB for its review
and approval. Persons interested in submitting comments with respect to
the information collection aspects of the proposed IRPS should submit
them to OMB at the address noted below.
Based on NCUA's experience, credit unions generally maintain
written loan participation policies and enter into written agreements
when purchasing loan participations. As such, they will only need to
modify their practices to comply with the proposed rule. It is,
therefore, NCUA's view that maintaining a written loan participation
policy and executing written participation purchase agreements are not
burdens created by this regulation. Rather, they are usual and
customary operating practices of a prudent financial institution. Based
on the current volume of federally insured credit unions reporting loan
participation activity, NCUA estimates approximately 2,000 federally
insured credit unions will need to modify a written loan participation
policy. NCUA further estimates it should take a credit union an average
of 4 hours to modify its loan participation policy. The total annual
burden imposed is approximately 8,000 hours. With regard to executing a
written loan participation agreement, NCUA estimates the regulation
will cause no additional burden.
NCUA considers comments by the public on this proposed collection
of information in:
Evaluating whether the proposed collection of information
is necessary for the proper performance of the functions of the NCUA,
including whether the information will have a practical use;
Evaluating the accuracy of the NCUA's estimate of the
burden of the proposed collection of information, including the
validity of the methodology and assumptions used;
Enhancing the quality, usefulness, and clarity of the
information to be collected; and
Minimizing the burden of collection of information on
those who are required to respond, including through the use of
appropriate automated, electronic, mechanical, or other technological
collection techniques or other forms of information technology; e.g.,
permitting electronic submission of responses.
The Paperwork Reduction Act requires OMB to make a decision concerning
the collection of information contained in the proposed regulation
between 30 and 60 days after publication of this document in the
Federal Register. Therefore, a comment to OMB is best assured of having
its full effect if OMB receives it within 30 days of publication. This
does not affect the deadline for the public to comment to NCUA on the
proposed regulation.
Comments on the proposed information collection requirements should
be sent to: Office of Information and Regulatory Affairs, OMB, New
Executive Office Building, 725 17th Street, NW., Washington, DC 20503;
Attention: NCUA Desk Officer, with a copy to Mary Rupp, Secretary of
the Board, National Credit Union Administration, 1775 Duke Street,
Alexandria, Virginia 22314-3428.
c. Executive Order 13132
Executive Order 13132 encourages independent regulatory agencies to
consider the impact of their actions on state and local interests. In
adherence to fundamental federalism principles, NCUA, an independent
regulatory agency as defined in 44 U.S.C. 3502(5), voluntarily complies
with the Executive Order. The proposed rule, if adopted, will also
apply to federally insured, state-chartered credit unions. By law,
these institutions are already subject to numerous provisions of NCUA's
rules, based on the agency's role as the insurer of member share
accounts and the significant interest NCUA has in the safety and
soundness of their operations. The proposed rule may have an occasional
direct effect on the states, the relationship between the national
government and the states, or on the distribution of power and
responsibilities among the various levels of government. The proposed
rule may supersede provisions of state law, regulation, or approvals.
The proposed rule could lead to conflicts between the NCUA and state
financial institution regulators on occasion, so NCUA requests comments
on ways to eliminate, or at least minimize, potential conflicts in this
area. Commenters may wish to provide recommendations on the potential
use of delegated authority, cooperative decision-making
responsibilities, certification processes of federal standards,
adoption of comparable programs by states requesting an exemption for
their regulated institutions, or other ways of meeting the intent of
the Executive Order.
d. The Treasury and General Government Appropriations Act, 1999--
Assessment of Federal Regulations and Policies on Families
NCUA has determined that this proposed rule would not affect family
well-being within the meaning of section 654 of the Treasury and
General Government Appropriations Act, 1999, Public Law 105-277, 112
Stat. 2681 (1998).
List of Subjects
12 CFR Part 701
Credit unions, Fair housing, Individuals with disabilities,
Insurance, Marital status discrimination, Mortgages, Religious
discrimination, Reporting and recordkeeping requirements, Sex
discrimination, Signs and symbols, Surety bonds.
12 CFR Part 741
Credit, Credit unions, Reporting and recordkeeping requirements,
Share insurance.
[[Page 79552]]
By the National Credit Union Administration Board, on December
15, 2011.
Mary F. Rupp,
Secretary of the Board.
For the reasons stated above, NCUA proposes to amend 12 CFR parts
701 and 741 as follows:
PART 701--ORGANIZATION AND OPERATIONS OF FEDERAL CREDIT UNIONS
1. The authority for part 701 continues to read as follows:
Authority: 12 U.S.C. 1752(5), 1755, 1756, 1757, 1758, 1759,
1761a, 1761b, 1766, 1767, 1782, 1784, 1786, 1787, 1789. Section
701.6 is also authorized by 15 U.S.C. 3717. Section 701.31 is also
authorized by 15 U.S.C. 1601 et seq.; 42 U.S.C. 1981 and 3601-3610.
Section 701.35 is also authorized by 42 U.S.C. 4311-4312.
2. Revise Sec. 701.22 to read as follows:
Sec. 701.22 Loan participations.
This section applies only to loan participations as defined in
paragraph (a). It does not include the purchase of an investment
interest in a pool of loans. This section establishes the requirements
a federally insured credit union must satisfy in order to purchase a
participation in a loan. This section applies only to a federally
insured credit union's purchase of a loan participation where the
borrower is not a member of that credit union. Generally, a federally
insured credit union's purchase of all or part of a loan made to one of
its own members, where no continuing contractual obligation between the
seller and purchaser is contemplated, is governed by section Sec.
701.23 of this chapter. Federally insured, state-chartered credit
unions must comply with these loan participation requirements as
provided in Sec. 741.225 of this chapter. This section does not apply
to corporate credit unions.
(a) For purposes of this section, the following definitions apply:
Associated borrower means any borrower with a shared ownership,
investment, or other pecuniary interest in a business or commercial
endeavor with the borrower. This includes guarantors, co-signors, major
stakeholders, owners, investors, affiliates and other parties who have
influence on the management, control, or operations of the borrower.
Credit union means any Federal or State-chartered credit union.
Credit union organization means any credit union service
organization meeting the requirements of part 712 of this chapter. This
term does not include trade associations or membership organizations
principally composed of credit unions.
Eligible organizations means a credit union, credit union
organization, or financial organization.
Financial organization means any federally-chartered or federally
insured financial institution; and any state or federal government
agency and its subdivisions.
Loan participation means a loan where one or more eligible
organizations participate pursuant to a written agreement with the
originating lender, and the written agreement requires the originating
lender's continuing participation throughout the life of the loan.
Originating lender means the participant with which the member
initially or originally contracts for a loan and who, thereafter or
concurrently with the funding of the loan, sells participations to
other lenders.
(b) A credit union may purchase a loan participation from an
eligible organization only if the loan is one the credit union is
empowered to grant and the following conditions are satisfied:
(1) The purchase complies with all regulations to the same extent
as if the credit union had originated the loan, including, for example,
the loans-to-one-borrower rule in Sec. 701.21(c)(5) of this chapter
for federal credit unions and the member business loan rule in part 723
of this chapter for all federally insured credit unions;
(2) The credit union has executed a written loan participation
agreement with the originating lender and the agreement meets the
minimum requirements for a loan participation agreement as described in
this section;
(3) The originating lender retains at least a 10 percent interest
in the outstanding balance of the loan through the life of the loan;
(4) The borrower is a member of a participating credit union before
the credit union purchases a loan participation; and,
(5) The purchase complies with the credit union's written loan
participation policy, which, among its provisions, must:
(i) Establish underwriting standards for loan participations which,
at a minimum, meet the same underwriting standards the credit union
uses when it originates a loan;
(ii) Establish a limit on the aggregate amount of loan
participations that may be purchased from any one originating lender,
not to exceed 25 percent of the credit union's net worth;
(iii) Establish limits on the amount of loan participations that
may be purchased by each loan type, not to exceed a specified
percentage of the credit union's net worth; and
(iv) Establish a limit on the aggregate amount of loan
participations that may be purchased with respect to a single borrower,
or group of associated borrowers, not to exceed 15 percent of the
credit union's net worth, unless granted a waiver by its Regional
Director.
(c) A loan participation agreement must:
(1) Be properly executed;
(2) Be acted on by the credit union's board of directors or, if the
board has so delegated in its policy, a designated committee or senior
management official(s);
(3) Be retained in the credit union's office; and
(4) Include provisions addressing the following:
(i) Prior to purchase, the identification, either directly in the
agreement or through a document which is incorporated by reference into
the agreement, of the specific loan participation(s) being purchased;
(ii) The percent of the loan participation retained by the
originating lender throughout the life of the loan, which must be at
least 10 percent;
(iii) The location and custodian for original loan documents;
(iv) Access to periodic financial and other performance information
about the loan, the borrower, and the servicer so participants can
monitor the loan;
(v) Enumerated duties and responsibilities of the originating
lender, servicer, and participants in respect of servicing, default,
foreclosure, collection, and other matters involving the ongoing
administration of the loan; and
(vi) Circumstances and conditions under which participants may
replace the servicer.
3. Amend Sec. 701.23 to add introductory text before paragraph (a)
as follows:
Sec. 701.23 Purchase, sale, and pledge of eligible obligations.
This section governs a federal credit union's purchase, sale, or
pledge of all or part of a loan to one of its own members, where no
continuing contractual obligation between the seller and purchaser is
contemplated. For purchases of eligible obligations, the borrower must
be a member of the purchasing federal credit union before the purchase
is made. A federal credit union may not purchase a non-member loan to
hold in its portfolio.
* * * * *
[[Page 79553]]
PART 741--REQUIREMENTS FOR INSURANCE
Subpart A--Regulations That Apply to Both Federal Credit Unions and
Federally Insured State-Chartered Credit Unions and That Are Not
Codified Elsewhere in NCUA's Regulations
4. The authority citation for part 741 continues to read as
follows:
Authority: 12 U.S.C. 1757, 1766(a), 1781-1790, and 1790d; 31
U.S.C. 3717.
5. Add paragraph (b)(4) to Sec. 741.8 to read as follows:
Sec. 741.8 Purchase of assets and assumption of liabilities.
* * * * *
(b) * * *
* * * * *
(4) Purchases of loan participations as defined in and meeting the
requirements of Sec. 701.22 of this chapter.
* * * * *
6. Add new Sec. 741.225 to read as follows:
Sec. 741.225 Loan participations.
Any credit union that is insured pursuant to Title II of the Act
must adhere to the requirements stated in Sec. 701.22 of this chapter
with the exception of Sec. 701.22(b)(4).
[FR Doc. 2011-32719 Filed 12-21-11; 8:45 am]
BILLING CODE 7535-01-P