The NCUA Staff Draft 2020-2021 Budget Justification, 59126-59192 [2019-23856]
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Federal Register / Vol. 84, No. 212 / Friday, November 1, 2019 / Notices
NATIONAL CREDIT UNION
ADMINISTRATION
The NCUA Staff Draft 2020—2021
Budget Justification
National Credit Union
Administration (NCUA).
ACTION: Notice.
AGENCY:
The NCUA’s draft, ‘‘detailed
business-type budget’’ is being made
available for public review as required
by federal statute. The proposed
resources will finance the agency’s
annual operations and capital projects,
both of which are necessary for the
agency to accomplish its mission. The
briefing schedule and comment
instructions are included in the
supplementary information section.
DATES: Requests to deliver a statement at
the budget briefing must be received on
or before Tuesday, November 12, 2019.
In order for the NCUA to produce copies
for public distribution at the budget
briefing, written statements and
presentations for those scheduled to
appear at the budget briefing must be
received on or before Monday,
November 18, 2019.
Written comments without public
presentation at the budget briefing may
be submitted by Monday, December 2,
2019.
ADDRESSES: You may submit comments
by any of the following methods (Please
send comments by one method only):
• Presentation at public budget
briefing: submit requests to deliver a
statement at the briefing to
BudgetBriefing@ncua.gov by Tuesday,
November 12, 2019. Include your name,
title, affiliation, mailing address, email
address, and telephone number. Copies
of your presentation must be submitted
to the same email address by Monday,
November 18, 2019.
• Written comments: submit
comments to BudgetComments@
ncua.gov by Monday, December 2, 2019.
Include your name and the following
subject line ‘‘Comments on the NCUA
Draft 2020–2021 Budget Justification.’’
Copies of the NCUA Draft 2020–2021
Budget Justification and associated
materials are also available on the
NCUA website at https://www.ncua.gov/
SUMMARY:
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About/Pages/budget-strategic-planning/
supplementary-materials.aspx. Printed
copies will be available at the November
20, 2019 budget briefing.
FOR FURTHER INFORMATION CONTACT:
Rendell Jones, Chief Financial Officer,
National Credit Union Administration,
1775 Duke Street, Alexandria, Virginia
22314–3428 or telephone: (703) 518–
6571.
SUPPLEMENTARY INFORMATION: The
following itemized list details the
documents attached to this notice and
made available for public review:
I. The NCUA Budget in Brief
II. Introduction and Strategic Context
III. Forecast and Enterprise Challenges
IV. Key Themes of the 2020–2021 Budget
V. Operating Budget
VI. Capital Budget
VII. Share Insurance Fund Administrative
Budget
VIII. Financing The NCUA Programs
IX. Appendix A: Supplemental Budget
Information
X: Appendix B: Capital Projects
Section 212 of the Economic Growth,
Regulatory Relief, and Consumer
Protection Act (Pub. L. 115–174)
amended 12 U.S.C. 1789(b)(1)(A) to
require the NCUA Board (Board) to
‘‘make publicly available and publish in
the Federal Register a draft of the
detailed business-type budget.’’
Although 12 U.S.C. 1789(b)(1)(A)
requires publication of a ‘‘business-type
budget’’ only for the agency operations
arising under the Federal Credit Union
Act’s subchapter on insurance activities,
in the interest of transparency the Board
is providing the agency’s entire staff
draft 2020–2021 Budget Justification
(budget) in this Notice.
The draft budget details the resources
required to support NCUA’s mission as
outlined in its 2018–2022 Strategic Plan.
The draft budget includes personnel and
dollar estimates for three major budget
components: (1) The Operating Budget;
(2) the Capital Budget; and (3) the Share
Insurance Fund Administrative Budget.
The resources proposed in the draft
budget will be used to carry out the
agency’s annual operations.
The NCUA staff will present its draft
budget to the Board at a budget briefing
open to the public and scheduled for
Wednesday, November 20, 2019 from
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10:00 a.m. to 12:00 p.m. Eastern. The
budget briefing will be held in the
NCUA Board meeting room. A
livestream of the briefing also will be
available through a link on ncua.gov.
If you wish to attend the briefing and
deliver a statement, you must email a
request to BudgetBriefing@ncua.gov by
Tuesday, November 12, 2019. Your
request must include your name, title,
affiliation, mailing address, email
address, and telephone number. The
NCUA will work to accommodate as
many public statements as possible at
the November 20, 2019 budget briefing.
The Board Secretary will inform you if
you have been approved to make a
presentation and how much time you
will be allotted. A written copy of your
presentation must be delivered to the
Board Secretary via email at
BudgetBriefing@ncua.gov by Monday,
November 18, 2019.
Written comments on the draft budget
will also be accepted by email at
BudgetComments@ncua.gov until
Monday, December 2, 2019. Include
your name and the following subject
line with your comments: ‘‘Comments
on the NCUA Draft 2020–2021 Budget
Justification.’’
All comments should provide
specific, actionable recommendations
rather than general remarks. The Board
will review and consider any comments
from the public prior to approving the
budget.
By the National Credit Union
Administration Board on October 28, 2019.
Gerard S. Poliquin,
Secretary of the Board.
I. The NCUA Budget in Brief
Proposed 2020 and 2021 Budgets
The National Credit Union
Administration’s (NCUA) 2018–2022
Strategic Plan sets forth the agency’s
goals and objectives that form the basis
for determining resource needs and
allocations. The annual budget provides
the resources to execute the strategic
plan, to implement important
initiatives, and to undertake the NCUA’s
major programs: Examination and
supervision, insurance, credit union
development, consumer financial
protection, and asset management.
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to the increased cost of FERS
contributions and 2.3 percentage points
of growth are the result of changes in
agency operations.
The 2.3 percent growth in agency
operations also includes absorbing the
equivalent of 0.8 percentage points of
growth for costs avoided in the Share
Insurance Fund Administrative Budget.
This means the actual budget increase to
fund the agency’s operations is the
equivalent of 1.5 percent growth.
Personnel levels for 2020 and 2021
reflect the agency’s current staffing
requirements and proposed staffing
enhancements related to high-priority
initiatives.
1 The published 2019 FTE level approved by the
Board on November 15, 2018 was 1,173 for the
Operating Budget. On July 18, 2019, the NCUA
Board approved an additional four FTE. The revised
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Operating Budget
The proposed 2020 Operating Budget
is $316.2 million. Personnel levels
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increase by three full-time equivalents
(FTE) compared to the 2019 Boardapproved budget.1
The 2020 Operating Budget, when
adjusted for inflation, represents a real
dollar increase of approximately $5.2
million, or 1.7 percent, compared to the
2019 Board-approved budget. In
nominal dollars, the 2019 Budget
increases by $11.8 million, or 3.9
percent, over the 2019 Board-approved
budget of $304.4 million. The Operating
Budget estimate for 2021 is $326 million
and reflects no change to authorized
positions.
The following chart shows recent
year-on-year trends for the NCUA
Operating Budget, in both real dollar
and nominal terms:
2020 Operating Budget proposes three more FTE,
for a total of 1,180.
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The NCUA’s 2020–2021 budget
justification consists of three separate
budgets: The Operating Budget, the
Capital Budget, and the National Credit
Union Share Insurance Fund
Administrative Budget. Combined, these
three budgets total $347.7 million for
2020, which is 1.1 percent more than
the 2020 funding level approved by the
NCUA Board in November 2018, and 3.9
percent more than the comparable 2019
Board-approved budget.
A significant cost driver in the 2020
budget is the increase in mandatory
contributions all federal agencies must
make to the Office of Personnel
Management (OPM) for the Federal
Employee Retirement System (FERS). Of
the total 3.9 percent budget increase
between 2019 and 2020, 1.6 percentage
points of growth are directly attributable
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The following chart presents the
major categories of spending supported
by the 2020 budget, while specific
adjustments to the 2019 Board-approved
budget are discussed in further detail,
below:
Total Staffing. The budget supports
1,185 FTE in total for 2020, of which
five are funded by the Share Insurance
Fund Administrative Budget. The
Operating Budget funds 1,180 FTE in
2020, a net increase of three FTEs from
the 2019 levels approved by the Board.
Additional staff have been added to
several offices as discussed later in this
document. Since 2018 and despite
significant credit union asset growth,
total NCUA staffing has remained
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Pay and Benefits. Pay and benefits
increase by $8.5 million in 2020, or 3.8
percent, for a budget of $231.4 million.
Over 50 percent of the growth in pay
and benefits—nearly $5 million—is the
result of OPM increasing the mandatory
employer contribution for the FERS.
Required FERS payments to OPM
increase from 13.7 percent of covered
employees’ salaries to 16 percent, a
change of 230 basis points. Nearly all
NCUA employees are covered by FERS,
which includes a defined pension
benefit funded by both employee and
employer contributions. Because almost
every federal agency is required to
participate in FERS, the employer share
of contributions increases throughout
the government in 2020. Excluding
additional FERS contributions from the
2020 budget, total personnel
compensation growth would be 1.6
percent instead of 3.8 percent, and total
Operating Budget growth would be 2.2
percent instead of 3.9 percent.
The remaining increase in pay and
benefits accounts for the merit and
locality pay adjustments required by the
NCUA’s current collective bargaining
agreement, the three new positions
proposed for 2020, anticipated staff
promotions, position changes, and
increased costs for other mandatory
employer contributions such as health
insurance and retirement contributions.
Travel. The travel budget increases by
$590,000 in 2020, or 2.2 percent, for a
budget of $27.4 million. In 2020, the
NCUA plans to train its Credit Union
Examiner workforce to conduct
examinations using the Modern
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Examination and Risk Identification
Tool (MERIT) system, which is planned
for full implementation in the fourth
quarter of 2020. State credit union
examiners will also be trained to use
MERIT. The Operating Budget includes
approximately $1.0 million in one-time
travel costs associated with the 778
NCUA employees who will participate
in MERIT training meetings in 2020.
In general, the NCUA continues
working to contain the growth of travel
costs by expanding offsite examination
work and using technology-driven
training. Government-wide per diem
rates published by the General Services
Administration (GSA) are expected to
increase by almost 1.3 percent in 2020,
accounting for a share of the travel
budget growth. In addition, starting in
2019 GSA instituted a cost recovery fee
for airline tickets purchased at
negotiated government rates, which
adds approximately $20,000 annually to
the agency’s cost of purchasing airline
tickets at government rates.
Rent, Communications, and Utilities.
Rent, communications, and utilities
increase by $188,000 in 2020, or 2.3
percent, for a budget of $8.2 million.
This funding pays for
telecommunications services, data
capacity contracts, and information
technology network support. The
increase is primarily due to additional
data capacity that will be required as a
result of implementing the new MERIT
examination system, which will be
cloud-based and consume more data
bandwidth than the AIRES system it is
replacing.
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Administrative Expenses.
Administrative expenses decrease by
$2.8 million in 2020, or 31.9 percent, for
a total budget of $5.9 million. Decreases
to the administrative expenses budget
category largely result from reclassifying
$2.6 million in software licensing costs
as contracted services, not
administrative expenses, in order to
reflect these costs consistently with
other federal budgetary presentations.
Contracted Services. Contracted
services expenses increase by $5.3
million in 2020 for a total budget of
$43.3 million. However, as discussed
above, approximately $2.6 million of
this increase results from costs
previously shown as administrative
expenses being reclassified as
contracted services in order to reflect
these costs consistently with other
federal budgetary presentations. The
actual increase in the contracted
services budget is approximately $2.7
million, or 7 percent.
Contracted services funding pays for
products and services acquired in the
commercial marketplace, and includes
critical mission support services such as
information technology hardware and
software support, accounting and
auditing services, and specialized
subject matter expertise. Certain
information technology costs that were
previously reported as administrative
expenses are now included as
contracted services, which accounts for
a portion of this increase. Expected
price inflation for services to be
purchased in 2020 accounts for the
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within a range of approximately five
positions, as shown in the chart below.
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remainder of the growth in this
category.
Capital Budget. The proposed 2020
Capital Budget is $25.1 million. The
2020 Capital Budget is $6.5 million
more than the 2020 funding level
approved by the Board in November
2018, and $3.1 million than the 2019
Board-approved budget.
The Capital Budget pays for
continued investments in technology
and infrastructure projects. A major
component of the Capital Budget is the
development of the first phases of the
Enterprise Solution Modernization
(ESM) program, which includes a new
technical platform and security
infrastructure, a central user interface
for stakeholders to transact business
with the NCUA, integration of business
intelligence tools into the supervision
function, and the MERIT examination
system, which will replace the agency’s
antiquated AIRES examination software
and will be used by both federal and
state examiners in almost all credit
union examinations. The business
intelligence capabilities were slated for
a later iteration of ESM, but were added
to the first phase when it was
determined they could be integrated
into MERIT for the 2020 release. The
NCUA’s Information Technology
Prioritization Council recommended
$20.9 million for IT software
development projects that continue to
replace the NCUA’s decades-old and
functionally obsolete information
technology systems, and $2.7 million in
other IT investments for 2020. The
NCUA’s facilities require $1.5 million in
capital investments.
Share Insurance Fund Administrative
Expenses. The proposed 2020 Share
Insurance Fund Administrative budget
is $6.5 million.
The 2020 Share Insurance Fund (SIF)
Administrative Budget is $2.7 million
less than the 2020 funding level
approved by the Board in November
2018, and $1.9 million less than the
2019 Board-approved budget. The
decrease in the SIF Administrative
Budget is primarily attributed to the
Office of National Examinations and
Supervision plan to oversee credit
union-run stress testing for the largest
Credit Unions using its own proprietary
models in 2020. Direct charges within
this budget include administration of
the NCUA Guaranteed Note (NGN)
program, state examiner training and
laptop leases, as well as financial audit
support. The reduction in the SIF
Administrative Expenses budget reflects
that costs related to the oversight of
credit union-run stress testing will be
financed by the Operating Budget.
It is also notable that the NCUA’s
operations have become more efficient
relative to the size of the credit union
system because consolidation in the
industry has led to growth in the
number of large credit unions,
specifically those with more than $10
billion in assets. This results in
additional complexity in the balance
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Budget Trends.
As shown in the chart below, the
relative size of the NCUA budget
continues to decline when compared to
balance sheets at federally insured
credit unions. This trend illustrates the
greater operating efficiencies the NCUA
has attained in the last several years
relative to the size of the credit union
system. Additionally, the NCUA has
improved its operating efficiencies more
aggressively than other financial
industry regulators.
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sheets of such credit unions, and a
corresponding increase in the
supervisory review required to ensure
the safety and soundness of such large
institutions. The NCUA has responded
to this increasing complexity through
several initiatives: Creation of the
specialized Office of National
Examination and Supervision,
development of in-house capabilities to
oversee large credit unions’ stress
testing, use of specialist examiners with
expertise in cybersecurity and capital
markets, and improved quality of
examination reports through enhanced
quality review processes.
Federal Compliance Cost Burden
As a federal agency, the NCUA is
required to devote significant resources
to numerous compliance activities
required by federal law, regulations, or,
in some cases, Executive Orders. These
requirements dictate how many of the
agency’s activities are implemented, and
generally result in increasing costs.
These compliance activities require
additional effort in areas such as
information technology acquisitions and
management, human capital processes,
financial management processes and
reporting, privacy compliance, and
physical and cyber security programs.
While agency managers are responsible
for these activities, required compliance
activities add additional layers of
review and procedures that make
processes more challenging and
expensive.
Financial Management
Federal law, regulations, and
government-wide guidance promulgated
by the Office of Management and
Budget (OMB), the Government
Accountability Office (GAO), and the
Department of the Treasury place
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numerous requirements on federal
agencies including the NCUA regarding
the management of public funds.
Government-wide financial
management compliance requirements
include: Financial statement audits,
improper payments, prompt payments,
internal controls, procurement, audits,
enterprise risk management, strategic
planning, and public reporting of
financial and other information.
Information Technology (IT)
There are numerous laws, regulations
and required guidance concerning
information technology used by the
federal government. Many of the
requirements cover IT security such as
the Federal Information Security
Management Act. Other requirements
cover records management, paperwork
reduction, information technology
acquisition, cybersecurity spending, and
accessible technology and continuity.
Human Capital
Like other federal agencies, the NCUA
is subject to an array of human capitalrelated laws, regulations, and other
mandatory guidance issued by OPM, the
Equal Employment Opportunity
Commission, and OMB. Human capital
compliance requirements include
procedures for engagement related to
hiring; management engagement with
public unions and collective bargaining;
employee discipline and removal
procedures; required training for
supervisors and employees; employee
work-life and benefits programs; equal
employment opportunity and required
diversity and inclusion programs; and
storage and retention of human resource
records. The NCUA is also required by
law to ‘‘maintain comparability with
other federal bank regulatory agencies’’
when setting employee salaries.
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Security
The NCUA’s security posture is
driven by numerous legal and regulatory
requirements covering the full range of
security functions. The NCUA is
required to comply with mandatory
requirements for personnel security;
physical security; emergency
management and continuity;
communications and information
security; and insider threat activities. In
addition to meeting specific legislative
mandates, as a federal agency, the
NCUA is required to follow guidance
from, but not limited to, the Office of
the Director of National Intelligence,
OPM, and the Federal Emergency
Management Agency.
General Compliance Activities
The NCUA also has other general
compliance activities that cut across
numerous offices. For example, the
NCUA expends resources complying
with the Privacy Act; Government in the
Sunshine Act; multiple laws and
regulations related to government ethics
standards; and various reporting and
other requirements set forth by the
Federal Credit Union Act and other
statutes.
Federal retirement costs are an
example of mandatory payments to
other federal agencies. As discussed
earlier in this document, the cost of
mandatory contributions to OPM for
most NCUA employees’ retirement
system will increase from 13.7 to 16.0
percent of their salaries, based on the
OPM Board of Actuaries of the Civil
Service Retirement System
recommendations. The budget impact of
these additional retirement costs in
2020 is an increase of approximately $5
million over 2019.
BILLING CODE 7535–01–P
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II. Introduction and Strategic Context
History
For more than 100 years, credit
unions have provided financial services
to their members in the United States.
Credit unions are unique depository
institutions created not for profit, but to
serve their members as credit
cooperatives.
On June 26, 2019, the NCUA
celebrated the 85th Anniversary of
President Franklin Roosevelt’s signing
of the Federal Credit Union Act. The
law was enacted during the Great
Depression, in 1934, enabling credit
unions to be organized throughout the
United States under charters approved
by the federal government. The purpose
of the federal law was to make credit
available to Americans and promote
thrift through a national system of
nonprofit, cooperative credit unions. In
the years since the passage of the
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Federal Credit Union Act, credit unions
have evolved and are larger and more
complex today than those first
institutions. But, credit unions continue
to provide needed financial services to
millions of Americans.
The NCUA is the independent federal
agency established in 1970 by the U.S.
Congress to regulate, charter, and
supervise federal credit unions. With
the backing of the full faith and credit
of the United States, the NCUA operates
and manages the National Credit Union
Share Insurance Fund, insuring the
deposits of the account holders in all
federal credit unions and the vast
majority of state-chartered credit
unions. No credit union member has
ever lost a penny of deposits insured by
the Share Insurance Fund.
Today, the NCUA is responsible for
the regulation and supervision of 5,308
federally insured credit unions 2 with
2 Source: The NCUA quarterly call report data, Q2
2019.
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approximately 118.3 million members 3
and more than $1.5 trillion 3 in assets
across all states and U.S. territories.
Authority
Pursuant to the Federal Credit Union
Act, authority for management of the
NCUA is vested in the NCUA Board. It
is the Board’s responsibility to
determine the resources necessary to
carry out the NCUA’s responsibilities
under the Act.3 The Board is authorized
to expend such funds and perform such
other functions or acts as it deems
necessary or appropriate in accordance
with the rules, regulations, or policies it
establishes.4
Upon determination of the budgeted
annual expenses for the agency’s
operations, the Board determines a fee
schedule to assess federal credit unions.
The Board gives consideration to the
ability of federal credit unions to pay
3 See
4 See
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12 U.S.C. 1752a(a).
12 U.S.C. 1766(i)(2).
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such a fee, and the necessity of the
expenses the NCUA will incur in
carrying out its responsibilities in
connection with federal credit unions.5
Pursuant to the law, fees collected are
deposited in the agency’s Operating
Fund at the Treasury of the United
States, and those fees are expended by
the Board to defray the cost of carrying
out the agency’s operations, including
the examination and supervision of
federal credit unions.6 In accordance
with its authority 7 to use the Share
Insurance Fund to carry out a portion of
its responsibilities, the Board approved
an Overhead Transfer Rate
methodology, and authorized the Office
of the Chief Financial Officer to transfer
resources from the Share Insurance
Fund to the Operating Fund to account
for insurance-related expenses.
Mission, Goals, and Strategy
The NCUA’s 2020–2021 Budget
Submission supports the agency’s third
year implementing its 2018–2022
Strategic Plan to achieve its priorities
and improve program performance.
Throughout 2020 and 2021, the
NCUA will continue fulfilling its
mission to ‘‘provide, through regulation
and supervision, a safe and sound credit
union system which promotes
confidence in the national system of
cooperative credit,’’ and its vision to
ensure that the ‘‘NCUA protects credit
unions and consumers who own them
through effective supervision, regulation
and insurance.’’ This budget commits
the resources necessary to implement
the NCUA’s plans to identify key
challenges facing the credit union
industry and leverage agency strengths
to help credit unions address those
challenges.
The budget supports the NCUA’s
programs, which are focused on
achieving the agency’s three strategic
goals:
D Ensure a safe and sound credit
union system;
D Provide a regulatory framework that
is transparent, efficient, and improves
consumer access; and
D Maximize organizational
performance to enable mission success.
Additional information about
alignment of the budget to the NCUA’s
strategic goals is in Appendix A.
In support of its first strategic goal—
ensure a safe and sound credit union
system—the NCUA will continue to
supervise federally insured credit
unions effectively and maintain a strong
Share Insurance Fund.
5 See
12 U.S.C. 1755(a)–(b).
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The NCUA’s primary function is to
identify credit union system risks,
determine the magnitude of those risks,
and mitigate unacceptable levels
through the examination and
supervision program. The agency
identifies supervision program priorities
each year, aligning budgeted resources
to these priorities while addressing
emerging issues in order to minimize
losses to the Share Insurance Fund.
Program priorities in 2020 include
addressing broad market risks and
emerging cybersecurity threats that
could threaten financial stability
generally, including the safety and
soundness of the credit union system.
Cybersecurity threats and other
technology-related issues continue to be
of key interest and concern to the
NCUA. Increasingly sophisticated cyberattacks pose a significant threat to credit
unions, financial regulators, and the
broader financial services sector. The
availability, confidentiality, and
integrity of credit union member
information remains a key supervisory
priority for the NCUA. As such, the
2020 budget includes resources to
continue to improve and standardize
supervision related to information
protection and cybersecurity risks and
threats.
The NCUA staff of credit union
examiners are the agency’s most
important assets for identifying and
addressing risks before they threaten
members’ deposits. To do their jobs
effectively in this complex and dynamic
financial environment, the NCUA staff
require the advanced skills, training,
and tools supported by the budget. The
multi-year ESM program will reach a
major milestone in 2020 with the release
of the Modern Examination and Risk
Identification Tool (MERIT), the
agency’s modernized examination tool
replacing the Automated Integrated
Regulatory Examination System
(AIRES), to all credit union examiners
and state regulators. As the agency
transitions to this new tool, which will
result in more efficient and effective
supervision, the NCUA must ensure its
staff is prepared. The 2020 budget
includes resources to train and prepare
the NCUA staff as they transition to
using MERIT.
To fulfill the NCUA’s second strategic
goal—provide a regulatory framework
that is transparent, efficient, and
improves customer access—the agency
is committed to creating a more
responsive system that will encourage
6 See
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12 U.S.C. 1755(d).
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innovation, provide flexibility, and
fulfill its primary mission of protecting
safety and soundness. The NCUA also
seeks to promote financial inclusion to
better serve a changing population and
economy. The NCUA also seeks to
ensure consumer compliance, and
financial protection. The budget
allocates resources to agency programs
that keep regulations up to date and
consistent with current law, assist
existing and prospective credit unions
with expansion and new chartering
activities.
Accomplishing the third strategic
goal—maximize organizational
performance to enable mission
success—ensures the NCUA employees
achieve the agency’s mission by
supporting them through efficient and
effective business processes, modern
and secure technology, and suitable
tools necessary to perform their duties.
The budget makes investments in
improved tools and facilities for the
NCUA staff, and technological
enhancements including new systems
that will improve operational
effectiveness and efficiency. The budget
also allocates resources to developing
better human capital planning and
processes including a new leadership
development strategy and a focus on
training for the transition to MERIT.
Organization, Major Agency Programs,
and Workforce
The NCUA operates its headquarters
in Alexandria, Virginia, to administer
and oversee its major programs and
support functions; its Asset
Management and Assistance Center
(AMAC) in Austin, Texas, to liquidate
credit unions and recover assets; and
three regional offices, to carry out the
agency’s supervision and examination
program.
In January 2019, the NCUA
consolidated its five regional offices into
three—Eastern, Southern, and
Western—as part of its on-going effort to
strengthen agency operations while
increasing efficiency. Reporting to these
regional offices, the NCUA has credit
union examiners responsible for a
portfolio of credit unions covering all 50
states, the District of Columbia, Guam,
Puerto Rico, and the U.S. Virgin Islands.
The NCUA organizational chart below
reflects the agency’s current structure,
and the map shows each region’s
geographical alignment:
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The NCUA’s regional offices will
carry out the agency’s 2020 examination
program. The NCUA uses an extended
examination cycle for well-managed,
low-risk federal credit unions with
assets of less than $1 billion.
Additionally, the NCUA’s examiners
perform streamlined examination
procedures for financially and
operationally sound credit unions with
assets less than $50 million. In addition,
the Office of National Examination and
Supervision (ONES) will continue to
examine credit unions with assets that
total over $10 billion that are located
throughout the United States. Based on
2019 second quarter call report
statistics, there are currently nine such
credit unions with 18.0 million
members, accounting for $256 billion in
credit union assets.
In 2020 and 2021, the agency’s
workforce will undertake tasks in all of
the NCUA’s major programs:
Supervision: The NCUA supervises
federally insured credit unions through
examinations and regulatory
enforcement including providing
guidance through various publications,
taking administrative actions and
conserving, liquidating, or merging
severely troubled institutions as
necessary to manage risk.
Insurance: The NCUA manages the
$16 billion Share Insurance Fund,
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which provides insurance to at least
$250,000 for deposits held at federally
insured credit unions. The fund is
capitalized by credit unions and
through retained earnings.
Credit Union Development: Through
training, partnerships and resource
assistance, the NCUA fosters credit
union development, particularly the
expansion of services to eligible
members provided by small, minority,
newly chartered, and low-income
designated credit unions. The NCUA
also charters new federal credit unions,
as well as approves modifications to
existing charters and fields of
membership.
Consumer Financial Protection: The
NCUA protects consumers’ rights
through effective enforcement of federal
consumer financial protection laws,
regulations, and requirements. The
NCUA also develops and promotes
financial education programs for credit
unions to assist members in making
smarter financial decisions.
Asset Management: The NCUA
conducts credit union liquidations and
performs management and recovery of
assets through AMAC. This office
effectively and efficiently manages and
disposes assets acquired from
liquidations.
The NCUA also performs stakeholder
outreach and is involved in numerous
cross-agency initiatives. The NCUA
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conducts stakeholder outreach to clearly
understand the needs of the credit
union system. The NCUA seeks input
from all of its stakeholders, including
the Administration, Congress, State
Supervisory Authorities, credit union
members, credit unions, and their
associations.
The NCUA collaborates with the other
financial regulatory agencies including
through participation in several
councils. Significant councils include
the Financial Stability Oversight
Council (FSOC), the Federal Financial
Institutions Examination Council
(FFIEC), and the Financial and Banking
Information Infrastructure Committee
(FBIIC). These councils and
relationships help ensure consistent
policy and standards within the nation’s
financial system, where appropriate.
Budget Process—Strategy to Budget
The NCUA’s budget process starts
with a review of the agency’s goals and
objectives set forth in the strategic plan.
The strategic plan is a framework that
sets the agency’s direction and guides
resource requests, ensuring the agency’s
resources and workforce are allocated
and aligned to agency priorities and
initiatives.
Each regional and central office
director at the NCUA develops an initial
budget request identifying the resources
necessary for their office to support the
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NCUA’s mission, strategic goals, and
strategic objectives. These budgets are
developed to ensure each office’s
requirements are individually justified
and remain consistent with the agency’s
overall strategic plan.
For regional offices, one of the
primary inputs in the development
process is a comprehensive workload
analysis that estimates the amount of
time necessary to conduct examinations
and supervise federally insured credit
unions in order to carry out the NCUA’s
dual mission as insurer and regulator.
This analysis starts with a field-level
review of every federally insured credit
union to estimate the number of
workload hours needed for the current
year. The workload estimates are then
refined by regional managers and
submitted to the NCUA central office for
the annual budget proposal. The
workload analysis accounts for the
efforts of nearly seventy percent of the
NCUA workforce and is the foundation
for budget requests from regional offices
and ONES.
In addition to the workload analysis,
from which central office budget staff
derive related personnel and travel cost
estimates, each of the NCUA offices
submit estimates for fixed and recurring
expenses, such as rental payments for
leased property, operations and
maintenance for owned facilities or
equipment, supplies,
telecommunications services, major
capital investments, and other
administrative and contracted services
costs.
Because information technology
investments impact all offices within
the agency, the NCUA has established
an Information Technology
Prioritization Council (ITPC). The ITPC
meets several times each year to
consider, analyze, and prioritize major
information technology investments to
ensure they are aligned with the
NCUA’s strategic plan. These focused
reviews result in a mutually agreedupon budget recommendation to
support the NCUA’s top short-term and
long-term information technology needs
and investment priorities.
Once compiled for the entire agency,
all office budget submissions undergo
thorough reviews by the responsible
regional and central office directors, the
Chief Financial Officer, and the NCUA’s
executive leadership. Through a series
of presentations and briefings by the
relevant office executives, the NCUA
Executive Director formulates an
agency-wide budget recommendation
for consideration by the Board.
In recent years, the Board has
emphasized the need for increased
transparency of the NCUA’s finances
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and its budgeting processes. In
response, the Office of the Chief
Financial Officer has made draft budgets
available for public comment via the
NCUA’s website, and solicited public
comments before presenting final
budget recommendations for the Board’s
approval. Furthermore, the Economic
Growth, Regulatory Relief, and
Consumer Protection Act, Public Law
115–174, enacted May 24, 2018,
requires in Section 212 that the NCUA
‘‘make publicly available and publish in
the Federal Register a draft of the
detailed business-type budget.’’ To
fulfill this requirement, the Board
delegated to the Executive Director the
authority to publish the draft budget
before submitting it for Board review.
This 2020–2021 budget justification
document includes comparisons to the
Board approved 2019–2020 budget, and
includes a summary description of the
major spending items in each budget
category to provide transparency and
understanding of the use of budgeted
resources. Estimates are provided by
major budget category, office, and cost
element.
The NCUA also posts supporting
documentation for its budget request on
the NCUA website to assist the public
in understanding its budget
development process. The budget
request for 2020 represents the NCUA’s
projections of operating and capital
costs for the year, and is subject to
approval by the Board.
Commitment to Financial Stewardship
The NCUA funds its activities through
operating fees levied on all federal
credit unions and through
reimbursements from the Share
Insurance Fund, funded by both federal
credit unions and federally insured
state-chartered credit unions. The
Overhead Transfer Rate (OTR)
calculation determines the annual
amount that the Share Insurance Fund
reimburses the Operating Fund to pay
for the NCUA’s insurance-related
activities. At the end of each calendar
year, the NCUA’s financial transactions
are subject to audit in accordance with
Generally Accepted Government
Auditing Standards.8
The Board and the agency are
committed to providing sound financial
stewardship. In recent years, the NCUA
Chief Financial Officer, with support
and direction from the Executive
Director and Board, has worked to
improve the NCUA’s financial
management, financial reporting, and
budget processes. In addition, through
prudent management of the Corporate
8 See
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System Resolution Program, the NCUA
has paid nearly $900 million in
dividends to eligible credit unions over
the last two years.
The NCUA revised its financial
presentations to conform to federal
budgetary concepts and increase
transparency of the agency’s planned
financial activity, starting with the 2018
budget. The 2020–2021 budget
continues this presentation. The NCUA
is the only Financial Institutions
Reform, Recovery, and Enforcement Act
(FIRREA) agency that publishes a
detailed, draft budget and solicits public
comments on it at a meeting with its
Board and other agency leadership.
The NCUA continues to work
diligently to strengthen its internal
controls for financial transactions, in
accordance with sound financial
management policies and practices.
Based on the results of the NCUA’s
assessments conducted through the
course of 2018, the agency provided an
unmodified Statement of Assurance
(signed February 14, 2019) that its
management had established and
maintained effective controls to achieve
the objectives of the Federal Managers
Financial Integrity Act (FMFIA) and
Office of Management and Budget
(OMB) Circular A–123. Specifically, the
NCUA supports the internal control
objectives of reporting, operations, and
compliance, as well as its integration
with overarching risk management
activities. Within the Office of the Chief
Financial Officer, the Internal Controls
Assessment Team (ICAT) continues to
mature the agency-wide internal control
program and continues to strengthen the
overall system of internal control,
further promote the importance of
identifying risk, and ensure the agency
has identified appropriate responses to
mitigate identified risks, in accordance
with the Government Accountability
Office’s Standards for Internal Controls
in the Federal Government (Green Book)
requirements.
III. Forecast and Enterprise Challenges
Economic Outlook
The NCUA’s mission is to provide,
through regulation and supervision, a
safe and sound credit union system,
which promotes confidence in the
national system of cooperative credit.
The challenges that the NCUA faces,
and the resources the NCUA requires to
fulfill its mission, depend on a variety
of factors that directly or indirectly
affect the health of the credit union
system. The NCUA must anticipate, to
the extent possible, developments that
will affect the system, develop
strategies, plans and processes to meet
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both the current and anticipated needs,
and assemble the resources, including
staff, necessary to ensure a safe and
sound system.
One key determinant of credit union
performance is the underlying economic
environment in which they must
operate. In general, for the past few
years, the economy has supported solid
financial system performance. The
economy continued to perform well in
the first half of 2019. Real gross
domestic product expanded by 2.6
percent at an annual rate and, in July,
the current economic expansion reached
the 10-year mark, making it the longest
post-war expansion on record.
Employment has risen steadily for close
to a decade and the unemployment rate
at mid-year was at a five-decade low.
Inflation remained subdued.
With the support of a solid economic
foundation, credit union lending,
membership growth, and credit quality
remained strong through the second
quarter of 2019. Federally insured credit
unions added 4.3 million members over
the year, boosting credit union
membership to 118.3 million in the
second quarter of 2019. Credit union
shares and deposits rose 5.5 percent
over the year ending in the second
quarter to $1.5 trillion. Total loans
outstanding at federally insured credit
unions increased 6.4 percent to $1.1
trillion, and the system-wide loan
delinquency rate fell to 63 basis points
from 67 basis points a year earlier. The
credit union system’s return on average
assets rose to 97 basis points, and the
system’s net worth ratio increased to
11.27 percent in the second quarter.
Although economic conditions were
generally favorable heading into the
second half of 2019, a number of
downside risks exist. Growth in several
major economies overseas showed signs
of weakness. This has generated a level
of uncertainty, which weighs on
business activity, boosts financial
market volatility, has pushed long-term
interest rates in the U.S. downward, and
has contributed to the Federal Reserve’s
decision to loosen monetary policy and
lower their short-term policy rate in two
25 basis point moves during the summer
after four years of tightening.
As of early October, long-term interest
rates had fallen by about 160 basis
points from their most recent peaks in
late 2018, and short-term rates had
declined roughly 50 basis points. With
long-term rates falling more than shortterm rates, the yield curve shifted down
and flattened.
In late May, the spread between the
10-year Treasury note and 3-month
Treasury bond turned negative; it
remained negative through the start of
October. Yield curve inversion has
preceded every recession in the last 50
years, but the timing between initial
inversion and the onset of recession has
varied, as shown in the chart. Most
analysts expect the current expansion to
continue during the NCUA 2020–2021
budget horizon.
Even though the number of negative
risks to the economy has risen, the nearterm outlook for the U.S. economy
remains positive. Forecasts for the next
two years call for somewhat slower—but
still solid—economic growth compared
with 2018. Employment is projected to
rise and the unemployment rate—
already below the level associated with
full employment—is expected to remain
low. Tight labor market conditions are
projected to keep inflation near the
Federal Reserve’s 2.0 percent target.
Federal Reserve policymakers have
lowered the federal funds target rate by
50 basis points since July. Their most
recent forecast, released in September,
suggests they could leave the federal
funds rate unchanged in a range of 1.75
percent and 2.00 percent through next
year, but there is a wide range of views
on the appropriate path of short-term
interest rates going forward. Analysts
are expecting the federal funds target
rate to decline by an additional 25 basis
points before the end of 2019 and are
projecting that other short-term interest
rates—which largely determine the
interest payments credit unions make—
will also move lower in the months
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ahead. Longer-term rates—which largely
determine the interest payments credit
unions receive—are expected to
stabilize in the second half of 2019 and
edge higher in 2020, as the recent flight
to safety reverses.
Solid economic conditions should
remain a positive force for credit union
lending, membership growth, and credit
quality over the 2020–2021 budget
horizon. In addition, the wider term
spread implied by current interest rate
forecasts should translate into less
pressure on credit union net interest
margins and net income going forward.
However, forecasts of the economic
environment are far from perfect. A
recession would pose significant
challenges to the credit union system,
leading to rising delinquencies, reduced
loan demand, and, potentially, an
increase in shares as consumers move
funds from riskier investments into
safer, insured credit union deposits. A
downturn in the economy would likely
lead to lower interest rates as well.
Credit union balance sheets should be
robust to a variety of rate environments.
The NCUA, like the credit unions
themselves, needs to plan and prepare
for a range of economic outcomes that
could affect credit union performance
and determine resource needs.
Other Risk Factors and Trends
In addition to risks associated with
movements in the general economy, the
NCUA and credit unions will need to
understand their increasing exposure to,
and address risks associated with, the
technological and structural changes
facing the system. Over the longer-term,
increased concentration of loan
portfolios, development of alternative
loan and deposit products, technologydriven changes in the financial
landscape, continued industry
consolidation, and ongoing
demographic changes will continue to
shape the environment facing credit
unions and will determine the resource
needs of the NCUA.
Cybersecurity: Credit unions’
increasing use of technology is making
the credit union system more vulnerable
to cyber-attacks. The prevalence of
malware, ransomware, distributed
denial of service (DDOS) attacks, and
other forms of cyber intrusion are
creating challenges at credit unions of
all sizes, and will require ongoing
measures for containment. These trends
are likely to continue, and even
accelerate, over the next two years.
Lending trends: Increasing
concentrations in member business
loans and private student loans, in
addition to other new types of lending
by credit unions, emphasize the need
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for long-term risk diversification and
effective risk management tools and
practices, along with expertise to
properly manage increasing
concentrations of risk.
Financial Landscape and Technology:
New financial products that mimic
deposit and loan accounts, such as
Apple Pay, Walmart pre-paid cards and
peer-to-peer lending, continue to
emerge. These new products pose a
competitive challenge to credit unions
and banks alike. Credit unions also face
a range of challenges from financial
technology (Fintech) companies in the
areas of lending and the provision of
other services. For example,
underwriting and lending may be
automated at a cost below levels
associated with more traditional
financial institutions, but may not be
subject to the same regulations and
safeguards that credit unions and other
traditional financial institutions face.
The emergence and increasing
importance of digital currencies may
pose both risks and opportunities for
credit unions. As these institutions and
products gain popularity, credit unions
may have to be more active in marketing
and rethink their business models.
Technological changes outside the
financial sector may also lead to
changes in consumer behavior that
indirectly affect credit unions. For
example, the increase in on-demand use
of auto services and pay-as-you-go, ondemand vehicle rental could reduce
purchases of consumer-owned vehicles.
That could lead to a slowdown or
reduction in the demand for vehicle
loans, now slightly more than a third of
the credit union system loan portfolio.
Membership trends: While overall
credit union membership continues to
grow, roughly half of federally insured
credit unions had fewer members at the
end of the second quarter of 2019 than
a year earlier. Demographic and field of
membership changes are likely to
continue leading to declining
membership at many credit unions. All
credit unions need to consider whether
their product mix is consistent with
their members’ needs and demographic
profile.
Smaller credit unions’ challenges and
industry consolidation: Small credit
unions face challenges to their longterm viability for a variety of reasons,
including weak earnings, declining
membership, high loan delinquencies,
and elevated non-interest expenses. If
current consolidation trends persist,
there will be fewer credit unions in
operation and those that remain will be
considerably larger and more complex.
As of June 30, 2019, there were 576
federally insured credit unions with
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assets of at least $500 million, 29
percent more than just five years earlier.
These 576 credit unions accounted for
73 percent of credit union members and
79 percent of credit union assets. Large
credit unions tend to offer more
complex products, services and
investments. Increasingly complex
institutions will pose management
challenges for the institutions
themselves, as well as the NCUA;
consolidation means the risks posed by
individual institutions will become
more significant to the Share Insurance
Fund.
Enterprise Risk Management
The NCUA uses an Enterprise Risk
Management (ERM) program to evaluate
various factors arising from its
operations and activities (both internal
to the agency and external in the
industry) that can impact the agency’s
performance relative to its mission,
vision, and performance outcomes.
Agency priority risks include both
internal considerations such as the
agency’s control framework, information
security posture, and external factors
such as credit union diversification risk.
All of these risks can materially impact
the agency’s ability to achieve its
mission.
The NCUA’s ERM Council provides
oversight of the agency’s enterprise risk
management activities. Through the
ERM program, established in 2015, the
agency is identifying and managing
risks that could affect the achievement
of its strategic objectives. In 2018 and
2019, the NCUA developed and
implemented processes for analyzing
and responding to enterprise risks. The
NCUA has conducted several risk
response assessments for priority areas
including credit union business
diversification, credit union
cybersecurity, agency controls, and
information security. These assessments
help inform the agency’s activities,
operations, and planning and budget
processes. Overall, the NCUA’s ERM
program promotes effective awareness
and management of risks, which, when
combined with robust measurement and
communication, are central to costeffective decision-making and risk
optimization within the agency.
The NCUA adopted its enterprise risk
appetite statement in the 2018–2022
Strategic Plan, which is:
The NCUA is vigilant and has an overall
judicious risk appetite. The NCUA’s primary
goal is to ensure the safety and soundness of
the credit union system and the agency
recognizes it is not desirable or practical to
avoid all risk. Acceptance of some risk is
often necessary to foster innovation and
agility. This risk appetite will guide the
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NCUA’s actions to achieve its strategic
objectives in support of providing, through
regulation and supervision, a safe and sound
credit union system, which promotes
confidence in the national system of
cooperative credit.
The agency’s risk appetite helps align
risks with opportunities when making
decisions and allocating resources to
achieve the agency’s strategic goals and
objectives. This enterprise risk appetite
statement is part of the NCUA’s overall
management approach and is supported
by detailed appetite statements for
individual risk areas.
In practice, this means that the NCUA
recognizes that risk is unavoidable and
sometimes inherent in carrying out the
agency’s mandate. The NCUA is
positioned to accept greater risks in
some areas than in others; however,
when consolidated, the risk appetite
establishes boundaries for the entire
agency and all of its programs.
Collaboration across programs and
functions is a fundamental part of
ensuring the agency stays within its risk
appetite boundaries, and the NCUA will
identify, assess, prioritize, respond to
and monitor risks to an acceptable level.
This budget proposal for 2020–2021
incorporates several specific
programmatic changes that resulted
from the NCUA’s enterprise risk
management reviews, such as hiring
new personnel focused on
cybersecurity, acquiring data loss
prevention and other network security
tools, and strengthening analytical focus
on emerging financial risks within the
credit union system.
IV. Key Themes of the 2020–2021
Budget
Overview
The budget supports the priorities and
goals outlined in the agency’s annual
performance plan and the 2018–2022
Strategic Plan. The resources and new
initiatives proposed in the budget
support the NCUA’s mission to
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maintain a safe and sound credit union
system.
The 2020–2021 budget carries forward
a number of key ongoing initiatives,
which include: The Exam Flexibility
Initiative; the increased use of off-site
examinations work and data analytics;
the modernization of information
technology systems; regulatory reform
initiatives; and efforts to implement
organizational efficiencies. Over the
course of the next five years, these
efforts will result in a more effective
organization.
In the 2020–2021 budget, the NCUA
will increase staffing in critical areas
necessary to operate as an effective
federal financial regulator capable of
addressing emerging issues and
continuing to modernize the
examination program. The NCUA
employees are the agency’s most
valuable resource for achieving its
mission, and the agency is committed to
a workplace and a workforce with
integrity, accountability, transparency,
inclusivity, and proficiency. We will
continue investing in the workforce
through training and development,
helping employees develop the tools
they need to do their work effectively.
Employment-related costs are the
single largest driver of the NCUA
budget; therefore, managing the size of
the workforce is important from a
budgetary standpoint. Increases to the
agency’s staffing levels in 2020 address
gaps in the agency’s workforce that must
be filled in order to execute the agency’s
mission and foster an innovative,
responsive and sound credit union
system that meets the needs of all
Americans. The NCUA continues to
assess and balance its mission workload
needs with the financial costs the
agency imposes on the credit union
system. Although the number of credit
unions continues to decline nationwide,
the NCUA must also consider the
increasing complexity and growing asset
base of the entire credit union system.
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The efficiency and effectiveness of the
agency’s workforce is dependent upon
the resiliency of the NCUA’s
information technology infrastructure
and availability of technological
applications. The NCUA is committed
to implementing new technology
responsibly and delivering secure,
reliable and innovative technological
solutions to support its mission. This
necessitates investments funded in the
Capital Budget and additional staff to
provide the analytical tools and
technology the workforce needs to
achieve the NCUA mission.
Enterprise Solution Modernization
In 2015, the NCUA conducted an
assessment of the information
technology (IT) needs across the agency
and developed a business case for
replacing its antiquated legacy systems.
This assessment recognized the full
range of industry leading, cost-effective
alternative strategies, services, and
products for implementing the agency’s
next generation of IT information
management, examination, supervisory,
and data collection solutions.
At that time, the NCUA acknowledged
a technology revamp of this magnitude
as a high-risk endeavor, both in terms of
cost and delivered functionality. The
risk stems from the number of systems
impacted and the unique nature of the
NCUA’s applications, many of which
require a high degree of customization.
However, the agency required a major
modernization after many years of
under-investment in software and
application development.
In November 2015, the NCUA Board
approved a plan for modernizing the
agency’s IT systems known as the
Enterprise Solution Modernization
(ESM) program. The ESM program
recognizes the following legacy systems,
capabilities and strategies need to be
modernized:
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To better manage the complexity of
the ESM Program, the NCUA
established three sub-programs to
modernize the NCUA’s technology
solutions and create an integrated
examination and data environment that
facilitates a safe and sound credit union
system:
Given the age of the NCUA’s legacy
examination systems and their
importance to the mission of the agency,
priority was given to the following parts
of the modernization effort in the first
phase of ESM development:
Æ Better information security across
the organization.
Æ Technical platform and foundation
for new applications.
Æ AIRES replacement (Examination
and Supervision Solution), including
financial analytics.
Æ Central user interface for
stakeholders to interact with the NCUA.
Æ Business Intelligence tools for
enhanced analytical capabilities (added
later to the initial phase as explained
below).
To deploy the Examination and
Supervision Solution, it was first
necessary to stand up new agency
infrastructure that supports the full
modernization program: The technology
architecture, infrastructure, and security
posture required to operate modernized
systems. The necessary infrastructure
was acquired and put in place in 2019.
The ESS program capabilities have been
deployed in part in 2019 and will be
rolled out nationwide in 2020. The new
examination solution, which is named
the Modern Examination and Risk
Identification Tool (MERIT), was
released to the Office of National
Examinations and Supervision in
September 2019, while the release to the
remaining Regional staff is scheduled
for the summer of 2020.
Though not originally included as
part of the initial ESM plan, the agency
has incorporated a robust business
intelligence solution into the MERIT
deployment, which advances the
agency’s analytic capabilities during
this phase. The need for better analytics
is central to the strategy to shift more
exam work offsite.
In addition to better data analytics,
MERIT provides numerous
improvements over the legacy AIRES
examination system, including:
Æ Implementation of better controlled
access to examination data across the
organization.
Æ Faster and well-organized ability to
request and submit items for the
examination.
Æ Collaboration and real-time
information for examiners, team
members, and supervisors, including
state supervisory authorities on joint
exams.
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Æ Opportunities for credit union
users to manage examination findings
and view completed examination
reports.
Æ Business process improvements to
achieve exam efficiencies, including
less data redundancy and relational
support between scope tasks,
questionnaires, and findings.
Cost Estimates
The NCUA engaged an independent
market research firm to estimate the cost
of the initial ESM phases, including
MERIT. Their research estimated a range
in costs of $18.9 to $37.9 million.
From 2015 to 2019, the NCUA Board
approved a total budget of $20.8 million
for the MERIT program. This total
included the modernized and more
secure IT infrastructure, central user
interface, and the first release of MERIT.
The total expected acquisition costs
for this phase of ESM, including actual
costs through 2019 and the budget for
2020, is $36.6 million. This will provide
additional needed functionality in the
second release of MERIT, including the
loan and share download business
intelligence integration.
The NCUA awarded the Examination
and Supervision Solution agile
development contract in 2018. For the
first three-month discovery phase of the
contract, the NCUA and the systems
integrator worked diligently to translate
the business process context and
identify tool-based implications and
functional gaps. After discovery
concluded, the NCUA determined the
full funding needed to meet
developmental, organizational change
management, and scheduling
requirements. As discussed above, the
funding total now includes the
advanced business intelligence
capabilities.
Through September 2019, the NCUA
accomplished the following:
Æ Established the ESM technical
program infrastructure platform,
including enhanced IT security.
Æ Developed the central user interface
known as NCUA Connect, achieving a
secure, single entry point into NCUA
applications.
Æ Deployed the new MERIT
examination tool to ONES to support
examination and supervision of the
largest credit unions.
Æ Developed financial analytics with
dashboards and visualizations designed
to assist the examiner in identifying
risk.
The project is on schedule to meet the
following performance targets:
Æ 2019: Conduct ONES examinations
and supervision contacts for all federal
credit unions with assets greater than
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$10 billion and joint exams with state
regulators in federally insured statechartered credit unions with assets
greater than $10 billion in Washington
and North Carolina using the MERIT
solution, which commenced on October
7, 2019.
Æ 2020: Deploy second release of
MERIT for the majority of the NCUA
staff, state supervisory authorities, and
credit unions in the third quarter of
2020.
Cybersecurity Priorities
Cyber-attacks pose a threat to credit
unions, financial regulators, and the
broader financial system. Advances in
technology and increased use of
cyberspace for financial transactions
means more opportunities for
cybersecurity threats and other
technology-related issues. As a result,
cybersecurity is one of the top priorities
of the NCUA Board. In June 2019,
Chairman Rodney E. Hood appointed a
special advisor for cybersecurity who
not only will provide strategic counsel
on cybersecurity policy but will also
engage with other federal financial
institution regulators and external
stakeholders.
In 2018, the NCUA began
implementing a new Automated
Cybersecurity Examination Tool (ACET)
maturity assessment for credit unions
with assets greater than $1 billion. The
focus of the ACET implementation was
to baseline individual credit unions’
cybersecurity maturity consistently
while benchmarking the entirety of the
sector. In 2019, the maturity
assessments were conducted on credit
unions with assets greater than $250
million; in 2020, the agency will
conduct maturity assessments on credit
unions with assets between $100
million and $250 million. The NCUA
continues to evaluate the feasibility for
conducting the maturity assessments on
even smaller, less complex institutions.
Concurrently, the NCUA is
developing a tailored examination
program based on the Information
Technology Risk Examination (InTREx)
solution leveraged by the Federal
Deposit Insurance Corporation, the
Federal Reserve Board and state
regulators to ensure a harmonized,
repeatable, measurable and transparent
process for examining the compliance,
safety and soundness of the credit
unions’ information security programs.
The examination procedures will be
maintained within the NCUA MERIT
solution. The agency expects the results
of both the maturity assessment and the
examination program to help focus and
prioritize cybersecurity for credit unions
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and make it an integral part of their riskmanagement strategies.
The NCUA will further build upon its
cybersecurity capabilities and programs
to continue helping credit unions and
consumers protect themselves.
Specifically, the 2020 budget allocates
resources to the following cybersecurityrelated activities:
Æ Advancing consistency,
transparency and accountability within
the cybersecurity examination and
supervision program;
Æ Expanding cybersecurity analytics
to better inform examination and
supervision decisions;
Æ Enhancing interoperability of the
maturity assessment capability for broad
credit union system distribution and
full integration into the new
examination system, MERIT;
Æ Stimulating due diligence for
supply chain and third-party service
provider management within the credit
union sub-sector;
Æ Assisting institutions with
resources to improve operational
cybersecurity hygiene and resilience;
Æ Performing skills assessments of
credit union examiners and taking steps
to build skill set of examination staff in
accordance with the National Initiative
of Cybersecurity Education (NICE)
Framework;
Æ Enhancing the professional
expertise and knowledge management
of
Æ agency specialists on cybersecurity
and emerging technical innovation in
the delivery of financial services,
cybersecurity trends and risk/threat; and
Æ Expanding collaboration and
coordination with relevant agencies
towards a more harmonized
examination and critical infrastructure
protection capability.
These initiatives—focused on
supervisory program development,
training, industry analysis and
exercises, combined with interagency
coordination and industry outreach—
will require additional personnel. The
2020 budget includes two new
cybersecurity positions within the
Office of Examination and Insurance to
improve the agency’s ability to be
prepared for and respond to the
broadening responsibilities tied to
cybersecurity and critical infrastructure
protection.
The NCUA also places strong
emphasis on ensuring the security of the
agency’s systems and the controlled,
unclassified information it collects. The
NCUA’s Office of the Chief Information
Officer is continually taking steps to
enhance the agency’s information
security posture and ensure the NCUA’s
systems and information are protected
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from compromise, including the work
done as part of ESM. The 2020 budget
allocates $500,000 to acquire and
implement data loss prevention (DLP) as
part of the Information Technology (IT)
Infrastructure, Platform and Security
Refresh Capital Initiative. DLP is a set of
tools and processes used to ensure that
sensitive data is not lost, misused, or
accessed by unauthorized users.
Bank Secrecy Act Compliance
The NCUA continues to budget
resources to comply with the statutory
mandate from Congress to enforce
federal credit union compliance with
Bank Secrecy Act (BSA) and AntiMoney Laundering (AML) laws and
regulations. Technological
advancements may expose even the
smallest credit unions to potential illicit
finance activities. The NCUA examines
federal credit union compliance with
BSA during every examination.
Additionally, the NCUA assists state
regulators by conducting BSA
examinations in federally insured, statechartered credit unions where state
resources are limited.
In 2019, the NCUA’s field staff began
more in-depth reviews of credit unions’
BSA and AML policies, procedures, and
processes to assess compliance with
new customer due diligence (31 CFR
1020.210(b)(5)) and beneficial
ownership requirements (31 CFR
1010.230) which became effective May
11, 2018.
The NCUA’s BSA reviews are riskfocused and include procedures to
review an institution’s compliance with
the pillars of the BSA. These procedures
are based on the examination
procedures in the FFIEC BSA/AML
Examination Manual the NCUA issues
jointly with the other federal financial
institution regulators. The NCUA’s
examiners tailor examinations based on
the unique risk characteristics of each
federal credit union. Additional or more
in depth reviews are performed for
those with higher risk activities; reviews
at credit unions with lower risk
activities are scaled appropriately.
The NCUA coordinates regularly with
our counterparts at the other federal
financial institution regulatory agencies,
as well as the Financial Crimes
Enforcement Network (FinCEN). The
NCUA actively participates in the Bank
Secrecy Act Advisory Group (BSAAG),
the FFIEC BSA/AML Working Group
and an interagency working group to
improve effectiveness and streamline,
where possible, regulations and
supervisory processes. The NCUA also
partners with the other federal financial
institution regulators to issue joint BSA
statements, including the Joint
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Statement on Risk-Focused BSA/AML
Supervision, dated July 22, 2019.
Interagency groups are currently
updating the Interagency Statement on
Enforcement of BSA/AML
Requirements, originally issued in 2007,
and the FFIEC BSA/AML Examination
Manual, last revised in 2014. The NCUA
intends to continue collaborating with
our regulatory counterparts, including
FinCEN.
In 2019, the NCUA issued Regulatory
Alert 19–RA–02, Serving Hemp
Businesses, to update federally insured
credit unions about changes in federal
law and regulation related to hemp.
Specifically, the guidance clarifies that
credit unions may provide the
customary range of financial services for
business accounts, including loans, to
lawfully operating hemp related
businesses within their fields of
membership, and provides information
to help credit unions better understand
what they should consider providing
financial services to lawfully operating
hemp businesses.
Stakeholder Engagement
In 2020, the agency is allocating
resources for engagement summits with
stakeholders. These events will include
credit union officials, staff, and
volunteers in order to discuss many of
the priorities the agency has funded
through this budget process. Topics of
interest at these summits may include
financial inclusion, minority depository
institutions, cybersecurity or risk and
risk mitigation strategies in the current
environment. The NCUA Board is
committed to understanding how these
priority areas impact credit unions and
engaging in a thoughtful dialogue to
determine whether there are additional
actions the NCUA should and shouldn’t
take to ensure credit unions are best
prepared to serve their members while
doing so in a safe and sound manner.
Examination Initiatives
The NCUA is focused on several
additional examination modernization
efforts as outlined in the August 2018
Letter to Credit Unions: 18–CU–01—
‘‘Examination Modernization
Initiatives.’’ This letter outlined five
initiatives to modernize the agency’s
examinations processes, including the
ESM program outlined above. Intended
benefits of these initiatives include:
Æ More efficient and less burdensome
examinations and supervision
Æ More consistent and accurate
supervisory determinations
Æ Enhanced coordination with State
Supervisory Authorities
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Æ More secure, reliable, and flexible
technology to support future expansion
capabilities
These modernization initiatives are
interrelated and complement each other.
As these initiatives support and build
upon each other, they will ultimately
result in a fully modernized
examination and supervision program
with various incremental improvements
along the way. The budget allocates
resources in support of these
improvements. Below is a more indepth discussion of four of the
initiatives. The fifth initiative, the ESM
program, is discussed in detail above.
ONES Data-Driven Supervision
This initiative began in 2018 as an
effort to move to a continuous
supervision model for the large, naturalperson credit unions supervised by the
ONES. This ongoing supervision
program will use data-driven analytics
to monitor and identify credit union risk
while supporting the oversight of credit
union-driven stress testing. The NCUA’s
ONES travel costs are projected to
decrease by 10 percent as a result of
implementing this program and the
transition to the NCUA’s in-house
oversight of credit union run stresstesting will allow the NCUSIF to avoid
$3 million in costs in 2020. The datadriven supervision initiative may lead
to analytical advancements that can be
adapted for supervising some or all
other insured credit unions.
Shared NCUA-State Regulator Federally
Insured, State-Chartered Credit Unions
Program
In 2017, the NCUA created the Joint
NCUA-State Supervisor Working Group
(working group), which is tasked with
improving coordination and scheduling
for joint exams, providing scheduling
flexibility, and reducing redundancy
where possible. The group’s goal is to
minimize the burden on federally
insured, state-chartered credit unions
resulting from having a separate
financial regulator and insurer.
In addition, the working group is
evaluating the appropriateness and
feasibility of adopting an alternatingyear examination approach for federally
insured, state-chartered credit unions. A
pilot program launched January 2019
and will allow the NCUA, state
regulators, and stakeholders to evaluate
the benefits and challenges of an
alternate-year examination program.
The pilot will last approximately three
years in order to collect enough
information to evaluate one full
alternating-year exam cycle. The results
of the pilot will provide valuable insight
into the advantages and risks of such an
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approach prior to finalizing a decision
about a permanent alternating-year
exam cycle.
To support joint examinations in
federally insured, state-chartered credit
unions, the working group developed a
new template framework for improved
coordination and cooperation between
the NCUA regions and the respective
state regulators. The working group is
also exploring ways to minimize
duplication and overlap through
examination and procedure
improvements and greater use of
technology. In addition, the working
group is evaluating other areas of
potential duplication that can be
reduced or eliminated, such as loan
participations, Credit Union Service
Organizations (CUSOs) and third party
vendor reviews, and other supervisory
matters. The goal of these reviews is to
better leverage the work of each
regulatory party in examining and
supervising federally insured, statechartered credit unions.
Virtual Examination Program
In 2017, the NCUA Board approved
the project and associated resources to
research methods to conduct offsite as
many aspects of the examination and
supervision processes as possible. The
virtual exam project team is researching
ways to harness new and emerging data,
advancements in analytical techniques,
innovative technology, and
improvements in supervisory
approaches. When approving the 2019
budget, the NCUA Board approved
using past years’ unspent balances to
complete the research and discovery
phase for virtualizing key elements of
the examination; this work will
continue through 2020.
By identifying and adopting
alternative methods to remotely analyze
much of the financial and operational
condition of a credit union, with
equivalent or improved effectiveness
relative to current examinations, it may
be possible to significantly reduce the
frequency and scope of onsite
examinations. Onsite examination
activities could potentially be limited to
periodic data quality and governance
reviews, interventions for material
problems, and meetings or other
examination activities that need to be
handled in person.
The virtual exam should lead to
greater use of standardized interaction
protocols, advanced analytical
capabilities, and more-informed subject
matter experts. This should result in
more consistent and accurate
supervisory determinations, provide
greater clarity and consistency with
respect to how the agency conducts
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supervisory oversight, and reduce
coordination challenges between agency
and credit union staff.
To be successful, it is likely
examination staff will need to analyze
more information about the credit union
being examined and communicate more
frequently with management at the
credit union. However, it is not the
agency’s intent to intervene in credit
unions’ day-to-day operations or
strategic planning.
The virtual examination team will
deliver to the NCUA Board by the end
of 2020 a report discussing alternative
methods identified to remotely analyze
aspects of the financial and operational
condition of a credit union.
Offsite Examination Procedures
Starting in 2016, the NCUA’s
Southern Region piloted a flexible exam
program—commonly called FLEX. The
pilot program ran through 2018 and
evaluated conducting certain existing
exam procedures offsite. The pilot
assessed examiners working remotely
on elements of examinations of well-run
credit unions with the technology and
platforms to provide electronic data
securely.
In 2019, the NCUA adopted the best
practices from the FLEX pilot
nationally. Now known as offsite
examination procedures, the NCUA
updated its National Supervision Policy
Manual to indicate the agency’s support
for providing staff with the flexibility to
conduct examination work offsite when
appropriate conditions are met. The
NCUA continues to develop plans to
increase agency use of offsite
procedures.
Regulatory Reform
The NCUA established a Regulatory
Reform Task Force (Task Force) in
March 2017 to oversee implementation
of the agency’s regulatory reform
agenda. This is consistent with the spirit
of Executive Order 13777 and the
Trump administration’s regulatory
reform agenda. Although the NCUA, as
an independent agency, is not required
to comply with Executive Order 13777,
the agency chose to review all of the
NCUA’s regulations, consistent with the
spirit of initiative and the public benefit
of periodic regulatory review. The
NCUA has undertaken a series of
regulatory changes as part of this effort,
and continues to pursue a regulatory
reform agenda, including matters such
as advertising, field of membership,
equity distribution, and securitization.
The Task Force published its final
report in December 2018.
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Reorganization/Restructuring
In July 2017, the NCUA’s executive
leadership committed to a
comprehensive plan that would invest
in the agency’s future, make critical
organizational alignment changes, and
improve the NCUA’s efficiency,
effectiveness, and focus on its core
mission responsibilities. The agency has
completed the operational actions
related to its reform plan.
As a result of the NCUA’s reform
plan:
Æ The NCUA created an office
focused exclusively on credit union
service needs including new charters,
credit union expansion, and training—
the Credit Union Resources and
Expansion (CURE) Office.
Æ Examination reports have been
improved through enhanced quality
measures.
Æ Two regional offices closed in
January 2019 and leased office space has
been reduced.
Æ AMAC’s staffing has been reduced,
and support functions are now better
aligned with the central office.
The NCUA continues to examine how
to best balance meeting workforce and
technology needs while containing
operating costs.
V. Operating Budget
Overview
The NCUA Operating Budget is the
annual resource plan for the NCUA to
conduct activities prescribed by the
Federal Credit Union Act of 1934. These
activities include: (1) Chartering new
federal credit unions; (2) approving field
of membership applications of federal
credit unions; (3) promulgating
regulations and providing guidance; (4)
performing regulatory compliance and
safety and soundness examinations; (5)
implementing and administering
enforcement actions, such as
prohibition orders, orders to cease and
desist, orders of conservatorship and
orders of liquidation; and (6)
administering the National Credit Union
Share Insurance Fund.
Staffing
The staffing levels proposed for 2020
reflect the resource requirements for
steady state operations at the NCUA as
it continues to modernize the
examination process to enhance the
efficiency and effectiveness of the
supervisory process. Two new
information systems officers in the
Office of Examinations and Insurance
will support expanded responsibilities
for cybersecurity and critical
infrastructure protection. A third
position will be created in the
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Chairman’s office to support the NCUA
through strategic outreach and
engagement with stakeholders in the
credit union system, including credit
union management, associations and
leagues, and journalists who cover the
industry.
During the July 2019 mid-session
review, the NCUA Board approved four
additional staff to support the agency’s
growing engagement with the
Administration, Congress, industry
stakeholders, and the general public.
The newly authorized positions for the
Office of External Affairs and
Communications include a Deputy
Director, a Communications Specialist,
a Technical Writer and Editor, and a
Program Analyst for External Affairs.
The full cost of these positions are
included in the 2020 budget.
The 2020 budget supports a total
agency staffing level of 1,185 personnel,
of which 1,180 are funded in the
Operating Budget. This is a net increase
of three positions, or 0.25 percent,
compared to the Board-approved level
for 2019, as modified at the July 2019
Board meeting. The new 2020 positions
are described in greater detail below.
In addition to the staff assigned to
regional offices, most of the staff in
ONES are remote field staff who also
travel to credit unions as part of their
examination responsibilities.
Request for New Staff in 2020
that include: Management of
interagency activities, development of
industry policy related to information
security, and improvement of credit
union cybersecurity resilience. The goal
of these positions is to increase
institutional knowledge of cybersecurity
best practices within the credit union
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Information Systems Officers (+2 New
Positions)
These new employees, requested in
the Office of Examination and
Insurance, will be responsible for
expanded cybersecurity responsibilities
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system and broaden skills within the
NCUA to ensure a consistent and
professional approach during credit
union supervision.
Senior Adviser to the Chairman for
Communications and Engagement (+1
New Position)
This new employee will support the
NCUA through strategic outreach and
Salaries and Benefits
The budget includes $231.4 million
for employee salaries and benefits in
2020. This change is an $8.5 million, or
3.8 percent, increase from the 2019
Board-approved budget.
Salaries and benefits costs make up
73.2 percent of the total budget. There
are two primary drivers of increased
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engagement with stakeholders in the
credit union system, including credit
union management, associations and
leagues, and journalists who cover the
industry. This employee will also assist
the NCUA Board by keeping members
up to date about challenges and changes
within the system.
Budget Category Descriptions and Major
Changes
costs in 2020 for the Salaries and
Benefits category:
Æ Merit and locality pay increases for
the NCUA’s 1,180 personnel paid from
the Operating Budget, in accordance
with the agency’s current Collective
Bargaining Agreement (CBA) and its
merit-based pay system. Salaries are
estimated to increase 1.8 percent in
aggregate compared to 2019. This
growth is lower than prior years due to
new employee starting salaries being set
at the lower end of pay ranges when
turnover occurs and because of some
staff reaching the salary caps for their
pay grades.
Æ Contributions for employee
retirement to the Federal Employee
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There are five major expenditure
categories in the NCUA budget. This
section explains how these expenditures
support the NCUA’s operations, and
presents a transparent and
comprehensive accounting of the
Operating Budget.
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Retirement System (FERS), which are
unilaterally set by the Office of
Personnel Management, and which
cannot be negotiated or changed by the
NCUA. Driven by the mandatory rate
adjustment, the 2020 benefits costs
increase 9.0 percent compared to 2019.
These changes are described in more
detail below.
In 2020, the NCUA’s compensation
levels will continue to ‘‘maintain
comparability with other federal bank
regulatory agencies,’’ as required by the
Federal Credit Union Act.9 The Salaries
and Benefits category of the budget
includes all employee pay raises for
2020, such as merit and locality
increases, and those for promotions,
reassignments, and other changes, as
described below.
Consistent with other federal pay
systems, the NCUA’s compensation
includes base pay and locality pay
components. The NCUA staff will be
eligible to receive an average meritbased increase of 3.0 percent, and an
additional locality adjustment ranging
from ¥1.0 percent to +3.0 percent,
depending on the geographic location.
The average increase in locality pay is
estimated to be 1.52 percent. Starting in
2018, the NCUA discontinued the
annual, general pay scale increase of
1.25 percent in accordance with the
most-recent CBA negotiations.
The first-year cost of the new
positions added in 2020 is estimated to
be $0.9 million. Specific increases to
individual offices’ salaries and benefits
budgets will vary based on current pay
levels, position changes, and
promotions.
Personnel compensation at the NCUA
varies among every office and region
depending on work experience, skills,
years of service, supervisory or nonsupervisory responsibilities, and
geographic locations. In general, more
than 85 percent of the NCUA workforce
has earned a bachelor’s degree or higher,
compared to approximately 35 percent
of the private-sector workforce. This
high level of educational achievement
ensures the NCUA workforce is able to
fulfill its mission effectively and
efficiently, and attracting a wellqualified workforce requires the agency
to pay employees competitive salaries.
Individual employee compensation
varies, depending on the cost of living
in the location where the employee is
stationed. The federal government sets
locality pay standards, which are
9 The Federal Credit Union Act states that, ‘‘In
setting and adjusting the total amount of
compensation and benefits for employees of the
Board, the Board shall seek to maintain
comparability with other [F]ederal bank regulatory
agencies.’’ See 12 U.S.C. 1766(j)(2).
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managed by the President’s Pay Agent—
a council established to make
recommendations on federal pay. The
council uses data from the Occupational
Employment Statistics program,
collected by the Bureau of Labor
Statistics, to compare salaries in over 30
metropolitan areas, and establishes
recommendations for equitable
adjustments to employee salaries to
account for cost-of-living differences
between localities.
The OPM economic assumptions for
actuarial valuation of the FERS have
increased significantly for 2020. All
federal agencies are expected to
contribute 16.0 percent of FERS
employees’ salaries to the OPM
retirement system, an increase of 230
basis points compared to the 2019 level.
This mandatary contribution is
prescribed in the OPM Benefits
Administration Letter dated June 2019.
The estimated impact on the NCUA
budget is an increase of approximately
$5.0 million in mandatory payments to
OPM, or 1.6 percentage points of
budgetary growth, compared to 2019
levels.
The average health insurance costs for
the Federal Employees Health Benefits
program for 2020 are consistent with
historical actual expenses. The
employee salary and benefits category
also includes costs associated with other
mandatory employer contributions such
as Social Security, Medicare,
transportation subsidies,
unemployment, and workers’
compensation.
The 2020 budget estimate for pay and
benefits includes the assumption of a
2.2 percent vacancy rate (roughly 26
full-time positions) during the year.
This aligns with the NCUA’s recent
attrition rates and workforce
management efforts to carefully review
every vacancy created in the agency in
2020 before a hiring notice is published.
The effect of this adjustment lowers the
NCUA budget estimate and results in
reduced fees collected from credit
unions.
The 2021 budget request for salaries
and benefits is estimated at $237.8
million, a $6.4 million increase from the
2020 level, which accounts for merit
and locality increases consistent with
the CBA (approximately $4.1 million),
the full-year cost impact of new
positions (approximately $0.6 million),
and associated increases in benefits for
all employees (approximately $1.7
million). The assumptions used for
compensation-related adjustments are
based on the CBA currently in force.
The NCUA CBA will be renegotiated
during 2020, with any changes reflected
in future budget cycles.
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Travel
The 2020 budget includes $27.4
million for Travel. This change is a
$590,000, or 2.2 percent, increase to the
2019 Board-approved budget. Travel
comprises approximately nine percent
of the overall 2020 budget. The
cumulative reduction of the credit
union examiner positions compared to
past years, extended examination
cycles, and increased use of offsite
examinations all help contain the
NCUA’s travel costs. However, the
General Services Administration (GSA)
announced an increase to standard
lodging rates to $96 dollars in 2020, an
increase of four dollars, or four percent
compared to 2019, which contributes to
the growth of estimated travel expenses
in 2020. In addition, effective with
2019, GSA will charge the NCUA fees
for the city pair program that provides
discounted and flexible air passenger
transportation services to federal
government travelers. Although the
NCUA has always participated in the
mandatory program, prior year fee
payments were not applied to the
NCUA. The annual cost of $20,000 to
GSA for all the NCUA employee travel
fees may increase depending on future
travel schedules.
The Travel cost category includes
expenses for employees’ airfare, lodging,
meals, auto rentals, reimbursements for
privately owned vehicle usage, and
other travel-related expenses. These are
necessary expenses for examiners’
onsite work in credit unions. Close to
two-thirds of the NCUA’s workforce is
comprised of field staff who spend a
significant part of their year traveling to
conduct the examination and
supervision program.
The NCUA staff also travel for routine
and specialized training. In 2020, the
NCUA will conduct a series of training
events to support the nationwide rollout of MERIT. The NCUA’s planning
staff conducted extensive research to
identify low-cost locations for these
events. The roll-out will be a labor
intensive effort requiring up to six
weeks of travel for many of the NCUA’s
staff, and will provide hands-on training
for this new system, which will be
officially deployed in the fourth quarter
of 2020. The estimated travel costs for
MERIT-related training funded in the
2020 Operating Budget is $1.0 million.
The NCUA plans to evaluate future
cost avoidance for travel through
continued expansion of offsite
examination work. In addition, agency
personnel will continue to utilize more
virtual training options, where
appropriate, to help minimize travel
expenses. The 2021 budget request for
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the travel is estimated to be $26.7
million, less than 2020 because of the
exclusion of one-time MERIT training
costs.
Rent, Communications, and Utilities
The 2020 budget includes $8.2 million
for Rent, Communications, and Utilities.
This is an $188,000 increase, or 2.3
percent more than the 2019 Boardapproved budget. The Rent,
Communications, and Utilities category
is the smallest component of the
NCUA’s budget and funds the agency’s
telecommunications and information
technology network expenses, and
facility rental costs.
The agency telecommunications
budget for 2020 is $4.5 million and
accounts for most of the increase in this
budget category. The
telecommunication charges include
leased lines, domestic and international
voice (including mobile), and other
network charges. Telecommunication
costs include the circuits and any
associated usage fees for providing voice
or data telecommunications service
between data centers, office locations,
the internet and any customer, supplier
or partner. The increased costs support
trusted internet protocol services due to
higher data consumption and use of
cloud-based services.
Office building leases, meeting
rentals, office utilities, and postage
expenses are also included in this
budget category. Facility costs total $2.1
million for 2020 and include the
NCUA’s annual payment of $1.3 million
to the Share Insurance Fund for its
central office note, which is scheduled
to be fully repaid in 2023. The annual
utility costs for the central office and
regional offices are estimated at
$483,000.
The 2020 budget also includes $1.1
million for event rental costs for
examiner meetings and other training
events. This includes the one-time costs
of $220,000 for space rental for the
MERIT training events planned in 2020.
The 2021 budget request for the Rent,
Communications, and Utilities category
is estimated to be $8.0 million, less than
2020 because of the exclusion of onetime MERIT training costs.
Administrative Expenses
The 2020 budget includes $5.9 million
for Administrative Expenses. This is a
decrease of $2.8 million, or 31.9
percent, compared to the 2019 Boardapproved budget. Recurring costs in the
Administrative Expenses category
include the annual reimbursement to
the Federal Financial Institutions
Examination Council (FFIEC), employee
relocation expenses, recruitment and
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advertising, shipping, printing,
subscriptions, examiner training and
meeting supplies, office furniture, and
employee supplies and materials.
Most of the decrease in the
Administrative Expenses budget results
from realigning the costs of various
service contracts, maintenance fees, and
end-user licensing for computer
software and database management
applications to the Contracted Services
budget. Approximately $3.8 million,
unchanged from 2019, will be
permanently included in Contract
Services, which is consistent with
standard government reporting for
software costs. This includes annual
software licenses and maintenance
support fees for the call center managed
by the Office of Consumer Financial
Protection.
As part of the FFIEC, the NCUA
shares in costs for joint actions and
services that affect the financial services
industry. The overall decrease is
$78,000 less than the 2019 budget levels
since the state examiner training costs
will be reduced next year.
The 2020 budget includes $100,000
for employee relocation expenses,
although expected relocation expenses
are estimated to be more. The budget
proposes using $900,000 of unspent
balances from prior years to pay for
these additional costs, for a total
relocation budget of $1,000,000. This
spending level reflects recent average
annual expenditures for employee
relocations and is a $250,000 increase
over the 2019 Board-approved budget.
Relocation costs are paid by the NCUA
to employees who are competitively
selected for a promotion or new job
within the agency in a different
geographic area than where they live.
Employee relocations have increased in
quantity and cost per employee in
recent years, especially in 2019. The
larger number of employee relocations
is partly the result of additional hiring
and partly from the effects of the 2018
NCUA reorganization. The increase in
relocation costs is also related to
changes in the 2017 tax law that now
treats all relocation reimbursements as
taxable income. Like other government
agencies and private sector employees,
the NCUA must now reimburse
employees not just for their relocation
expenses, but also for the personal tax
liability resulting from those payments.
Continuous business process
improvements and financial controls
have decreased costs for printing, and
other administrative costs, which are
estimated to be $112,000 less than in
2019.
The 2021 budget request for the
Administrative Services category is
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expected to increase by $250,000, or 4.2
percent, due to increases in the
employee relocation budget.
Contracted Services
The 2020 budget includes $43.3
million for Contracted Services. This is
a $5.3 million, or 13.8 percent, increase
compared to the 2019 Board-approved
budget. The Contracted Services budget
category includes costs incurred when
products and services are acquired in
the commercial marketplace. Acquiring
specific expertise or services from
contract providers is often the most
cost-effective approach to fulfill the
NCUA’s mission. Such services include
critical mission support such as
information technology equipment and
software development, accounting and
auditing services, and specialized
subject matter expertise that enable staff
to focus on core mission execution.
The majority of funding in the
Contracted Services category is related
to the NCUA’s priority to implement a
robust supervision framework by
identifying and resolving traditional risk
concerns such as interest rate risk,
credit risk, and industry concentration
risk, as well as by addressing new and
evolving operational risks such as
cybersecurity threats. Growth in the
contracted services budget category
results primarily from new operations
and maintenance costs associated with
ongoing capital investments, such as
replacements for the AIRES and CU
Online. Other costs include core agency
business operation systems such as
accounting and payroll processing, and
various recurring costs, as described in
the seven major categories, below:
D Information Technology Operations
and Maintenance (45 percent of
contracted services)
—IT network support services and
help desk support
—Contractor program and web
support and network and
equipment maintenance services
—Administration of software
products such as Microsoft Office,
Share Point and audio visual
services
D Administrative Support and Other
Services (14 percent of contracted
services)
—Examination and Supervision
program support
—Technical support for examination
and cybersecurity training programs
—Equipment maintenance services
—Legal services and other expert
consulting support
—Other administrative mission
support services for the NCUA
central office
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D Accounting, Procurement, Payroll and
Human Resources Systems (10
percent of contracted services)
—Accounting and procurement
systems and support
—Human resources, payroll, and
employee services
—Equal employment opportunity and
diversity programs
D Building Operations, Maintenance,
and Security (10 percent of
contracted services)
—Central office facility operations
and maintenance
—Building security and continuity
programs
—Personnel security and
administrative programs
D Information Technology Security (9
percent of contracted services)
—Enhanced secure data storage and
operations
—Information security programs
—Security system assessment services
D Training (7 percent of contracted
services)
—Examiner staff, technical and
specialized training and
development
—Senior executive and mission
support staff professional
development
D Audit and Financial Management
Support (5 percent of contracted
services)
—Annual audit support services
—Material loss reviews
—Investigation support services
—Financial management support
services
Major programs within the contracted
services category include:
D Training requirements for the
examiner workforce. The NCUA’s most
important resource is its highly
educated, experienced, and skilled
workforce. It is important that staff have
the proper knowledge, skills, and
abilities to perform assigned duties and
meet emerging needs. Each year, Credit
Union Examiners attend several levels
of training, including in core areas such
as capital markets, consumer
compliance, and specialized lending.
The training deliverables for 2020
include the MERIT training sessions
discussed elsewhere in this document,
classes offered by the Federal Financial
Institutions Examination Council, new
examiner classes, and subject matter
expert training sessions for the NCUA
examiners.
Starting in 2020, the NCUA is
reducing its financial support for
training for state examiners. Budgets for
state examiner training at the FFIEC
have been reduced by approximately 50
percent.
Contracted service providers, in
partnership with the NCUA subject
matter experts, will develop and design
subject matter expert training classes for
examiners and conduct a triennial
review of several modules of the
NCUA’s core course curriculum.
Additionally, contracted service
providers and central office staff will
continue conducting organizational
development and teambuilding training
to help support new team operations as
a result of the Agency reorganization.
D The NCUA’s information security
program supports ongoing efforts to
strengthen cybersecurity and ensure
compliance with the Federal
Information System Management Act.
D Agency financial management
services, human resources technology
support, and payroll services. The
NCUA contracts for these back-office
support services with the U.S.
Department of Transportation’s
Enterprise Service Center (DOT/ESC)
and the General Services
Administration. The NCUA’s human
resource system, HR Links, also adopted
by other federal agencies, is a shared
solution that automates routine human
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VerDate Sep<11>2014
The following pie chart illustrates the
breakout of the seven categories for the
total 2020 contracted services budget of
$43.3 million.
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resource tasks and improves time and
attendance functionality.
D Audit. The NCUA Office of
Inspector General contracts with an
accounting firm to conduct the annual
audit of the agency’s four permanent
funds. The results of these audits are
posted annually on the NCUA website
and also included as part of the agency’s
Annual Report.
A significant share of the budget for
the Contracted Services category
finances on-going infrastructure support
for the agency. For example, the NCUA
relies on recurring contracted services to
maintain a number of the agency’s
examination systems that will replace
legacy systems such as AIRES and CU
Online. In future budgets, annual
Operation and Maintenance costs for the
MERIT system will be included in the
Contract Services spending category.
Several of the NCUA’s core information
technology systems and processes also
require additional contract support in
2020, which result in increased budgets
in the Contracted Services category, as
described below.
Within the budget for the Office of
Chief Information Officer, an additional
$0.7 million is required primarily for
the operations and maintenance costs of
capital projects delivered in 2019 and
2020, and for other information
technology hardware critical to ensure
business continuity.
Within the budget for the Office of
Chief Financial Officer, the annual fee
paid to the Department of
Transportation (DOT) for the NCUA’s
financial management system is roughly
the same as the 2019 level of $1.2
million.
Within the budget for the Office of
Continuity and Security Management,
the Central Office building’s physical
access controls will be replaced in 2020,
which is expected to cost approximately
$600,000. In addition, mandatory
reimbursement to the Office of
Personnel Management for background
investigations will increase by an
estimated $125,000 in 2020.
The 2021 budget for Contracted
Services is estimated to increase by
$4,000,000, or 9.3 percent, compared to
2020, largely due to the operations and
maintenance costs resulting from the
delivery of capital projects funded in
prior years.
VI. Capital Budget
Overview
Annually, the NCUA uses a rigorous
investment review process to identify
the agency’s needs for information
technology (IT), facility improvements
and repairs, and other multi-year capital
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investments. The NCUA staff review the
agency’s inventory of owned facilities,
equipment, information technology
systems, and information technology
hardware to determine what requires
repair, major renovation, or
replacement. The staff then make
recommendations for prioritized
investments to the Executive Director
and the NCUA Board.
Routine repairs and lifecycle-driven
property renovations are necessary to
properly maintain investments in the
NCUA’s central office building in
Alexandria, Virginia and the agency’s
owned office building in Austin, Texas.
The NCUA facility manager assesses the
agency’s properties to determine the
need for essential repairs, replacement
of building systems that have reached
the end of their engineered lives, or
renovations required to support changes
in the agency’s organizational structure
or to address revisions to building
standards and codes.
IT systems and hardware are another
significant capital expenditure for
modern organizations. The 2019 budget
allowed the NCUA to deliver and
deploy a number of cybersecurity and
governance tools, and the first iteration
of ESM with several projects included,
such as the first release of MERIT in
2019. The 2020 budget maintains the
investment in current and replacement
IT systems.
The budget fully supports the NCUA’s
effort to modernize its IT infrastructure
and applications, including the full
rollout of MERIT, the NCUA’s
Examination and Supervision Solution
(ESS) project, which will replace the
legacy Automated Integrated Regulatory
Examination System (AIRES) system.
Other IT investments include ongoing
enhancements and upgrades to enhance
decades-old legacy systems, network
servers, incident and vulnerability
management systems to enhance the
agency’s cybersecurity posture, and
various hardware investments to refresh
agency networks and ensure staff have
the tools necessary to maintain and
increase their productivity.
The NCUA’s 2020 capital budget is
$25.1 million. The capital budget funds
the NCUA’s long-term investments. The
Information Technology Prioritization
Council recommended $20.9 million for
IT software development projects and
$2.7 million in other IT investments for
2020. The NCUA facilities require $1.5
million in capital investments. Detailed
descriptions of all 2020 capital projects,
including a discussion of how each
project helps the agency achieve its
strategic goals and objectives, are
provided in Appendix B.
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Summary of Capital Projects
Examination and Supervision Solution
and Infrastructure Hosting ($15.8
Million)
The purpose of the Examination and
Supervision Solution and Infrastructure
Hosting (ESS&IH) project is to
implement a new, flexible, technical
foundation to enable current and future
NCUA business process modernization
initiatives, and replace the NCUA’s
legacy exam system, AIRES, with a new
customized Commercial-Off-The-Shelf
(COTS) solution. In 2020, all NCUA
examiners will be trained to use the new
MERIT system, with full
implementation expected by the fourth
quarter.
Enterprise Central Data Repository ($1.1
Million)
The Enterprise Central Data
Repository (ECDR) project will
implement a central data repository that
will serve as the data integration point
for ESS, ONES’s analytic tools, the
NCUA’s legacy applications and the
Data Collection Solution (DCS). The
ECDR will become an enterprise
solution for the NCUA allowing the
agency to transition in a phased
approach from the existing legacy
databases to a cloud-based data
repository serving the agency’s needs.
Enterprise Data Program ($0.45 Million)
The purpose of this project is the
centralization, organization and storage
of the NCUA data. The primary goal is
to enable the NCUA to manage
enterprise data as a strategic asset
through its full lifecycle (create/collect,
manage/move, consume, dispose). The
Enterprise Data Program (EDP) will also
facilitate the centralization and
organization of the NCUA’s data with an
authoritative source so analysis is more
accurate, simple and easily distributed
across the agency.
Asset and Liabilities Management
Application ($2.1 Million)
The purpose of the Asset and
Liabilities Management (ALM)
application is for the NCUA to build
internal analytical capabilities to run
supervisory stress testing in house and
to conduct regular quantitative risk
assessments by procuring and
configuring off-the-shelf analytical tools,
models and software used commonly in
stress testing and other risk management
activities.
This effort delivers a complete
solution that will focus on modernizing
the NCUA’s supervision tools and
approaches, identifying material risks
facing the covered credit unions, and
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tailoring resources to the material risks
and risk focused exams. This effort will
allow the NCUA to reduce the existing
third party contractor’s role to only
consultation.
Enterprise Learning Management
System Replacement ($1.0 Million)
The purpose of the Enterprise
Learning Management System (LMS)
Replacement project is to conduct
market research, initiate an acquisition,
create a project management plan, and
execute the production and
implementation of a cost-effective,
cloud-based solution and training
services that provides the NCUA with
the full-range of eLearning functionality
associated with a modern LMS. This
will allow for enhanced examiner
utilization and accessibility driven by
quality content, ease of use and system
reliability, role-based interface, ability
to view personalized pages by role,
centralized content and, adherence to
federally mandated reporting
requirements and records management
requirements.
Integrated Financial Management
System Analysis ($0.4 Million)
The purpose of this project is to
analyze financial system improvements.
The NCUA’s current financial
management system service provider
increased the fee it charges the NCUA
in 2019 by 40 percent. The NCUA plans
to review various options to obtain
better financial management results in a
cost-effective manner.
Enterprise Laptop Lease ($0.65 Million)
The purpose of the Enterprise Laptop
Refresh project is to provide the NCUA
with a more efficient, mobile friendly,
and secure tool to help employees better
perform their jobs at a reasonable cost.
Information Technology Infrastructure,
Platform and Security Refresh ($2.0
Million)
The purpose of the Information
Technology (IT) Infrastructure, Platform
and Security Refresh project is to refresh
and/or replace routers, switches virtual
servers, wireless, virtual private
network, infrastructure appliances, end
of life and end of service components in
order to ensure that the NCUA data is
secure and operations are stable.
NCUA Website Development ($0.1
Million)
The purpose of the Web Services
project is to serve the web-related needs
of the internal NCUA stakeholders and
the public. The project provides design,
development, and maintenance of the
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agency’s public websites: NCUA.gov
and MyCreditUnion.gov.
Central Office Renovations ($0.5
Million)
NCUA headquarters renovation
project will improve overall space
utilization in the NCUA-owned Central
Office. The goal of the project is to
improve operational efficiency while
decreasing operating cost by
discontinuing commercial office leases
and consolidating all Washington-region
operations within one owned building.
The project will increase the NCUA
headquarters building capacity and
some offices currently on separate floors
will be collocated onto one floor,
increasing operational efficiency.
Central Office Heating, Ventilation, and
Air Conditioning (HVAC) System
Replacement ($0.75 Million)
The NCUA central office HVAC
system replacement project will
recapitalize the HVAC system in the
agency’s central office building,
including all cooling towers, air
handlers, boilers and HVAC
components. The current HVAC system
is original to the facility, 24 years old
and obsolete. The current system is at
the end of its usable life and it is not
working efficiently.
Austin, Texas Office Building
Modernization ($0.27 million)
In 2020, the NCUA will continue its
multi-year improvement project at the
Austin, Texas office building. These
capital improvements are required for
the facility to continue routine and safe
operations, and align with the lifecycle
replacement required for critical
infrastructure.
VII. Share Insurance Fund
Administrative Budget
Overview
The Share Insurance Fund
Administrative budget funds direct
costs associated with authorized Share
Insurance Fund activities. The direct
charges to the Share Insurance Fund
include costs associated with the NCUA
Guaranteed Note (NGN) program and
administrative costs, and represent total
estimated costs to the Share Insurance
Fund.10 The Share Insurance Fund
Administrative budget funds five
10 Note these direct costs are exclusive of any
costs that are shared with the Operating Fund
through the Overhead Transfer Rate, and with
payments available upon requisition by the Board,
without fiscal year limitation, for insurance under
section 1787 of this title, and for providing
assistance and making expenditures under section
1788 of this title in connection with the liquidation
or threatened liquidation of insured credit unions
as it may determine to be proper.
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59151
positions that were formerly part of the
Temporary Corporate Credit Union
Stabilization Fund (Stabilization Fund)
budget.
The cost of the NGN program and the
Corporate System Resolution Program,
including costs associated with the
administration of those programs, are
funded from the Share Insurance Fund
Administrative budget. These costs have
no impact on the NCUA’s current and
future Operating Fund budgets. The
budget for the Share Insurance Fund
also includes funding for expenditures
previously authorized as direct
expenses of the Share Insurance Fund
for items such as state examiner
computer leases, training and financial
audit support.
The 2020 Share Insurance Fund
Administrative budget is estimated to be
$6.5 million, $1.9 million, or 23 percent,
less than 2019. The budget decrease is
primarily driven by the removal of
third-party stress testing on large credit
unions and the decrease in costs for
valuation services for the NGN program.
These services enable the NCUA to
continue supporting the NGN program,
which includes managing legacy assets
within the NGN trusts. Legacy assets
consist of over 1,000 investment
securities that are secured by residential
mortgages and other assets.
The 2021 requested budget supports
similar workload and resources,
increasing $482,000, or 7.5 percent,
compared to the 2020 funding level.
Budget Category Descriptions and Major
Changes
Salaries and Benefits
The employee pay and benefits
expense category for the Share
Insurance Fund Administrative budget
is estimated to be $1.47 million, which
represents an increase of $232,000
compared to 2019. This increase is due
to aligning the budget to actual payroll
costs for staff on board, as well as an
increase to mandatory agency
contribution rates to the FERS
retirement program. Personnel
compensation is 23 percent of the total
budget. The financial analysts on the
NGN team have specialized technical
expertise to manage the remaining $6
billion of legacy assets. Personnel costs
are estimated in a manner similar to the
operating budget.
Travel
The estimated travel cost of $52,000 is
less than one percent of the overall 2019
budget and remains the same as the
2020 budget estimate. These costs cover
all of the travel expenses for the five
staff that manage and support the NGN
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program. Two of the five staff are remote
employees and are expected to travel
periodically to the NCUA’s central
office.
Administrative Training
Training expenses, which represent
less than one percent of the budget, are
estimated to be remain at $27,000, based
on projections of employee professional
development plans and specialized
training requirements.
Support for the NGN Program (Contract
Support)
Contract costs to support the NGN
program, which represent 42 percent of
the budget, are estimated to be $2.7
million, a decrease of $0.2 million from
the 2019 level. Funding is needed to
fulfill Corporate System Resolution
Program requirements and includes
outside professional services such as
external valuation experts, financial
specialists, and accountants.
These experts assist the NCUA with
the following services:
Consulting Services in the amount of
$1.0 million support two NCUA offices:
Examination and Insurance and the
Chief Financial Officer. Services include
quarterly management reviews of asset
valuations, as well as analyses of
emerging issues. Contractors also
provide support for the annual financial
audit process and improvements in
internal controls. Tasks include:
Supporting complex accounting and
financial requirements for settlements,
sale of legacy assets, parity payments,
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changing valuation model assumptions,
and other asset disposition activities.
Additionally, professional services are
used to assist with accounting, tax,
financial reporting, and systems support
for the corporate Asset Management
Estates.
Valuation Services in the amount of
$0.9 million funds valuation support for
the NGN legacy assets. As supported by
the NGN Oversight Committee,
resources are also needed to conduct
special analyses, including valuations
for determining reasonable market
prices for securities to be sold by
auction.
Software and Data Subscription
Services in the amount of $0.8 million
supports technical tools used to provide
waterfall models, calculations, and
metrics for the structured investment
products underlying the NGN portfolio.
The service provides coverage of all
relevant asset classes, waterfall models
that are seasoned and tested throughout
the industry, and a broad array of
calculations and metrics. Financial data
analytics play a critical role in the
surveillance, modeling, and pricing of
the legacy assets that securitize the NGN
Trusts, as well as supporting the
management reviews that the NCUA
performs on the cash flow projections.
Now that some of the NGNs have begun
maturing, the NCUA has added data
subscription services to provide
additional valuation as well as support
for the legacy asset disposition process.
Other annual subscriptions provide
important services related to
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surveillance of the portfolio of corporate
bonds and mortgage-related bonds.
Independent credit research services
include fundamental capital structure
research, credit analyses for surveillance
of corporate bond portfolio and
monoline insurer exposure, and direct
access to various industry experts for
discussion on specific credits.
Other Direct Expenses
Other direct expenses of the Share
Insurance Fund are estimated to be $2.2
million in 2020, a decrease of $1.9
million, or 47 percent, compared to the
2019 budget level. NCUA is required to
conduct annual stress testing of certain
large credit unions to ensure the credit
unions remain financially sound
through challenging economic cycles. In
previous years the NCUA engaged
BlackRock Solutions as its partner to
challenge the stress test results prepared
by the covered credit unions. Over a
multi-year endeavor, the NCUA has
procured the personnel, data, and
systems to conduct this analysis
internally. Accordingly, the NCUA has
determined it will not engage BlackRock
Solutions for the 2020 stress test cycle
and has removed this cost from the
budget. Had BlackRock been engaged for
the 2020 cycle, the agency would have
incurred $3 million in costs.
The $0.7 million increase in the
estimated costs for state examiner
training is driven by the MERIT travel
and training requirement.
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BILLING CODE 7535–01–C
The NCUA website has a dedicated
section that provides financial reports
for the Share Insurance Fund, 11 and a
separate page that explains the NCUA
Guaranteed Notes Program and provides
11 See: https://www.ncua.gov/services/Pages/
share-insurance/reports.aspx.
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comprehensive reporting and analysis
on the legacy assets.12
VIII. Financing the NCUA Programs
Overview
As part of the annual budgetary
process, the NCUA remains mindful
that its operating funding comes directly
12 See: https://www.ncua.gov/regulationsupervision/Pages/guaranteed-notes.aspx.
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from federal and state chartered credit
unions. The agency strives to ensure
that any allocation of these funds
follows a thorough review of the
necessity of the expenditures and
whether programs are operating in an
efficient, effective, transparent, and
fully accountable manner.
To achieve its statutory mission, the
NCUA incurs various expenses,
including those involved in examining
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and supervising federally insured credit
unions. The NCUA Board adopts an
Operating Budget, including the Capital
Budget, in the fall of each year to fund
the vast majority of the costs of
operating the agency.13 The Federal
Credit Union Act authorizes two
primary sources to fund the Operating
Budget:
(1) Requisitions from the Share
Insurance Fund ‘‘for such
administrative and other expenses
incurred in carrying out the purposes of
[Title II of the Act] as [the Board] may
determine to be proper’’; 14 and
(2) ‘‘fees and assessments (including
income earned on insurance deposits)
levied on insured credit unions under
[the Act].’’ 15 Among the fees levied
under the Act are annual Operating
Fees, which are required for federal
credit unions under 12 U.S.C. 1755
‘‘and may be expended by the Board to
defray the expenses incurred in carrying
out the provisions of [the Act,]
including the examination and
supervision of [federal credit unions].’’
Taken together, these dual authorities
effectively require the Board to
determine which expenses are
appropriately paid from each source
while giving the Board broad discretion
in allocating expenses.
In 1972, the Government
Accountability Office recommended the
NCUA adopt a method for properly
allocating Operating Budget costs—that
is, the portion of the NCUA’s budget
funded by requisitions from the Share
Insurance Fund and the portion covered
by Operating Fees paid by federal credit
unions.16 The NCUA has since used an
allocation methodology, known as the
Overhead Transfer Rate (OTR), to
determine how much of the Operating
Budget to fund with a requisition from
the Share Insurance Fund.
To allocate agency expenses between
these two primary funding sources, the
NCUA uses the OTR methodology. The
OTR is the formula the NCUA uses to
allocate insurance-related expenses to
the Share Insurance Fund under Title II.
Almost all other operating expenses are
13 Some costs are directly charged to the Share
Insurance Fund when appropriate to do so. For
example, costs for training and equipment provided
to State Supervisory Authorities are directly
charged to the Share Insurance Fund.
14 12 U.S.C. 1783(a).
15 12 U.S.C. 1766(j)(3). Other sources of income
for the Operating Budget have included interest
income, funds from publication sales, parking fee
income, and rental income.
16 https://www.gao.gov/assets/210/203181.pdf.
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collected through annual Operating Fees
paid by federal credit unions.17
Two statutory provisions directly
limit the Board’s discretion with respect
to Share Insurance Fund requisitions for
the NCUA’s Operating Budget and,
hence, the OTR. First, expenses funded
from the Share Insurance Fund must
carry out the purposes of Title II of the
Act, which relate to share insurance.18
Second, the NCUA may not fund its
entire Operating Budget through charges
to the Share Insurance Fund.19 The
NCUA has not imposed additional
policy or regulatory limitations on its
discretion for determining the OTR.
Overhead Transfer Rate (OTR)
The NCUA Board approved the
current methodology for calculating the
OTR at its November 2017 open
meeting.20 The OTR is designed to cover
the NCUA’s costs of examining and
supervising the risk to the Share
Insurance Fund posed by all federally
insured credit unions, as well as the
costs of administering the fund. The
OTR represents the percentage of the
agency’s operating budget paid for by a
transfer from the Share Insurance Fund.
Federally insured credit unions are not
billed for, and do not have to remit, the
OTR amount; instead, it is transferred
directly to the Operating Fund from the
Share Insurance Fund. This transfer,
therefore, represents a cost to all
federally insured credit unions.
The OTR formula is based on the
following underlying principles to
allocate agency operating costs:
1. Time spent examining and
supervising federal credit unions is
allocated as 50 percent insurance
related.21
17 Annual Operating Fees must ‘‘be determined
according to a schedule, or schedules, or other
method determined by the NCUA Board to be
appropriate, which gives due consideration to the
expenses of the [NCUA] in carrying out its
responsibilities under the [Act] and to the ability of
[FCUs] to pay the fee.’’ 12 U.S.C. 1755(b).
18 12 U.S.C. 1783(a).
19 The Act in 12 U.S.C. 1755(a) states, ‘‘[i]n
accordance with rules prescribed by the Board, each
[federal credit union] shall pay to the [NCUA] an
annual operating fee which may be composed of
one or more charges identified as to the function or
functions for which assessed.’’ See also 12 U.S.C.
1766(j)(3).
20 82 FR 55644 (Nov. 22, 2017).
21 The 50 percent allocation mathematically
emulates an examination and supervision program
design where the NCUA would alternate
examinations, and/or conduct joint examinations,
between its insurance function and its prudential
regulator function if they were separate units within
the NCUA. It reflects an equal sharing of
supervisory responsibilities between the NCUA’s
dual roles as charterer/prudential regulator and
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2. All time and costs the NCUA
spends supervising or evaluating the
risks posed by federally insured, statechartered credit unions or other entities
that the NCUA does not charter or
regulate (for example, third-party
vendors and CUSOs) are allocated as
100 percent insurance related.22
3. Time and costs related to the
NCUA’s role as charterer and enforcer of
consumer protection and other noninsurance based laws governing the
operation of credit unions (like field of
membership requirements) are allocated
as 0 percent insurance related.23
4. Time and costs related to the
NCUA’s role in administering federal
share insurance and the Share Insurance
Fund are allocated as 100 percent
insurance related.24
These four principles are applied to
the activities and costs of the agency,
which results in the portion of the
agency’s Operating Budget that is
transferred from the Share Insurance
Fund. Based on the Board–approved
methodology, the OTR for 2020 is
modestly higher than 2019, and
estimated to be 61.3 percent. Thus, 61.3
percent of the total Operating Budget is
estimated to be paid out of the Share
Insurance Fund. The remaining 38.7
percent of the Operating Budget is
estimated to be paid for through the
Operating Fee. The explicit and implicit
distribution of total Operating Budget
costs for federal credit unions and
federally insured, state-chartered credit
unions is as follows:
insurer given both roles have a vested interest in the
safety and soundness of federal credit unions. It is
consistent with the alternating examinations the
FDIC and state regulators conduct for insured statechartered banks as mandated by Congress. Further,
it reflects that the NCUA is responsible for
managing risk to the Share Insurance Fund and
therefore should not rely solely on examinations
and supervision conducted by the prudential
regulator.
22 The NCUA does not charter state-chartered
credit unions nor serve as their prudential
regulator. The NCUA’s role with respect to federally
insured state-chartered credit unions is as insurer.
Therefore, all examination and supervision work
and other agency costs attributable to insured statechartered credit unions is allocated as 100 percent
insurance related.
23 As the federal agency with the responsibility to
charter federal credit unions and enforce noninsurance related laws governing how credit unions
operate in the marketplace, the NCUA resources
allocated to these functions are properly assigned
to its role as charterer/prudential regulator.
24 The NCUA conducts liquidations of credit
unions, insured share payouts, and other resolution
activities in its role as insurer. Also, activities
related to share insurance, such as answering
consumer inquiries about insurance coverage, are a
function of the NCUA’s role as insurer.
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59155
Federal credit
unions
(percent)
Federal Credit Union Operating Fee ...............................................................................................
OTR × Percent of Insured Shares ...................................................................................................
38.7
31.3 (61.3 × 51.1)
0.0
30.0 (61.3 × 48.9)
Total ..........................................................................................................................................
70.0
30.0
In terms of accounting for funds
transferred from the Share Insurance
Fund to the Operating Fund, the OTR is
applied to actual expenses incurred
each month. Therefore, the rate
calculated by the OTR formula is
multiplied by each month’s actual
operating expenses and charged to the
Share Insurance Fund. Because of this
monthly reconciliation to actual
operating expenditures, when the
NCUA’s expenditures are less than
budgeted, the amount charged to the
Share Insurance Fund is also less—and
those lower expenditures benefit both
federally chartered and state charted
credit unions.
The following chart illustrates the
share of the Operating Budget paid by
federal credit unions (FCUs, 70.0%) and
federally insured, state-chartered credit
unions (FISCUs, 30.0%).
The Board delegated authority to the
Chief Financial Officer to administer the
methodology approved by the Board for
calculating the Operating Fees, and to
set the fee schedule as calculated per
the approved methodology outlined in
this section. There is no change to the
underlying approved Operating Fee
methodology for 2020; the change in the
assessments for 2020 are due to changes
in the OTR rate and to indexing the fee
schedule for projected asset growth.
For 2020, based on the OTR
methodology discussed above, the
resulting share of the budget that is
funded from the Operating Fee is $144.8
million. This equates to 0.0181 percent
of the estimated federal credit union
assets for December 2019. The overall
increase for the operating fee is 1.2
percent over 2019.
The Operating Fee will be assessed to
federal credit unions based on estimated
year-end assets. Credit unions with
assets less than $1 million will not be
assessed an Operating Fee. To set the
assessment scale for 2020, federal credit
union asset growth will be projected
through December 31, 2019. Based on
the June 30, 2019, Call Report data,
annual growth is projected to be 5.6
percent at year end. The asset level
dividing points will be increased by this
same projected growth rate. Assets are
indexed annually to preserve the same
relative relationship of the scale to
applicable asset base.
To establish the rate applicable to
each asset level, the factors outlined in
the table below result in an average
Operating Fee rate increase of 1.2
percent for natural person federal credit
unions. The corporate federal credit
union rate scale remains unchanged
from prior years.
To illustrate the rate impact for
federal credit unions with assets under
$1.5 billion, the fee increases from
$269.4 per million dollars of assets, to
$272.7 per one million dollars of assets.
This is an increase of $3.3 per million
dollars of assets, or 1.2 percent.
Federal credit union assets between
$1.5 billion and $4.8 billion would be
assessed at a rate of $79.48 per million,
and assets above $4.8 billion would be
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Federally insured,
state-chartered
credit unions
(percent)
Est. share of the operating budget covered by:
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assessed at $26.54 per million. As noted
above, these tiers were indexed to the
5.6 percent projected asset growth, and
the rates are increased by 1.2 percent.
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The following tables illustrate the
methodology and calculations used to
develop the Operating Fee.
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IX. Appendix A: Supplemental Budget
Information
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X. Appendix B. Capital Projects
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[FR Doc. 2019–23856 Filed 10–31–19; 8:45 am]
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Agencies
[Federal Register Volume 84, Number 212 (Friday, November 1, 2019)]
[Notices]
[Pages 59126-59192]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-23856]
[[Page 59125]]
Vol. 84
Friday,
No. 212
November 1, 2019
Part V
National Credit Union Administration
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The NCUA Staff Draft 2020-2021 Budget Justification; Notice
Federal Register / Vol. 84 , No. 212 / Friday, November 1, 2019 /
Notices
[[Page 59126]]
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NATIONAL CREDIT UNION ADMINISTRATION
The NCUA Staff Draft 2020--2021 Budget Justification
AGENCY: National Credit Union Administration (NCUA).
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The NCUA's draft, ``detailed business-type budget'' is being
made available for public review as required by federal statute. The
proposed resources will finance the agency's annual operations and
capital projects, both of which are necessary for the agency to
accomplish its mission. The briefing schedule and comment instructions
are included in the supplementary information section.
DATES: Requests to deliver a statement at the budget briefing must be
received on or before Tuesday, November 12, 2019. In order for the NCUA
to produce copies for public distribution at the budget briefing,
written statements and presentations for those scheduled to appear at
the budget briefing must be received on or before Monday, November 18,
2019.
Written comments without public presentation at the budget briefing
may be submitted by Monday, December 2, 2019.
ADDRESSES: You may submit comments by any of the following methods
(Please send comments by one method only):
Presentation at public budget briefing: submit requests to
deliver a statement at the briefing to ncua.gov">[email protected]ncua.gov by
Tuesday, November 12, 2019. Include your name, title, affiliation,
mailing address, email address, and telephone number. Copies of your
presentation must be submitted to the same email address by Monday,
November 18, 2019.
Written comments: submit comments to
ncua.gov">[email protected]ncua.gov by Monday, December 2, 2019. Include your name
and the following subject line ``Comments on the NCUA Draft 2020-2021
Budget Justification.''
Copies of the NCUA Draft 2020-2021 Budget Justification and
associated materials are also available on the NCUA website at https://www.ncua.gov/About/Pages/budget-strategic-planning/supplementary-materials.aspx. Printed copies will be available at the November 20,
2019 budget briefing.
FOR FURTHER INFORMATION CONTACT: Rendell Jones, Chief Financial
Officer, National Credit Union Administration, 1775 Duke Street,
Alexandria, Virginia 22314-3428 or telephone: (703) 518-6571.
SUPPLEMENTARY INFORMATION: The following itemized list details the
documents attached to this notice and made available for public review:
I. The NCUA Budget in Brief
II. Introduction and Strategic Context
III. Forecast and Enterprise Challenges
IV. Key Themes of the 2020-2021 Budget
V. Operating Budget
VI. Capital Budget
VII. Share Insurance Fund Administrative Budget
VIII. Financing The NCUA Programs
IX. Appendix A: Supplemental Budget Information
X: Appendix B: Capital Projects
Section 212 of the Economic Growth, Regulatory Relief, and Consumer
Protection Act (Pub. L. 115-174) amended 12 U.S.C. 1789(b)(1)(A) to
require the NCUA Board (Board) to ``make publicly available and publish
in the Federal Register a draft of the detailed business-type budget.''
Although 12 U.S.C. 1789(b)(1)(A) requires publication of a ``business-
type budget'' only for the agency operations arising under the Federal
Credit Union Act's subchapter on insurance activities, in the interest
of transparency the Board is providing the agency's entire staff draft
2020-2021 Budget Justification (budget) in this Notice.
The draft budget details the resources required to support NCUA's
mission as outlined in its 2018-2022 Strategic Plan. The draft budget
includes personnel and dollar estimates for three major budget
components: (1) The Operating Budget; (2) the Capital Budget; and (3)
the Share Insurance Fund Administrative Budget. The resources proposed
in the draft budget will be used to carry out the agency's annual
operations.
The NCUA staff will present its draft budget to the Board at a
budget briefing open to the public and scheduled for Wednesday,
November 20, 2019 from 10:00 a.m. to 12:00 p.m. Eastern. The budget
briefing will be held in the NCUA Board meeting room. A livestream of
the briefing also will be available through a link on ncua.gov.
If you wish to attend the briefing and deliver a statement, you
must email a request to ncua.gov">[email protected]ncua.gov by Tuesday, November
12, 2019. Your request must include your name, title, affiliation,
mailing address, email address, and telephone number. The NCUA will
work to accommodate as many public statements as possible at the
November 20, 2019 budget briefing. The Board Secretary will inform you
if you have been approved to make a presentation and how much time you
will be allotted. A written copy of your presentation must be delivered
to the Board Secretary via email at ncua.gov">[email protected]ncua.gov by Monday,
November 18, 2019.
Written comments on the draft budget will also be accepted by email
at ncua.gov">[email protected]ncua.gov until Monday, December 2, 2019. Include your
name and the following subject line with your comments: ``Comments on
the NCUA Draft 2020-2021 Budget Justification.''
All comments should provide specific, actionable recommendations
rather than general remarks. The Board will review and consider any
comments from the public prior to approving the budget.
By the National Credit Union Administration Board on October 28,
2019.
Gerard S. Poliquin,
Secretary of the Board.
I. The NCUA Budget in Brief
Proposed 2020 and 2021 Budgets
The National Credit Union Administration's (NCUA) 2018-2022
Strategic Plan sets forth the agency's goals and objectives that form
the basis for determining resource needs and allocations. The annual
budget provides the resources to execute the strategic plan, to
implement important initiatives, and to undertake the NCUA's major
programs: Examination and supervision, insurance, credit union
development, consumer financial protection, and asset management.
[[Page 59127]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.022
The NCUA's 2020-2021 budget justification consists of three
separate budgets: The Operating Budget, the Capital Budget, and the
National Credit Union Share Insurance Fund Administrative Budget.
Combined, these three budgets total $347.7 million for 2020, which is
1.1 percent more than the 2020 funding level approved by the NCUA Board
in November 2018, and 3.9 percent more than the comparable 2019 Board-
approved budget.
A significant cost driver in the 2020 budget is the increase in
mandatory contributions all federal agencies must make to the Office of
Personnel Management (OPM) for the Federal Employee Retirement System
(FERS). Of the total 3.9 percent budget increase between 2019 and 2020,
1.6 percentage points of growth are directly attributable to the
increased cost of FERS contributions and 2.3 percentage points of
growth are the result of changes in agency operations.
The 2.3 percent growth in agency operations also includes absorbing
the equivalent of 0.8 percentage points of growth for costs avoided in
the Share Insurance Fund Administrative Budget. This means the actual
budget increase to fund the agency's operations is the equivalent of
1.5 percent growth.
Personnel levels for 2020 and 2021 reflect the agency's current
staffing requirements and proposed staffing enhancements related to
high-priority initiatives.
Operating Budget
The proposed 2020 Operating Budget is $316.2 million. Personnel
levels increase by three full-time equivalents (FTE) compared to the
2019 Board-approved budget.\1\
---------------------------------------------------------------------------
\1\ The published 2019 FTE level approved by the Board on
November 15, 2018 was 1,173 for the Operating Budget. On July 18,
2019, the NCUA Board approved an additional four FTE. The revised
2020 Operating Budget proposes three more FTE, for a total of 1,180.
---------------------------------------------------------------------------
The 2020 Operating Budget, when adjusted for inflation, represents
a real dollar increase of approximately $5.2 million, or 1.7 percent,
compared to the 2019 Board-approved budget. In nominal dollars, the
2019 Budget increases by $11.8 million, or 3.9 percent, over the 2019
Board-approved budget of $304.4 million. The Operating Budget estimate
for 2021 is $326 million and reflects no change to authorized
positions.
The following chart shows recent year-on-year trends for the NCUA
Operating Budget, in both real dollar and nominal terms:
[[Page 59128]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.023
The following chart presents the major categories of spending
supported by the 2020 budget, while specific adjustments to the 2019
Board-approved budget are discussed in further detail, below:
[GRAPHIC] [TIFF OMITTED] TN01NO19.024
Total Staffing. The budget supports 1,185 FTE in total for 2020, of
which five are funded by the Share Insurance Fund Administrative
Budget. The Operating Budget funds 1,180 FTE in 2020, a net increase of
three FTEs from the 2019 levels approved by the Board. Additional staff
have been added to several offices as discussed later in this document.
Since 2018 and despite significant credit union asset growth, total
NCUA staffing has remained
[[Page 59129]]
within a range of approximately five positions, as shown in the chart
below.
[GRAPHIC] [TIFF OMITTED] TN01NO19.025
Pay and Benefits. Pay and benefits increase by $8.5 million in
2020, or 3.8 percent, for a budget of $231.4 million. Over 50 percent
of the growth in pay and benefits--nearly $5 million--is the result of
OPM increasing the mandatory employer contribution for the FERS.
Required FERS payments to OPM increase from 13.7 percent of covered
employees' salaries to 16 percent, a change of 230 basis points. Nearly
all NCUA employees are covered by FERS, which includes a defined
pension benefit funded by both employee and employer contributions.
Because almost every federal agency is required to participate in FERS,
the employer share of contributions increases throughout the government
in 2020. Excluding additional FERS contributions from the 2020 budget,
total personnel compensation growth would be 1.6 percent instead of 3.8
percent, and total Operating Budget growth would be 2.2 percent instead
of 3.9 percent.
The remaining increase in pay and benefits accounts for the merit
and locality pay adjustments required by the NCUA's current collective
bargaining agreement, the three new positions proposed for 2020,
anticipated staff promotions, position changes, and increased costs for
other mandatory employer contributions such as health insurance and
retirement contributions.
Travel. The travel budget increases by $590,000 in 2020, or 2.2
percent, for a budget of $27.4 million. In 2020, the NCUA plans to
train its Credit Union Examiner workforce to conduct examinations using
the Modern Examination and Risk Identification Tool (MERIT) system,
which is planned for full implementation in the fourth quarter of 2020.
State credit union examiners will also be trained to use MERIT. The
Operating Budget includes approximately $1.0 million in one-time travel
costs associated with the 778 NCUA employees who will participate in
MERIT training meetings in 2020.
In general, the NCUA continues working to contain the growth of
travel costs by expanding offsite examination work and using
technology-driven training. Government-wide per diem rates published by
the General Services Administration (GSA) are expected to increase by
almost 1.3 percent in 2020, accounting for a share of the travel budget
growth. In addition, starting in 2019 GSA instituted a cost recovery
fee for airline tickets purchased at negotiated government rates, which
adds approximately $20,000 annually to the agency's cost of purchasing
airline tickets at government rates.
Rent, Communications, and Utilities. Rent, communications, and
utilities increase by $188,000 in 2020, or 2.3 percent, for a budget of
$8.2 million. This funding pays for telecommunications services, data
capacity contracts, and information technology network support. The
increase is primarily due to additional data capacity that will be
required as a result of implementing the new MERIT examination system,
which will be cloud-based and consume more data bandwidth than the
AIRES system it is replacing.
Administrative Expenses. Administrative expenses decrease by $2.8
million in 2020, or 31.9 percent, for a total budget of $5.9 million.
Decreases to the administrative expenses budget category largely result
from reclassifying $2.6 million in software licensing costs as
contracted services, not administrative expenses, in order to reflect
these costs consistently with other federal budgetary presentations.
Contracted Services. Contracted services expenses increase by $5.3
million in 2020 for a total budget of $43.3 million. However, as
discussed above, approximately $2.6 million of this increase results
from costs previously shown as administrative expenses being
reclassified as contracted services in order to reflect these costs
consistently with other federal budgetary presentations. The actual
increase in the contracted services budget is approximately $2.7
million, or 7 percent.
Contracted services funding pays for products and services acquired
in the commercial marketplace, and includes critical mission support
services such as information technology hardware and software support,
accounting and auditing services, and specialized subject matter
expertise. Certain information technology costs that were previously
reported as administrative expenses are now included as contracted
services, which accounts for a portion of this increase. Expected price
inflation for services to be purchased in 2020 accounts for the
[[Page 59130]]
remainder of the growth in this category.
Capital Budget. The proposed 2020 Capital Budget is $25.1 million.
The 2020 Capital Budget is $6.5 million more than the 2020 funding
level approved by the Board in November 2018, and $3.1 million than the
2019 Board-approved budget.
The Capital Budget pays for continued investments in technology and
infrastructure projects. A major component of the Capital Budget is the
development of the first phases of the Enterprise Solution
Modernization (ESM) program, which includes a new technical platform
and security infrastructure, a central user interface for stakeholders
to transact business with the NCUA, integration of business
intelligence tools into the supervision function, and the MERIT
examination system, which will replace the agency's antiquated AIRES
examination software and will be used by both federal and state
examiners in almost all credit union examinations. The business
intelligence capabilities were slated for a later iteration of ESM, but
were added to the first phase when it was determined they could be
integrated into MERIT for the 2020 release. The NCUA's Information
Technology Prioritization Council recommended $20.9 million for IT
software development projects that continue to replace the NCUA's
decades-old and functionally obsolete information technology systems,
and $2.7 million in other IT investments for 2020. The NCUA's
facilities require $1.5 million in capital investments.
Share Insurance Fund Administrative Expenses. The proposed 2020
Share Insurance Fund Administrative budget is $6.5 million.
The 2020 Share Insurance Fund (SIF) Administrative Budget is $2.7
million less than the 2020 funding level approved by the Board in
November 2018, and $1.9 million less than the 2019 Board-approved
budget. The decrease in the SIF Administrative Budget is primarily
attributed to the Office of National Examinations and Supervision plan
to oversee credit union-run stress testing for the largest Credit
Unions using its own proprietary models in 2020. Direct charges within
this budget include administration of the NCUA Guaranteed Note (NGN)
program, state examiner training and laptop leases, as well as
financial audit support. The reduction in the SIF Administrative
Expenses budget reflects that costs related to the oversight of credit
union-run stress testing will be financed by the Operating Budget.
Budget Trends.
As shown in the chart below, the relative size of the NCUA budget
continues to decline when compared to balance sheets at federally
insured credit unions. This trend illustrates the greater operating
efficiencies the NCUA has attained in the last several years relative
to the size of the credit union system. Additionally, the NCUA has
improved its operating efficiencies more aggressively than other
financial industry regulators.
[GRAPHIC] [TIFF OMITTED] TN01NO19.026
It is also notable that the NCUA's operations have become more
efficient relative to the size of the credit union system because
consolidation in the industry has led to growth in the number of large
credit unions, specifically those with more than $10 billion in assets.
This results in additional complexity in the balance
[[Page 59131]]
sheets of such credit unions, and a corresponding increase in the
supervisory review required to ensure the safety and soundness of such
large institutions. The NCUA has responded to this increasing
complexity through several initiatives: Creation of the specialized
Office of National Examination and Supervision, development of in-house
capabilities to oversee large credit unions' stress testing, use of
specialist examiners with expertise in cybersecurity and capital
markets, and improved quality of examination reports through enhanced
quality review processes.
Federal Compliance Cost Burden
As a federal agency, the NCUA is required to devote significant
resources to numerous compliance activities required by federal law,
regulations, or, in some cases, Executive Orders. These requirements
dictate how many of the agency's activities are implemented, and
generally result in increasing costs. These compliance activities
require additional effort in areas such as information technology
acquisitions and management, human capital processes, financial
management processes and reporting, privacy compliance, and physical
and cyber security programs. While agency managers are responsible for
these activities, required compliance activities add additional layers
of review and procedures that make processes more challenging and
expensive.
Financial Management
Federal law, regulations, and government-wide guidance promulgated
by the Office of Management and Budget (OMB), the Government
Accountability Office (GAO), and the Department of the Treasury place
numerous requirements on federal agencies including the NCUA regarding
the management of public funds. Government-wide financial management
compliance requirements include: Financial statement audits, improper
payments, prompt payments, internal controls, procurement, audits,
enterprise risk management, strategic planning, and public reporting of
financial and other information.
Information Technology (IT)
There are numerous laws, regulations and required guidance
concerning information technology used by the federal government. Many
of the requirements cover IT security such as the Federal Information
Security Management Act. Other requirements cover records management,
paperwork reduction, information technology acquisition, cybersecurity
spending, and accessible technology and continuity.
Human Capital
Like other federal agencies, the NCUA is subject to an array of
human capital-related laws, regulations, and other mandatory guidance
issued by OPM, the Equal Employment Opportunity Commission, and OMB.
Human capital compliance requirements include procedures for engagement
related to hiring; management engagement with public unions and
collective bargaining; employee discipline and removal procedures;
required training for supervisors and employees; employee work-life and
benefits programs; equal employment opportunity and required diversity
and inclusion programs; and storage and retention of human resource
records. The NCUA is also required by law to ``maintain comparability
with other federal bank regulatory agencies'' when setting employee
salaries.
Security
The NCUA's security posture is driven by numerous legal and
regulatory requirements covering the full range of security functions.
The NCUA is required to comply with mandatory requirements for
personnel security; physical security; emergency management and
continuity; communications and information security; and insider threat
activities. In addition to meeting specific legislative mandates, as a
federal agency, the NCUA is required to follow guidance from, but not
limited to, the Office of the Director of National Intelligence, OPM,
and the Federal Emergency Management Agency.
General Compliance Activities
The NCUA also has other general compliance activities that cut
across numerous offices. For example, the NCUA expends resources
complying with the Privacy Act; Government in the Sunshine Act;
multiple laws and regulations related to government ethics standards;
and various reporting and other requirements set forth by the Federal
Credit Union Act and other statutes.
Federal retirement costs are an example of mandatory payments to
other federal agencies. As discussed earlier in this document, the cost
of mandatory contributions to OPM for most NCUA employees' retirement
system will increase from 13.7 to 16.0 percent of their salaries, based
on the OPM Board of Actuaries of the Civil Service Retirement System
recommendations. The budget impact of these additional retirement costs
in 2020 is an increase of approximately $5 million over 2019.
BILLING CODE 7535-01-P
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[GRAPHIC] [TIFF OMITTED] TN01NO19.027
[[Page 59133]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.028
BILLING CODE 7535-01-C
II. Introduction and Strategic Context
History
For more than 100 years, credit unions have provided financial
services to their members in the United States. Credit unions are
unique depository institutions created not for profit, but to serve
their members as credit cooperatives.
On June 26, 2019, the NCUA celebrated the 85th Anniversary of
President Franklin Roosevelt's signing of the Federal Credit Union Act.
The law was enacted during the Great Depression, in 1934, enabling
credit unions to be organized throughout the United States under
charters approved by the federal government. The purpose of the federal
law was to make credit available to Americans and promote thrift
through a national system of nonprofit, cooperative credit unions. In
the years since the passage of the Federal Credit Union Act, credit
unions have evolved and are larger and more complex today than those
first institutions. But, credit unions continue to provide needed
financial services to millions of Americans.
The NCUA is the independent federal agency established in 1970 by
the U.S. Congress to regulate, charter, and supervise federal credit
unions. With the backing of the full faith and credit of the United
States, the NCUA operates and manages the National Credit Union Share
Insurance Fund, insuring the deposits of the account holders in all
federal credit unions and the vast majority of state-chartered credit
unions. No credit union member has ever lost a penny of deposits
insured by the Share Insurance Fund.
Today, the NCUA is responsible for the regulation and supervision
of 5,308 federally insured credit unions \2\ with approximately 118.3
million members \3\ and more than $1.5 trillion \3\ in assets across
all states and U.S. territories.
---------------------------------------------------------------------------
\2\ Source: The NCUA quarterly call report data, Q2 2019.
---------------------------------------------------------------------------
Authority
Pursuant to the Federal Credit Union Act, authority for management
of the NCUA is vested in the NCUA Board. It is the Board's
responsibility to determine the resources necessary to carry out the
NCUA's responsibilities under the Act.\3\ The Board is authorized to
expend such funds and perform such other functions or acts as it deems
necessary or appropriate in accordance with the rules, regulations, or
policies it establishes.\4\
---------------------------------------------------------------------------
\3\ See 12 U.S.C. 1752a(a).
\4\ See 12 U.S.C. 1766(i)(2).
---------------------------------------------------------------------------
Upon determination of the budgeted annual expenses for the agency's
operations, the Board determines a fee schedule to assess federal
credit unions. The Board gives consideration to the ability of federal
credit unions to pay
[[Page 59134]]
such a fee, and the necessity of the expenses the NCUA will incur in
carrying out its responsibilities in connection with federal credit
unions.\5\ Pursuant to the law, fees collected are deposited in the
agency's Operating Fund at the Treasury of the United States, and those
fees are expended by the Board to defray the cost of carrying out the
agency's operations, including the examination and supervision of
federal credit unions.\6\ In accordance with its authority \7\ to use
the Share Insurance Fund to carry out a portion of its
responsibilities, the Board approved an Overhead Transfer Rate
methodology, and authorized the Office of the Chief Financial Officer
to transfer resources from the Share Insurance Fund to the Operating
Fund to account for insurance-related expenses.
---------------------------------------------------------------------------
\5\ See 12 U.S.C. 1755(a)-(b).
\6\ See 12 U.S.C. 1755(d).
\7\ See 12 U.S.C. 1783(a).
---------------------------------------------------------------------------
Mission, Goals, and Strategy
The NCUA's 2020-2021 Budget Submission supports the agency's third
year implementing its 2018-2022 Strategic Plan to achieve its
priorities and improve program performance.
Throughout 2020 and 2021, the NCUA will continue fulfilling its
mission to ``provide, through regulation and supervision, a safe and
sound credit union system which promotes confidence in the national
system of cooperative credit,'' and its vision to ensure that the
``NCUA protects credit unions and consumers who own them through
effective supervision, regulation and insurance.'' This budget commits
the resources necessary to implement the NCUA's plans to identify key
challenges facing the credit union industry and leverage agency
strengths to help credit unions address those challenges.
The budget supports the NCUA's programs, which are focused on
achieving the agency's three strategic goals:
[ssquf] Ensure a safe and sound credit union system;
[ssquf] Provide a regulatory framework that is transparent,
efficient, and improves consumer access; and
[ssquf] Maximize organizational performance to enable mission
success.
Additional information about alignment of the budget to the NCUA's
strategic goals is in Appendix A.
In support of its first strategic goal--ensure a safe and sound
credit union system--the NCUA will continue to supervise federally
insured credit unions effectively and maintain a strong Share Insurance
Fund.
The NCUA's primary function is to identify credit union system
risks, determine the magnitude of those risks, and mitigate
unacceptable levels through the examination and supervision program.
The agency identifies supervision program priorities each year,
aligning budgeted resources to these priorities while addressing
emerging issues in order to minimize losses to the Share Insurance
Fund. Program priorities in 2020 include addressing broad market risks
and emerging cybersecurity threats that could threaten financial
stability generally, including the safety and soundness of the credit
union system.
Cybersecurity threats and other technology-related issues continue
to be of key interest and concern to the NCUA. Increasingly
sophisticated cyber-attacks pose a significant threat to credit unions,
financial regulators, and the broader financial services sector. The
availability, confidentiality, and integrity of credit union member
information remains a key supervisory priority for the NCUA. As such,
the 2020 budget includes resources to continue to improve and
standardize supervision related to information protection and
cybersecurity risks and threats.
The NCUA staff of credit union examiners are the agency's most
important assets for identifying and addressing risks before they
threaten members' deposits. To do their jobs effectively in this
complex and dynamic financial environment, the NCUA staff require the
advanced skills, training, and tools supported by the budget. The
multi-year ESM program will reach a major milestone in 2020 with the
release of the Modern Examination and Risk Identification Tool (MERIT),
the agency's modernized examination tool replacing the Automated
Integrated Regulatory Examination System (AIRES), to all credit union
examiners and state regulators. As the agency transitions to this new
tool, which will result in more efficient and effective supervision,
the NCUA must ensure its staff is prepared. The 2020 budget includes
resources to train and prepare the NCUA staff as they transition to
using MERIT.
To fulfill the NCUA's second strategic goal--provide a regulatory
framework that is transparent, efficient, and improves customer
access--the agency is committed to creating a more responsive system
that will encourage innovation, provide flexibility, and fulfill its
primary mission of protecting safety and soundness. The NCUA also seeks
to promote financial inclusion to better serve a changing population
and economy. The NCUA also seeks to ensure consumer compliance, and
financial protection. The budget allocates resources to agency programs
that keep regulations up to date and consistent with current law,
assist existing and prospective credit unions with expansion and new
chartering activities.
Accomplishing the third strategic goal--maximize organizational
performance to enable mission success--ensures the NCUA employees
achieve the agency's mission by supporting them through efficient and
effective business processes, modern and secure technology, and
suitable tools necessary to perform their duties. The budget makes
investments in improved tools and facilities for the NCUA staff, and
technological enhancements including new systems that will improve
operational effectiveness and efficiency. The budget also allocates
resources to developing better human capital planning and processes
including a new leadership development strategy and a focus on training
for the transition to MERIT.
Organization, Major Agency Programs, and Workforce
The NCUA operates its headquarters in Alexandria, Virginia, to
administer and oversee its major programs and support functions; its
Asset Management and Assistance Center (AMAC) in Austin, Texas, to
liquidate credit unions and recover assets; and three regional offices,
to carry out the agency's supervision and examination program.
In January 2019, the NCUA consolidated its five regional offices
into three--Eastern, Southern, and Western--as part of its on-going
effort to strengthen agency operations while increasing efficiency.
Reporting to these regional offices, the NCUA has credit union
examiners responsible for a portfolio of credit unions covering all 50
states, the District of Columbia, Guam, Puerto Rico, and the U.S.
Virgin Islands.
The NCUA organizational chart below reflects the agency's current
structure, and the map shows each region's geographical alignment:
BILLING CODE 7535-01-P
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[GRAPHIC] [TIFF OMITTED] TN01NO19.029
[[Page 59136]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.030
BILLING CODE 7535-01-C
The NCUA's regional offices will carry out the agency's 2020
examination program. The NCUA uses an extended examination cycle for
well-managed, low-risk federal credit unions with assets of less than
$1 billion. Additionally, the NCUA's examiners perform streamlined
examination procedures for financially and operationally sound credit
unions with assets less than $50 million. In addition, the Office of
National Examination and Supervision (ONES) will continue to examine
credit unions with assets that total over $10 billion that are located
throughout the United States. Based on 2019 second quarter call report
statistics, there are currently nine such credit unions with 18.0
million members, accounting for $256 billion in credit union assets.
In 2020 and 2021, the agency's workforce will undertake tasks in
all of the NCUA's major programs:
Supervision: The NCUA supervises federally insured credit unions
through examinations and regulatory enforcement including providing
guidance through various publications, taking administrative actions
and conserving, liquidating, or merging severely troubled institutions
as necessary to manage risk.
Insurance: The NCUA manages the $16 billion Share Insurance Fund,
which provides insurance to at least $250,000 for deposits held at
federally insured credit unions. The fund is capitalized by credit
unions and through retained earnings.
Credit Union Development: Through training, partnerships and
resource assistance, the NCUA fosters credit union development,
particularly the expansion of services to eligible members provided by
small, minority, newly chartered, and low-income designated credit
unions. The NCUA also charters new federal credit unions, as well as
approves modifications to existing charters and fields of membership.
Consumer Financial Protection: The NCUA protects consumers' rights
through effective enforcement of federal consumer financial protection
laws, regulations, and requirements. The NCUA also develops and
promotes financial education programs for credit unions to assist
members in making smarter financial decisions.
Asset Management: The NCUA conducts credit union liquidations and
performs management and recovery of assets through AMAC. This office
effectively and efficiently manages and disposes assets acquired from
liquidations.
The NCUA also performs stakeholder outreach and is involved in
numerous cross-agency initiatives. The NCUA conducts stakeholder
outreach to clearly understand the needs of the credit union system.
The NCUA seeks input from all of its stakeholders, including the
Administration, Congress, State Supervisory Authorities, credit union
members, credit unions, and their associations.
The NCUA collaborates with the other financial regulatory agencies
including through participation in several councils. Significant
councils include the Financial Stability Oversight Council (FSOC), the
Federal Financial Institutions Examination Council (FFIEC), and the
Financial and Banking Information Infrastructure Committee (FBIIC).
These councils and relationships help ensure consistent policy and
standards within the nation's financial system, where appropriate.
Budget Process--Strategy to Budget
The NCUA's budget process starts with a review of the agency's
goals and objectives set forth in the strategic plan. The strategic
plan is a framework that sets the agency's direction and guides
resource requests, ensuring the agency's resources and workforce are
allocated and aligned to agency priorities and initiatives.
Each regional and central office director at the NCUA develops an
initial budget request identifying the resources necessary for their
office to support the
[[Page 59137]]
NCUA's mission, strategic goals, and strategic objectives. These
budgets are developed to ensure each office's requirements are
individually justified and remain consistent with the agency's overall
strategic plan.
For regional offices, one of the primary inputs in the development
process is a comprehensive workload analysis that estimates the amount
of time necessary to conduct examinations and supervise federally
insured credit unions in order to carry out the NCUA's dual mission as
insurer and regulator. This analysis starts with a field-level review
of every federally insured credit union to estimate the number of
workload hours needed for the current year. The workload estimates are
then refined by regional managers and submitted to the NCUA central
office for the annual budget proposal. The workload analysis accounts
for the efforts of nearly seventy percent of the NCUA workforce and is
the foundation for budget requests from regional offices and ONES.
In addition to the workload analysis, from which central office
budget staff derive related personnel and travel cost estimates, each
of the NCUA offices submit estimates for fixed and recurring expenses,
such as rental payments for leased property, operations and maintenance
for owned facilities or equipment, supplies, telecommunications
services, major capital investments, and other administrative and
contracted services costs.
Because information technology investments impact all offices
within the agency, the NCUA has established an Information Technology
Prioritization Council (ITPC). The ITPC meets several times each year
to consider, analyze, and prioritize major information technology
investments to ensure they are aligned with the NCUA's strategic plan.
These focused reviews result in a mutually agreed-upon budget
recommendation to support the NCUA's top short-term and long-term
information technology needs and investment priorities.
Once compiled for the entire agency, all office budget submissions
undergo thorough reviews by the responsible regional and central office
directors, the Chief Financial Officer, and the NCUA's executive
leadership. Through a series of presentations and briefings by the
relevant office executives, the NCUA Executive Director formulates an
agency-wide budget recommendation for consideration by the Board.
In recent years, the Board has emphasized the need for increased
transparency of the NCUA's finances and its budgeting processes. In
response, the Office of the Chief Financial Officer has made draft
budgets available for public comment via the NCUA's website, and
solicited public comments before presenting final budget
recommendations for the Board's approval. Furthermore, the Economic
Growth, Regulatory Relief, and Consumer Protection Act, Public Law 115-
174, enacted May 24, 2018, requires in Section 212 that the NCUA ``make
publicly available and publish in the Federal Register a draft of the
detailed business-type budget.'' To fulfill this requirement, the Board
delegated to the Executive Director the authority to publish the draft
budget before submitting it for Board review.
This 2020-2021 budget justification document includes comparisons
to the Board approved 2019-2020 budget, and includes a summary
description of the major spending items in each budget category to
provide transparency and understanding of the use of budgeted
resources. Estimates are provided by major budget category, office, and
cost element.
The NCUA also posts supporting documentation for its budget request
on the NCUA website to assist the public in understanding its budget
development process. The budget request for 2020 represents the NCUA's
projections of operating and capital costs for the year, and is subject
to approval by the Board.
Commitment to Financial Stewardship
The NCUA funds its activities through operating fees levied on all
federal credit unions and through reimbursements from the Share
Insurance Fund, funded by both federal credit unions and federally
insured state-chartered credit unions. The Overhead Transfer Rate (OTR)
calculation determines the annual amount that the Share Insurance Fund
reimburses the Operating Fund to pay for the NCUA's insurance-related
activities. At the end of each calendar year, the NCUA's financial
transactions are subject to audit in accordance with Generally Accepted
Government Auditing Standards.\8\
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\8\ See 12 U.S.C. 1783(b) and 1789(b).
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The Board and the agency are committed to providing sound financial
stewardship. In recent years, the NCUA Chief Financial Officer, with
support and direction from the Executive Director and Board, has worked
to improve the NCUA's financial management, financial reporting, and
budget processes. In addition, through prudent management of the
Corporate System Resolution Program, the NCUA has paid nearly $900
million in dividends to eligible credit unions over the last two years.
The NCUA revised its financial presentations to conform to federal
budgetary concepts and increase transparency of the agency's planned
financial activity, starting with the 2018 budget. The 2020-2021 budget
continues this presentation. The NCUA is the only Financial
Institutions Reform, Recovery, and Enforcement Act (FIRREA) agency that
publishes a detailed, draft budget and solicits public comments on it
at a meeting with its Board and other agency leadership.
The NCUA continues to work diligently to strengthen its internal
controls for financial transactions, in accordance with sound financial
management policies and practices. Based on the results of the NCUA's
assessments conducted through the course of 2018, the agency provided
an unmodified Statement of Assurance (signed February 14, 2019) that
its management had established and maintained effective controls to
achieve the objectives of the Federal Managers Financial Integrity Act
(FMFIA) and Office of Management and Budget (OMB) Circular A-123.
Specifically, the NCUA supports the internal control objectives of
reporting, operations, and compliance, as well as its integration with
overarching risk management activities. Within the Office of the Chief
Financial Officer, the Internal Controls Assessment Team (ICAT)
continues to mature the agency-wide internal control program and
continues to strengthen the overall system of internal control, further
promote the importance of identifying risk, and ensure the agency has
identified appropriate responses to mitigate identified risks, in
accordance with the Government Accountability Office's Standards for
Internal Controls in the Federal Government (Green Book) requirements.
III. Forecast and Enterprise Challenges
Economic Outlook
The NCUA's mission is to provide, through regulation and
supervision, a safe and sound credit union system, which promotes
confidence in the national system of cooperative credit. The challenges
that the NCUA faces, and the resources the NCUA requires to fulfill its
mission, depend on a variety of factors that directly or indirectly
affect the health of the credit union system. The NCUA must anticipate,
to the extent possible, developments that will affect the system,
develop strategies, plans and processes to meet
[[Page 59138]]
both the current and anticipated needs, and assemble the resources,
including staff, necessary to ensure a safe and sound system.
One key determinant of credit union performance is the underlying
economic environment in which they must operate. In general, for the
past few years, the economy has supported solid financial system
performance. The economy continued to perform well in the first half of
2019. Real gross domestic product expanded by 2.6 percent at an annual
rate and, in July, the current economic expansion reached the 10-year
mark, making it the longest post-war expansion on record. Employment
has risen steadily for close to a decade and the unemployment rate at
mid-year was at a five-decade low. Inflation remained subdued.
With the support of a solid economic foundation, credit union
lending, membership growth, and credit quality remained strong through
the second quarter of 2019. Federally insured credit unions added 4.3
million members over the year, boosting credit union membership to
118.3 million in the second quarter of 2019. Credit union shares and
deposits rose 5.5 percent over the year ending in the second quarter to
$1.5 trillion. Total loans outstanding at federally insured credit
unions increased 6.4 percent to $1.1 trillion, and the system-wide loan
delinquency rate fell to 63 basis points from 67 basis points a year
earlier. The credit union system's return on average assets rose to 97
basis points, and the system's net worth ratio increased to 11.27
percent in the second quarter.
Although economic conditions were generally favorable heading into
the second half of 2019, a number of downside risks exist. Growth in
several major economies overseas showed signs of weakness. This has
generated a level of uncertainty, which weighs on business activity,
boosts financial market volatility, has pushed long-term interest rates
in the U.S. downward, and has contributed to the Federal Reserve's
decision to loosen monetary policy and lower their short-term policy
rate in two 25 basis point moves during the summer after four years of
tightening.
As of early October, long-term interest rates had fallen by about
160 basis points from their most recent peaks in late 2018, and short-
term rates had declined roughly 50 basis points. With long-term rates
falling more than short-term rates, the yield curve shifted down and
flattened.
In late May, the spread between the 10-year Treasury note and 3-
month Treasury bond turned negative; it remained negative through the
start of October. Yield curve inversion has preceded every recession in
the last 50 years, but the timing between initial inversion and the
onset of recession has varied, as shown in the chart. Most analysts
expect the current expansion to continue during the NCUA 2020-2021
budget horizon.
[GRAPHIC] [TIFF OMITTED] TN01NO19.031
Even though the number of negative risks to the economy has risen,
the near-term outlook for the U.S. economy remains positive. Forecasts
for the next two years call for somewhat slower--but still solid--
economic growth compared with 2018. Employment is projected to rise and
the unemployment rate--already below the level associated with full
employment--is expected to remain low. Tight labor market conditions
are projected to keep inflation near the Federal Reserve's 2.0 percent
target. Federal Reserve policymakers have lowered the federal funds
target rate by 50 basis points since July. Their most recent forecast,
released in September, suggests they could leave the federal funds rate
unchanged in a range of 1.75 percent and 2.00 percent through next
year, but there is a wide range of views on the appropriate path of
short-term interest rates going forward. Analysts are expecting the
federal funds target rate to decline by an additional 25 basis points
before the end of 2019 and are projecting that other short-term
interest rates--which largely determine the interest payments credit
unions make--will also move lower in the months
[[Page 59139]]
ahead. Longer-term rates--which largely determine the interest payments
credit unions receive--are expected to stabilize in the second half of
2019 and edge higher in 2020, as the recent flight to safety reverses.
Solid economic conditions should remain a positive force for credit
union lending, membership growth, and credit quality over the 2020-2021
budget horizon. In addition, the wider term spread implied by current
interest rate forecasts should translate into less pressure on credit
union net interest margins and net income going forward.
However, forecasts of the economic environment are far from
perfect. A recession would pose significant challenges to the credit
union system, leading to rising delinquencies, reduced loan demand,
and, potentially, an increase in shares as consumers move funds from
riskier investments into safer, insured credit union deposits. A
downturn in the economy would likely lead to lower interest rates as
well. Credit union balance sheets should be robust to a variety of rate
environments. The NCUA, like the credit unions themselves, needs to
plan and prepare for a range of economic outcomes that could affect
credit union performance and determine resource needs.
Other Risk Factors and Trends
In addition to risks associated with movements in the general
economy, the NCUA and credit unions will need to understand their
increasing exposure to, and address risks associated with, the
technological and structural changes facing the system. Over the
longer-term, increased concentration of loan portfolios, development of
alternative loan and deposit products, technology-driven changes in the
financial landscape, continued industry consolidation, and ongoing
demographic changes will continue to shape the environment facing
credit unions and will determine the resource needs of the NCUA.
Cybersecurity: Credit unions' increasing use of technology is
making the credit union system more vulnerable to cyber-attacks. The
prevalence of malware, ransomware, distributed denial of service (DDOS)
attacks, and other forms of cyber intrusion are creating challenges at
credit unions of all sizes, and will require ongoing measures for
containment. These trends are likely to continue, and even accelerate,
over the next two years.
Lending trends: Increasing concentrations in member business loans
and private student loans, in addition to other new types of lending by
credit unions, emphasize the need for long-term risk diversification
and effective risk management tools and practices, along with expertise
to properly manage increasing concentrations of risk.
Financial Landscape and Technology: New financial products that
mimic deposit and loan accounts, such as Apple Pay, Walmart pre-paid
cards and peer-to-peer lending, continue to emerge. These new products
pose a competitive challenge to credit unions and banks alike. Credit
unions also face a range of challenges from financial technology
(Fintech) companies in the areas of lending and the provision of other
services. For example, underwriting and lending may be automated at a
cost below levels associated with more traditional financial
institutions, but may not be subject to the same regulations and
safeguards that credit unions and other traditional financial
institutions face. The emergence and increasing importance of digital
currencies may pose both risks and opportunities for credit unions. As
these institutions and products gain popularity, credit unions may have
to be more active in marketing and rethink their business models.
Technological changes outside the financial sector may also lead to
changes in consumer behavior that indirectly affect credit unions. For
example, the increase in on-demand use of auto services and pay-as-you-
go, on-demand vehicle rental could reduce purchases of consumer-owned
vehicles. That could lead to a slowdown or reduction in the demand for
vehicle loans, now slightly more than a third of the credit union
system loan portfolio.
Membership trends: While overall credit union membership continues
to grow, roughly half of federally insured credit unions had fewer
members at the end of the second quarter of 2019 than a year earlier.
Demographic and field of membership changes are likely to continue
leading to declining membership at many credit unions. All credit
unions need to consider whether their product mix is consistent with
their members' needs and demographic profile.
Smaller credit unions' challenges and industry consolidation: Small
credit unions face challenges to their long-term viability for a
variety of reasons, including weak earnings, declining membership, high
loan delinquencies, and elevated non-interest expenses. If current
consolidation trends persist, there will be fewer credit unions in
operation and those that remain will be considerably larger and more
complex. As of June 30, 2019, there were 576 federally insured credit
unions with assets of at least $500 million, 29 percent more than just
five years earlier. These 576 credit unions accounted for 73 percent of
credit union members and 79 percent of credit union assets. Large
credit unions tend to offer more complex products, services and
investments. Increasingly complex institutions will pose management
challenges for the institutions themselves, as well as the NCUA;
consolidation means the risks posed by individual institutions will
become more significant to the Share Insurance Fund.
Enterprise Risk Management
The NCUA uses an Enterprise Risk Management (ERM) program to
evaluate various factors arising from its operations and activities
(both internal to the agency and external in the industry) that can
impact the agency's performance relative to its mission, vision, and
performance outcomes. Agency priority risks include both internal
considerations such as the agency's control framework, information
security posture, and external factors such as credit union
diversification risk. All of these risks can materially impact the
agency's ability to achieve its mission.
The NCUA's ERM Council provides oversight of the agency's
enterprise risk management activities. Through the ERM program,
established in 2015, the agency is identifying and managing risks that
could affect the achievement of its strategic objectives. In 2018 and
2019, the NCUA developed and implemented processes for analyzing and
responding to enterprise risks. The NCUA has conducted several risk
response assessments for priority areas including credit union business
diversification, credit union cybersecurity, agency controls, and
information security. These assessments help inform the agency's
activities, operations, and planning and budget processes. Overall, the
NCUA's ERM program promotes effective awareness and management of
risks, which, when combined with robust measurement and communication,
are central to cost-effective decision-making and risk optimization
within the agency.
The NCUA adopted its enterprise risk appetite statement in the
2018-2022 Strategic Plan, which is:
The NCUA is vigilant and has an overall judicious risk appetite.
The NCUA's primary goal is to ensure the safety and soundness of the
credit union system and the agency recognizes it is not desirable or
practical to avoid all risk. Acceptance of some risk is often
necessary to foster innovation and agility. This risk appetite will
guide the
[[Page 59140]]
NCUA's actions to achieve its strategic objectives in support of
providing, through regulation and supervision, a safe and sound
credit union system, which promotes confidence in the national
system of cooperative credit.
The agency's risk appetite helps align risks with opportunities
when making decisions and allocating resources to achieve the agency's
strategic goals and objectives. This enterprise risk appetite statement
is part of the NCUA's overall management approach and is supported by
detailed appetite statements for individual risk areas.
In practice, this means that the NCUA recognizes that risk is
unavoidable and sometimes inherent in carrying out the agency's
mandate. The NCUA is positioned to accept greater risks in some areas
than in others; however, when consolidated, the risk appetite
establishes boundaries for the entire agency and all of its programs.
Collaboration across programs and functions is a fundamental part of
ensuring the agency stays within its risk appetite boundaries, and the
NCUA will identify, assess, prioritize, respond to and monitor risks to
an acceptable level. This budget proposal for 2020-2021 incorporates
several specific programmatic changes that resulted from the NCUA's
enterprise risk management reviews, such as hiring new personnel
focused on cybersecurity, acquiring data loss prevention and other
network security tools, and strengthening analytical focus on emerging
financial risks within the credit union system.
IV. Key Themes of the 2020-2021 Budget
Overview
The budget supports the priorities and goals outlined in the
agency's annual performance plan and the 2018-2022 Strategic Plan. The
resources and new initiatives proposed in the budget support the NCUA's
mission to maintain a safe and sound credit union system.
The 2020-2021 budget carries forward a number of key ongoing
initiatives, which include: The Exam Flexibility Initiative; the
increased use of off-site examinations work and data analytics; the
modernization of information technology systems; regulatory reform
initiatives; and efforts to implement organizational efficiencies. Over
the course of the next five years, these efforts will result in a more
effective organization.
In the 2020-2021 budget, the NCUA will increase staffing in
critical areas necessary to operate as an effective federal financial
regulator capable of addressing emerging issues and continuing to
modernize the examination program. The NCUA employees are the agency's
most valuable resource for achieving its mission, and the agency is
committed to a workplace and a workforce with integrity,
accountability, transparency, inclusivity, and proficiency. We will
continue investing in the workforce through training and development,
helping employees develop the tools they need to do their work
effectively.
Employment-related costs are the single largest driver of the NCUA
budget; therefore, managing the size of the workforce is important from
a budgetary standpoint. Increases to the agency's staffing levels in
2020 address gaps in the agency's workforce that must be filled in
order to execute the agency's mission and foster an innovative,
responsive and sound credit union system that meets the needs of all
Americans. The NCUA continues to assess and balance its mission
workload needs with the financial costs the agency imposes on the
credit union system. Although the number of credit unions continues to
decline nationwide, the NCUA must also consider the increasing
complexity and growing asset base of the entire credit union system.
The efficiency and effectiveness of the agency's workforce is
dependent upon the resiliency of the NCUA's information technology
infrastructure and availability of technological applications. The NCUA
is committed to implementing new technology responsibly and delivering
secure, reliable and innovative technological solutions to support its
mission. This necessitates investments funded in the Capital Budget and
additional staff to provide the analytical tools and technology the
workforce needs to achieve the NCUA mission.
Enterprise Solution Modernization
In 2015, the NCUA conducted an assessment of the information
technology (IT) needs across the agency and developed a business case
for replacing its antiquated legacy systems. This assessment recognized
the full range of industry leading, cost-effective alternative
strategies, services, and products for implementing the agency's next
generation of IT information management, examination, supervisory, and
data collection solutions.
At that time, the NCUA acknowledged a technology revamp of this
magnitude as a high-risk endeavor, both in terms of cost and delivered
functionality. The risk stems from the number of systems impacted and
the unique nature of the NCUA's applications, many of which require a
high degree of customization. However, the agency required a major
modernization after many years of under-investment in software and
application development.
In November 2015, the NCUA Board approved a plan for modernizing
the agency's IT systems known as the Enterprise Solution Modernization
(ESM) program. The ESM program recognizes the following legacy systems,
capabilities and strategies need to be modernized:
[[Page 59141]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.032
To better manage the complexity of the ESM Program, the NCUA
established three sub-programs to modernize the NCUA's technology
solutions and create an integrated examination and data environment
that facilitates a safe and sound credit union system:
[GRAPHIC] [TIFF OMITTED] TN01NO19.033
Given the age of the NCUA's legacy examination systems and their
importance to the mission of the agency, priority was given to the
following parts of the modernization effort in the first phase of ESM
development:
[cir] Better information security across the organization.
[cir] Technical platform and foundation for new applications.
[cir] AIRES replacement (Examination and Supervision Solution),
including financial analytics.
[cir] Central user interface for stakeholders to interact with the
NCUA.
[cir] Business Intelligence tools for enhanced analytical
capabilities (added later to the initial phase as explained below).
To deploy the Examination and Supervision Solution, it was first
necessary to stand up new agency infrastructure that supports the full
modernization program: The technology architecture, infrastructure, and
security posture required to operate modernized systems. The necessary
infrastructure was acquired and put in place in 2019. The ESS program
capabilities have been deployed in part in 2019 and will be rolled out
nationwide in 2020. The new examination solution, which is named the
Modern Examination and Risk Identification Tool (MERIT), was released
to the Office of National Examinations and Supervision in September
2019, while the release to the remaining Regional staff is scheduled
for the summer of 2020.
Though not originally included as part of the initial ESM plan, the
agency has incorporated a robust business intelligence solution into
the MERIT deployment, which advances the agency's analytic capabilities
during this phase. The need for better analytics is central to the
strategy to shift more exam work offsite.
In addition to better data analytics, MERIT provides numerous
improvements over the legacy AIRES examination system, including:
[cir] Implementation of better controlled access to examination
data across the organization.
[cir] Faster and well-organized ability to request and submit items
for the examination.
[cir] Collaboration and real-time information for examiners, team
members, and supervisors, including state supervisory authorities on
joint exams.
[[Page 59142]]
[cir] Opportunities for credit union users to manage examination
findings and view completed examination reports.
[cir] Business process improvements to achieve exam efficiencies,
including less data redundancy and relational support between scope
tasks, questionnaires, and findings.
Cost Estimates
The NCUA engaged an independent market research firm to estimate
the cost of the initial ESM phases, including MERIT. Their research
estimated a range in costs of $18.9 to $37.9 million.
From 2015 to 2019, the NCUA Board approved a total budget of $20.8
million for the MERIT program. This total included the modernized and
more secure IT infrastructure, central user interface, and the first
release of MERIT.
The total expected acquisition costs for this phase of ESM,
including actual costs through 2019 and the budget for 2020, is $36.6
million. This will provide additional needed functionality in the
second release of MERIT, including the loan and share download business
intelligence integration.
The NCUA awarded the Examination and Supervision Solution agile
development contract in 2018. For the first three-month discovery phase
of the contract, the NCUA and the systems integrator worked diligently
to translate the business process context and identify tool-based
implications and functional gaps. After discovery concluded, the NCUA
determined the full funding needed to meet developmental,
organizational change management, and scheduling requirements. As
discussed above, the funding total now includes the advanced business
intelligence capabilities.
Through September 2019, the NCUA accomplished the following:
[cir] Established the ESM technical program infrastructure
platform, including enhanced IT security.
[cir] Developed the central user interface known as NCUA Connect,
achieving a secure, single entry point into NCUA applications.
[cir] Deployed the new MERIT examination tool to ONES to support
examination and supervision of the largest credit unions.
[cir] Developed financial analytics with dashboards and
visualizations designed to assist the examiner in identifying risk.
The project is on schedule to meet the following performance
targets:
[cir] 2019: Conduct ONES examinations and supervision contacts for
all federal credit unions with assets greater than $10 billion and
joint exams with state regulators in federally insured state-chartered
credit unions with assets greater than $10 billion in Washington and
North Carolina using the MERIT solution, which commenced on October 7,
2019.
[cir] 2020: Deploy second release of MERIT for the majority of the
NCUA staff, state supervisory authorities, and credit unions in the
third quarter of 2020.
Cybersecurity Priorities
Cyber-attacks pose a threat to credit unions, financial regulators,
and the broader financial system. Advances in technology and increased
use of cyberspace for financial transactions means more opportunities
for cybersecurity threats and other technology-related issues. As a
result, cybersecurity is one of the top priorities of the NCUA Board.
In June 2019, Chairman Rodney E. Hood appointed a special advisor for
cybersecurity who not only will provide strategic counsel on
cybersecurity policy but will also engage with other federal financial
institution regulators and external stakeholders.
In 2018, the NCUA began implementing a new Automated Cybersecurity
Examination Tool (ACET) maturity assessment for credit unions with
assets greater than $1 billion. The focus of the ACET implementation
was to baseline individual credit unions' cybersecurity maturity
consistently while benchmarking the entirety of the sector. In 2019,
the maturity assessments were conducted on credit unions with assets
greater than $250 million; in 2020, the agency will conduct maturity
assessments on credit unions with assets between $100 million and $250
million. The NCUA continues to evaluate the feasibility for conducting
the maturity assessments on even smaller, less complex institutions.
Concurrently, the NCUA is developing a tailored examination program
based on the Information Technology Risk Examination (InTREx) solution
leveraged by the Federal Deposit Insurance Corporation, the Federal
Reserve Board and state regulators to ensure a harmonized, repeatable,
measurable and transparent process for examining the compliance, safety
and soundness of the credit unions' information security programs.
The examination procedures will be maintained within the NCUA MERIT
solution. The agency expects the results of both the maturity
assessment and the examination program to help focus and prioritize
cybersecurity for credit unions and make it an integral part of their
risk-management strategies.
The NCUA will further build upon its cybersecurity capabilities and
programs to continue helping credit unions and consumers protect
themselves. Specifically, the 2020 budget allocates resources to the
following cybersecurity-related activities:
[cir] Advancing consistency, transparency and accountability within
the cybersecurity examination and supervision program;
[cir] Expanding cybersecurity analytics to better inform
examination and supervision decisions;
[cir] Enhancing interoperability of the maturity assessment
capability for broad credit union system distribution and full
integration into the new examination system, MERIT;
[cir] Stimulating due diligence for supply chain and third-party
service provider management within the credit union sub-sector;
[cir] Assisting institutions with resources to improve operational
cybersecurity hygiene and resilience;
[cir] Performing skills assessments of credit union examiners and
taking steps to build skill set of examination staff in accordance with
the National Initiative of Cybersecurity Education (NICE) Framework;
[cir] Enhancing the professional expertise and knowledge management
of
[cir] agency specialists on cybersecurity and emerging technical
innovation in the delivery of financial services, cybersecurity trends
and risk/threat; and
[cir] Expanding collaboration and coordination with relevant
agencies towards a more harmonized examination and critical
infrastructure protection capability.
These initiatives--focused on supervisory program development,
training, industry analysis and exercises, combined with interagency
coordination and industry outreach--will require additional personnel.
The 2020 budget includes two new cybersecurity positions within the
Office of Examination and Insurance to improve the agency's ability to
be prepared for and respond to the broadening responsibilities tied to
cybersecurity and critical infrastructure protection.
The NCUA also places strong emphasis on ensuring the security of
the agency's systems and the controlled, unclassified information it
collects. The NCUA's Office of the Chief Information Officer is
continually taking steps to enhance the agency's information security
posture and ensure the NCUA's systems and information are protected
[[Page 59143]]
from compromise, including the work done as part of ESM. The 2020
budget allocates $500,000 to acquire and implement data loss prevention
(DLP) as part of the Information Technology (IT) Infrastructure,
Platform and Security Refresh Capital Initiative. DLP is a set of tools
and processes used to ensure that sensitive data is not lost, misused,
or accessed by unauthorized users.
Bank Secrecy Act Compliance
The NCUA continues to budget resources to comply with the statutory
mandate from Congress to enforce federal credit union compliance with
Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) laws and
regulations. Technological advancements may expose even the smallest
credit unions to potential illicit finance activities. The NCUA
examines federal credit union compliance with BSA during every
examination. Additionally, the NCUA assists state regulators by
conducting BSA examinations in federally insured, state-chartered
credit unions where state resources are limited.
In 2019, the NCUA's field staff began more in-depth reviews of
credit unions' BSA and AML policies, procedures, and processes to
assess compliance with new customer due diligence (31 CFR
1020.210(b)(5)) and beneficial ownership requirements (31 CFR 1010.230)
which became effective May 11, 2018.
The NCUA's BSA reviews are risk-focused and include procedures to
review an institution's compliance with the pillars of the BSA. These
procedures are based on the examination procedures in the FFIEC BSA/AML
Examination Manual the NCUA issues jointly with the other federal
financial institution regulators. The NCUA's examiners tailor
examinations based on the unique risk characteristics of each federal
credit union. Additional or more in depth reviews are performed for
those with higher risk activities; reviews at credit unions with lower
risk activities are scaled appropriately.
The NCUA coordinates regularly with our counterparts at the other
federal financial institution regulatory agencies, as well as the
Financial Crimes Enforcement Network (FinCEN). The NCUA actively
participates in the Bank Secrecy Act Advisory Group (BSAAG), the FFIEC
BSA/AML Working Group and an interagency working group to improve
effectiveness and streamline, where possible, regulations and
supervisory processes. The NCUA also partners with the other federal
financial institution regulators to issue joint BSA statements,
including the Joint Statement on Risk-Focused BSA/AML Supervision,
dated July 22, 2019. Interagency groups are currently updating the
Interagency Statement on Enforcement of BSA/AML Requirements,
originally issued in 2007, and the FFIEC BSA/AML Examination Manual,
last revised in 2014. The NCUA intends to continue collaborating with
our regulatory counterparts, including FinCEN.
In 2019, the NCUA issued Regulatory Alert 19-RA-02, Serving Hemp
Businesses, to update federally insured credit unions about changes in
federal law and regulation related to hemp. Specifically, the guidance
clarifies that credit unions may provide the customary range of
financial services for business accounts, including loans, to lawfully
operating hemp related businesses within their fields of membership,
and provides information to help credit unions better understand what
they should consider providing financial services to lawfully operating
hemp businesses.
Stakeholder Engagement
In 2020, the agency is allocating resources for engagement summits
with stakeholders. These events will include credit union officials,
staff, and volunteers in order to discuss many of the priorities the
agency has funded through this budget process. Topics of interest at
these summits may include financial inclusion, minority depository
institutions, cybersecurity or risk and risk mitigation strategies in
the current environment. The NCUA Board is committed to understanding
how these priority areas impact credit unions and engaging in a
thoughtful dialogue to determine whether there are additional actions
the NCUA should and shouldn't take to ensure credit unions are best
prepared to serve their members while doing so in a safe and sound
manner.
Examination Initiatives
The NCUA is focused on several additional examination modernization
efforts as outlined in the August 2018 Letter to Credit Unions: 18-CU-
01--``Examination Modernization Initiatives.'' This letter outlined
five initiatives to modernize the agency's examinations processes,
including the ESM program outlined above. Intended benefits of these
initiatives include:
[cir] More efficient and less burdensome examinations and
supervision
[cir] More consistent and accurate supervisory determinations
[cir] Enhanced coordination with State Supervisory Authorities
[cir] More secure, reliable, and flexible technology to support
future expansion capabilities
These modernization initiatives are interrelated and complement
each other. As these initiatives support and build upon each other,
they will ultimately result in a fully modernized examination and
supervision program with various incremental improvements along the
way. The budget allocates resources in support of these improvements.
Below is a more in-depth discussion of four of the initiatives. The
fifth initiative, the ESM program, is discussed in detail above.
ONES Data-Driven Supervision
This initiative began in 2018 as an effort to move to a continuous
supervision model for the large, natural-person credit unions
supervised by the ONES. This ongoing supervision program will use data-
driven analytics to monitor and identify credit union risk while
supporting the oversight of credit union-driven stress testing. The
NCUA's ONES travel costs are projected to decrease by 10 percent as a
result of implementing this program and the transition to the NCUA's
in-house oversight of credit union run stress-testing will allow the
NCUSIF to avoid $3 million in costs in 2020. The data-driven
supervision initiative may lead to analytical advancements that can be
adapted for supervising some or all other insured credit unions.
Shared NCUA-State Regulator Federally Insured, State-Chartered Credit
Unions Program
In 2017, the NCUA created the Joint NCUA-State Supervisor Working
Group (working group), which is tasked with improving coordination and
scheduling for joint exams, providing scheduling flexibility, and
reducing redundancy where possible. The group's goal is to minimize the
burden on federally insured, state-chartered credit unions resulting
from having a separate financial regulator and insurer.
In addition, the working group is evaluating the appropriateness
and feasibility of adopting an alternating-year examination approach
for federally insured, state-chartered credit unions. A pilot program
launched January 2019 and will allow the NCUA, state regulators, and
stakeholders to evaluate the benefits and challenges of an alternate-
year examination program. The pilot will last approximately three years
in order to collect enough information to evaluate one full
alternating-year exam cycle. The results of the pilot will provide
valuable insight into the advantages and risks of such an
[[Page 59144]]
approach prior to finalizing a decision about a permanent alternating-
year exam cycle.
To support joint examinations in federally insured, state-chartered
credit unions, the working group developed a new template framework for
improved coordination and cooperation between the NCUA regions and the
respective state regulators. The working group is also exploring ways
to minimize duplication and overlap through examination and procedure
improvements and greater use of technology. In addition, the working
group is evaluating other areas of potential duplication that can be
reduced or eliminated, such as loan participations, Credit Union
Service Organizations (CUSOs) and third party vendor reviews, and other
supervisory matters. The goal of these reviews is to better leverage
the work of each regulatory party in examining and supervising
federally insured, state-chartered credit unions.
Virtual Examination Program
In 2017, the NCUA Board approved the project and associated
resources to research methods to conduct offsite as many aspects of the
examination and supervision processes as possible. The virtual exam
project team is researching ways to harness new and emerging data,
advancements in analytical techniques, innovative technology, and
improvements in supervisory approaches. When approving the 2019 budget,
the NCUA Board approved using past years' unspent balances to complete
the research and discovery phase for virtualizing key elements of the
examination; this work will continue through 2020.
By identifying and adopting alternative methods to remotely analyze
much of the financial and operational condition of a credit union, with
equivalent or improved effectiveness relative to current examinations,
it may be possible to significantly reduce the frequency and scope of
onsite examinations. Onsite examination activities could potentially be
limited to periodic data quality and governance reviews, interventions
for material problems, and meetings or other examination activities
that need to be handled in person.
The virtual exam should lead to greater use of standardized
interaction protocols, advanced analytical capabilities, and more-
informed subject matter experts. This should result in more consistent
and accurate supervisory determinations, provide greater clarity and
consistency with respect to how the agency conducts supervisory
oversight, and reduce coordination challenges between agency and credit
union staff.
To be successful, it is likely examination staff will need to
analyze more information about the credit union being examined and
communicate more frequently with management at the credit union.
However, it is not the agency's intent to intervene in credit unions'
day-to-day operations or strategic planning.
The virtual examination team will deliver to the NCUA Board by the
end of 2020 a report discussing alternative methods identified to
remotely analyze aspects of the financial and operational condition of
a credit union.
Offsite Examination Procedures
Starting in 2016, the NCUA's Southern Region piloted a flexible
exam program--commonly called FLEX. The pilot program ran through 2018
and evaluated conducting certain existing exam procedures offsite. The
pilot assessed examiners working remotely on elements of examinations
of well-run credit unions with the technology and platforms to provide
electronic data securely.
In 2019, the NCUA adopted the best practices from the FLEX pilot
nationally. Now known as offsite examination procedures, the NCUA
updated its National Supervision Policy Manual to indicate the agency's
support for providing staff with the flexibility to conduct examination
work offsite when appropriate conditions are met. The NCUA continues to
develop plans to increase agency use of offsite procedures.
Regulatory Reform
The NCUA established a Regulatory Reform Task Force (Task Force) in
March 2017 to oversee implementation of the agency's regulatory reform
agenda. This is consistent with the spirit of Executive Order 13777 and
the Trump administration's regulatory reform agenda. Although the NCUA,
as an independent agency, is not required to comply with Executive
Order 13777, the agency chose to review all of the NCUA's regulations,
consistent with the spirit of initiative and the public benefit of
periodic regulatory review. The NCUA has undertaken a series of
regulatory changes as part of this effort, and continues to pursue a
regulatory reform agenda, including matters such as advertising, field
of membership, equity distribution, and securitization. The Task Force
published its final report in December 2018.
Reorganization/Restructuring
In July 2017, the NCUA's executive leadership committed to a
comprehensive plan that would invest in the agency's future, make
critical organizational alignment changes, and improve the NCUA's
efficiency, effectiveness, and focus on its core mission
responsibilities. The agency has completed the operational actions
related to its reform plan.
As a result of the NCUA's reform plan:
[cir] The NCUA created an office focused exclusively on credit
union service needs including new charters, credit union expansion, and
training--the Credit Union Resources and Expansion (CURE) Office.
[cir] Examination reports have been improved through enhanced
quality measures.
[cir] Two regional offices closed in January 2019 and leased office
space has been reduced.
[cir] AMAC's staffing has been reduced, and support functions are
now better aligned with the central office.
The NCUA continues to examine how to best balance meeting workforce
and technology needs while containing operating costs.
V. Operating Budget
Overview
The NCUA Operating Budget is the annual resource plan for the NCUA
to conduct activities prescribed by the Federal Credit Union Act of
1934. These activities include: (1) Chartering new federal credit
unions; (2) approving field of membership applications of federal
credit unions; (3) promulgating regulations and providing guidance; (4)
performing regulatory compliance and safety and soundness examinations;
(5) implementing and administering enforcement actions, such as
prohibition orders, orders to cease and desist, orders of
conservatorship and orders of liquidation; and (6) administering the
National Credit Union Share Insurance Fund.
Staffing
The staffing levels proposed for 2020 reflect the resource
requirements for steady state operations at the NCUA as it continues to
modernize the examination process to enhance the efficiency and
effectiveness of the supervisory process. Two new information systems
officers in the Office of Examinations and Insurance will support
expanded responsibilities for cybersecurity and critical infrastructure
protection. A third position will be created in the
[[Page 59145]]
Chairman's office to support the NCUA through strategic outreach and
engagement with stakeholders in the credit union system, including
credit union management, associations and leagues, and journalists who
cover the industry.
During the July 2019 mid-session review, the NCUA Board approved
four additional staff to support the agency's growing engagement with
the Administration, Congress, industry stakeholders, and the general
public. The newly authorized positions for the Office of External
Affairs and Communications include a Deputy Director, a Communications
Specialist, a Technical Writer and Editor, and a Program Analyst for
External Affairs. The full cost of these positions are included in the
2020 budget.
The 2020 budget supports a total agency staffing level of 1,185
personnel, of which 1,180 are funded in the Operating Budget. This is a
net increase of three positions, or 0.25 percent, compared to the
Board-approved level for 2019, as modified at the July 2019 Board
meeting. The new 2020 positions are described in greater detail below.
[GRAPHIC] [TIFF OMITTED] TN01NO19.034
In addition to the staff assigned to regional offices, most of the
staff in ONES are remote field staff who also travel to credit unions
as part of their examination responsibilities.
Request for New Staff in 2020
Information Systems Officers (+2 New Positions)
These new employees, requested in the Office of Examination and
Insurance, will be responsible for expanded cybersecurity
responsibilities that include: Management of interagency activities,
development of industry policy related to information security, and
improvement of credit union cybersecurity resilience. The goal of these
positions is to increase institutional knowledge of cybersecurity best
practices within the credit union
[[Page 59146]]
system and broaden skills within the NCUA to ensure a consistent and
professional approach during credit union supervision.
Senior Adviser to the Chairman for Communications and Engagement (+1
New Position)
This new employee will support the NCUA through strategic outreach
and engagement with stakeholders in the credit union system, including
credit union management, associations and leagues, and journalists who
cover the industry. This employee will also assist the NCUA Board by
keeping members up to date about challenges and changes within the
system.
Budget Category Descriptions and Major Changes
There are five major expenditure categories in the NCUA budget.
This section explains how these expenditures support the NCUA's
operations, and presents a transparent and comprehensive accounting of
the Operating Budget.
[GRAPHIC] [TIFF OMITTED] TN01NO19.035
Salaries and Benefits
The budget includes $231.4 million for employee salaries and
benefits in 2020. This change is an $8.5 million, or 3.8 percent,
increase from the 2019 Board-approved budget.
Salaries and benefits costs make up 73.2 percent of the total
budget. There are two primary drivers of increased costs in 2020 for
the Salaries and Benefits category:
[cir] Merit and locality pay increases for the NCUA's 1,180
personnel paid from the Operating Budget, in accordance with the
agency's current Collective Bargaining Agreement (CBA) and its merit-
based pay system. Salaries are estimated to increase 1.8 percent in
aggregate compared to 2019. This growth is lower than prior years due
to new employee starting salaries being set at the lower end of pay
ranges when turnover occurs and because of some staff reaching the
salary caps for their pay grades.
[cir] Contributions for employee retirement to the Federal Employee
[[Page 59147]]
Retirement System (FERS), which are unilaterally set by the Office of
Personnel Management, and which cannot be negotiated or changed by the
NCUA. Driven by the mandatory rate adjustment, the 2020 benefits costs
increase 9.0 percent compared to 2019.
These changes are described in more detail below.
In 2020, the NCUA's compensation levels will continue to ``maintain
comparability with other federal bank regulatory agencies,'' as
required by the Federal Credit Union Act.\9\ The Salaries and Benefits
category of the budget includes all employee pay raises for 2020, such
as merit and locality increases, and those for promotions,
reassignments, and other changes, as described below.
---------------------------------------------------------------------------
\9\ The Federal Credit Union Act states that, ``In setting and
adjusting the total amount of compensation and benefits for
employees of the Board, the Board shall seek to maintain
comparability with other [F]ederal bank regulatory agencies.'' See
12 U.S.C. 1766(j)(2).
---------------------------------------------------------------------------
Consistent with other federal pay systems, the NCUA's compensation
includes base pay and locality pay components. The NCUA staff will be
eligible to receive an average merit-based increase of 3.0 percent, and
an additional locality adjustment ranging from -1.0 percent to +3.0
percent, depending on the geographic location. The average increase in
locality pay is estimated to be 1.52 percent. Starting in 2018, the
NCUA discontinued the annual, general pay scale increase of 1.25
percent in accordance with the most-recent CBA negotiations.
The first-year cost of the new positions added in 2020 is estimated
to be $0.9 million. Specific increases to individual offices' salaries
and benefits budgets will vary based on current pay levels, position
changes, and promotions.
Personnel compensation at the NCUA varies among every office and
region depending on work experience, skills, years of service,
supervisory or non-supervisory responsibilities, and geographic
locations. In general, more than 85 percent of the NCUA workforce has
earned a bachelor's degree or higher, compared to approximately 35
percent of the private-sector workforce. This high level of educational
achievement ensures the NCUA workforce is able to fulfill its mission
effectively and efficiently, and attracting a well-qualified workforce
requires the agency to pay employees competitive salaries.
Individual employee compensation varies, depending on the cost of
living in the location where the employee is stationed. The federal
government sets locality pay standards, which are managed by the
President's Pay Agent--a council established to make recommendations on
federal pay. The council uses data from the Occupational Employment
Statistics program, collected by the Bureau of Labor Statistics, to
compare salaries in over 30 metropolitan areas, and establishes
recommendations for equitable adjustments to employee salaries to
account for cost-of-living differences between localities.
The OPM economic assumptions for actuarial valuation of the FERS
have increased significantly for 2020. All federal agencies are
expected to contribute 16.0 percent of FERS employees' salaries to the
OPM retirement system, an increase of 230 basis points compared to the
2019 level. This mandatary contribution is prescribed in the OPM
Benefits Administration Letter dated June 2019. The estimated impact on
the NCUA budget is an increase of approximately $5.0 million in
mandatory payments to OPM, or 1.6 percentage points of budgetary
growth, compared to 2019 levels.
The average health insurance costs for the Federal Employees Health
Benefits program for 2020 are consistent with historical actual
expenses. The employee salary and benefits category also includes costs
associated with other mandatory employer contributions such as Social
Security, Medicare, transportation subsidies, unemployment, and
workers' compensation.
The 2020 budget estimate for pay and benefits includes the
assumption of a 2.2 percent vacancy rate (roughly 26 full-time
positions) during the year. This aligns with the NCUA's recent
attrition rates and workforce management efforts to carefully review
every vacancy created in the agency in 2020 before a hiring notice is
published. The effect of this adjustment lowers the NCUA budget
estimate and results in reduced fees collected from credit unions.
The 2021 budget request for salaries and benefits is estimated at
$237.8 million, a $6.4 million increase from the 2020 level, which
accounts for merit and locality increases consistent with the CBA
(approximately $4.1 million), the full-year cost impact of new
positions (approximately $0.6 million), and associated increases in
benefits for all employees (approximately $1.7 million). The
assumptions used for compensation-related adjustments are based on the
CBA currently in force. The NCUA CBA will be renegotiated during 2020,
with any changes reflected in future budget cycles.
Travel
The 2020 budget includes $27.4 million for Travel. This change is a
$590,000, or 2.2 percent, increase to the 2019 Board-approved budget.
Travel comprises approximately nine percent of the overall 2020 budget.
The cumulative reduction of the credit union examiner positions
compared to past years, extended examination cycles, and increased use
of offsite examinations all help contain the NCUA's travel costs.
However, the General Services Administration (GSA) announced an
increase to standard lodging rates to $96 dollars in 2020, an increase
of four dollars, or four percent compared to 2019, which contributes to
the growth of estimated travel expenses in 2020. In addition, effective
with 2019, GSA will charge the NCUA fees for the city pair program that
provides discounted and flexible air passenger transportation services
to federal government travelers. Although the NCUA has always
participated in the mandatory program, prior year fee payments were not
applied to the NCUA. The annual cost of $20,000 to GSA for all the NCUA
employee travel fees may increase depending on future travel schedules.
The Travel cost category includes expenses for employees' airfare,
lodging, meals, auto rentals, reimbursements for privately owned
vehicle usage, and other travel-related expenses. These are necessary
expenses for examiners' onsite work in credit unions. Close to two-
thirds of the NCUA's workforce is comprised of field staff who spend a
significant part of their year traveling to conduct the examination and
supervision program.
The NCUA staff also travel for routine and specialized training. In
2020, the NCUA will conduct a series of training events to support the
nationwide roll-out of MERIT. The NCUA's planning staff conducted
extensive research to identify low-cost locations for these events. The
roll-out will be a labor intensive effort requiring up to six weeks of
travel for many of the NCUA's staff, and will provide hands-on training
for this new system, which will be officially deployed in the fourth
quarter of 2020. The estimated travel costs for MERIT-related training
funded in the 2020 Operating Budget is $1.0 million.
The NCUA plans to evaluate future cost avoidance for travel through
continued expansion of offsite examination work. In addition, agency
personnel will continue to utilize more virtual training options, where
appropriate, to help minimize travel expenses. The 2021 budget request
for
[[Page 59148]]
the travel is estimated to be $26.7 million, less than 2020 because of
the exclusion of one-time MERIT training costs.
Rent, Communications, and Utilities
The 2020 budget includes $8.2 million for Rent, Communications, and
Utilities. This is an $188,000 increase, or 2.3 percent more than the
2019 Board-approved budget. The Rent, Communications, and Utilities
category is the smallest component of the NCUA's budget and funds the
agency's telecommunications and information technology network
expenses, and facility rental costs.
The agency telecommunications budget for 2020 is $4.5 million and
accounts for most of the increase in this budget category. The
telecommunication charges include leased lines, domestic and
international voice (including mobile), and other network charges.
Telecommunication costs include the circuits and any associated usage
fees for providing voice or data telecommunications service between
data centers, office locations, the internet and any customer, supplier
or partner. The increased costs support trusted internet protocol
services due to higher data consumption and use of cloud-based
services.
Office building leases, meeting rentals, office utilities, and
postage expenses are also included in this budget category. Facility
costs total $2.1 million for 2020 and include the NCUA's annual payment
of $1.3 million to the Share Insurance Fund for its central office
note, which is scheduled to be fully repaid in 2023. The annual utility
costs for the central office and regional offices are estimated at
$483,000.
The 2020 budget also includes $1.1 million for event rental costs
for examiner meetings and other training events. This includes the one-
time costs of $220,000 for space rental for the MERIT training events
planned in 2020.
The 2021 budget request for the Rent, Communications, and Utilities
category is estimated to be $8.0 million, less than 2020 because of the
exclusion of one-time MERIT training costs.
Administrative Expenses
The 2020 budget includes $5.9 million for Administrative Expenses.
This is a decrease of $2.8 million, or 31.9 percent, compared to the
2019 Board-approved budget. Recurring costs in the Administrative
Expenses category include the annual reimbursement to the Federal
Financial Institutions Examination Council (FFIEC), employee relocation
expenses, recruitment and advertising, shipping, printing,
subscriptions, examiner training and meeting supplies, office
furniture, and employee supplies and materials.
Most of the decrease in the Administrative Expenses budget results
from realigning the costs of various service contracts, maintenance
fees, and end-user licensing for computer software and database
management applications to the Contracted Services budget.
Approximately $3.8 million, unchanged from 2019, will be permanently
included in Contract Services, which is consistent with standard
government reporting for software costs. This includes annual software
licenses and maintenance support fees for the call center managed by
the Office of Consumer Financial Protection.
As part of the FFIEC, the NCUA shares in costs for joint actions
and services that affect the financial services industry. The overall
decrease is $78,000 less than the 2019 budget levels since the state
examiner training costs will be reduced next year.
The 2020 budget includes $100,000 for employee relocation expenses,
although expected relocation expenses are estimated to be more. The
budget proposes using $900,000 of unspent balances from prior years to
pay for these additional costs, for a total relocation budget of
$1,000,000. This spending level reflects recent average annual
expenditures for employee relocations and is a $250,000 increase over
the 2019 Board-approved budget. Relocation costs are paid by the NCUA
to employees who are competitively selected for a promotion or new job
within the agency in a different geographic area than where they live.
Employee relocations have increased in quantity and cost per employee
in recent years, especially in 2019. The larger number of employee
relocations is partly the result of additional hiring and partly from
the effects of the 2018 NCUA reorganization. The increase in relocation
costs is also related to changes in the 2017 tax law that now treats
all relocation reimbursements as taxable income. Like other government
agencies and private sector employees, the NCUA must now reimburse
employees not just for their relocation expenses, but also for the
personal tax liability resulting from those payments.
Continuous business process improvements and financial controls
have decreased costs for printing, and other administrative costs,
which are estimated to be $112,000 less than in 2019.
The 2021 budget request for the Administrative Services category is
expected to increase by $250,000, or 4.2 percent, due to increases in
the employee relocation budget.
Contracted Services
The 2020 budget includes $43.3 million for Contracted Services.
This is a $5.3 million, or 13.8 percent, increase compared to the 2019
Board-approved budget. The Contracted Services budget category includes
costs incurred when products and services are acquired in the
commercial marketplace. Acquiring specific expertise or services from
contract providers is often the most cost-effective approach to fulfill
the NCUA's mission. Such services include critical mission support such
as information technology equipment and software development,
accounting and auditing services, and specialized subject matter
expertise that enable staff to focus on core mission execution.
The majority of funding in the Contracted Services category is
related to the NCUA's priority to implement a robust supervision
framework by identifying and resolving traditional risk concerns such
as interest rate risk, credit risk, and industry concentration risk, as
well as by addressing new and evolving operational risks such as
cybersecurity threats. Growth in the contracted services budget
category results primarily from new operations and maintenance costs
associated with ongoing capital investments, such as replacements for
the AIRES and CU Online. Other costs include core agency business
operation systems such as accounting and payroll processing, and
various recurring costs, as described in the seven major categories,
below:
[ssquf] Information Technology Operations and Maintenance (45 percent
of contracted services)
--IT network support services and help desk support
--Contractor program and web support and network and equipment
maintenance services
--Administration of software products such as Microsoft Office,
Share Point and audio visual services
[ssquf] Administrative Support and Other Services (14 percent of
contracted services)
--Examination and Supervision program support
--Technical support for examination and cybersecurity training
programs
--Equipment maintenance services
--Legal services and other expert consulting support
--Other administrative mission support services for the NCUA
central office
[[Page 59149]]
[ssquf] Accounting, Procurement, Payroll and Human Resources Systems
(10 percent of contracted services)
--Accounting and procurement systems and support
--Human resources, payroll, and employee services
--Equal employment opportunity and diversity programs
[ssquf] Building Operations, Maintenance, and Security (10 percent of
contracted services)
--Central office facility operations and maintenance
--Building security and continuity programs
--Personnel security and administrative programs
[ssquf] Information Technology Security (9 percent of contracted
services)
--Enhanced secure data storage and operations
--Information security programs
--Security system assessment services
[ssquf] Training (7 percent of contracted services)
--Examiner staff, technical and specialized training and
development
--Senior executive and mission support staff professional
development
[ssquf] Audit and Financial Management Support (5 percent of contracted
services)
--Annual audit support services
--Material loss reviews
--Investigation support services
--Financial management support services
The following pie chart illustrates the breakout of the seven
categories for the total 2020 contracted services budget of $43.3
million.
[GRAPHIC] [TIFF OMITTED] TN01NO19.036
Major programs within the contracted services category include:
[ssquf] Training requirements for the examiner workforce. The
NCUA's most important resource is its highly educated, experienced, and
skilled workforce. It is important that staff have the proper
knowledge, skills, and abilities to perform assigned duties and meet
emerging needs. Each year, Credit Union Examiners attend several levels
of training, including in core areas such as capital markets, consumer
compliance, and specialized lending. The training deliverables for 2020
include the MERIT training sessions discussed elsewhere in this
document, classes offered by the Federal Financial Institutions
Examination Council, new examiner classes, and subject matter expert
training sessions for the NCUA examiners.
Starting in 2020, the NCUA is reducing its financial support for
training for state examiners. Budgets for state examiner training at
the FFIEC have been reduced by approximately 50 percent.
Contracted service providers, in partnership with the NCUA subject
matter experts, will develop and design subject matter expert training
classes for examiners and conduct a triennial review of several modules
of the NCUA's core course curriculum. Additionally, contracted service
providers and central office staff will continue conducting
organizational development and teambuilding training to help support
new team operations as a result of the Agency reorganization.
[ssquf] The NCUA's information security program supports ongoing
efforts to strengthen cybersecurity and ensure compliance with the
Federal Information System Management Act.
[ssquf] Agency financial management services, human resources
technology support, and payroll services. The NCUA contracts for these
back-office support services with the U.S. Department of
Transportation's Enterprise Service Center (DOT/ESC) and the General
Services Administration. The NCUA's human resource system, HR Links,
also adopted by other federal agencies, is a shared solution that
automates routine human
[[Page 59150]]
resource tasks and improves time and attendance functionality.
[ssquf] Audit. The NCUA Office of Inspector General contracts with
an accounting firm to conduct the annual audit of the agency's four
permanent funds. The results of these audits are posted annually on the
NCUA website and also included as part of the agency's Annual Report.
A significant share of the budget for the Contracted Services
category finances on-going infrastructure support for the agency. For
example, the NCUA relies on recurring contracted services to maintain a
number of the agency's examination systems that will replace legacy
systems such as AIRES and CU Online. In future budgets, annual
Operation and Maintenance costs for the MERIT system will be included
in the Contract Services spending category. Several of the NCUA's core
information technology systems and processes also require additional
contract support in 2020, which result in increased budgets in the
Contracted Services category, as described below.
Within the budget for the Office of Chief Information Officer, an
additional $0.7 million is required primarily for the operations and
maintenance costs of capital projects delivered in 2019 and 2020, and
for other information technology hardware critical to ensure business
continuity.
Within the budget for the Office of Chief Financial Officer, the
annual fee paid to the Department of Transportation (DOT) for the
NCUA's financial management system is roughly the same as the 2019
level of $1.2 million.
Within the budget for the Office of Continuity and Security
Management, the Central Office building's physical access controls will
be replaced in 2020, which is expected to cost approximately $600,000.
In addition, mandatory reimbursement to the Office of Personnel
Management for background investigations will increase by an estimated
$125,000 in 2020.
The 2021 budget for Contracted Services is estimated to increase by
$4,000,000, or 9.3 percent, compared to 2020, largely due to the
operations and maintenance costs resulting from the delivery of capital
projects funded in prior years.
VI. Capital Budget
Overview
Annually, the NCUA uses a rigorous investment review process to
identify the agency's needs for information technology (IT), facility
improvements and repairs, and other multi-year capital investments. The
NCUA staff review the agency's inventory of owned facilities,
equipment, information technology systems, and information technology
hardware to determine what requires repair, major renovation, or
replacement. The staff then make recommendations for prioritized
investments to the Executive Director and the NCUA Board.
Routine repairs and lifecycle-driven property renovations are
necessary to properly maintain investments in the NCUA's central office
building in Alexandria, Virginia and the agency's owned office building
in Austin, Texas. The NCUA facility manager assesses the agency's
properties to determine the need for essential repairs, replacement of
building systems that have reached the end of their engineered lives,
or renovations required to support changes in the agency's
organizational structure or to address revisions to building standards
and codes.
IT systems and hardware are another significant capital expenditure
for modern organizations. The 2019 budget allowed the NCUA to deliver
and deploy a number of cybersecurity and governance tools, and the
first iteration of ESM with several projects included, such as the
first release of MERIT in 2019. The 2020 budget maintains the
investment in current and replacement IT systems.
The budget fully supports the NCUA's effort to modernize its IT
infrastructure and applications, including the full rollout of MERIT,
the NCUA's Examination and Supervision Solution (ESS) project, which
will replace the legacy Automated Integrated Regulatory Examination
System (AIRES) system. Other IT investments include ongoing
enhancements and upgrades to enhance decades-old legacy systems,
network servers, incident and vulnerability management systems to
enhance the agency's cybersecurity posture, and various hardware
investments to refresh agency networks and ensure staff have the tools
necessary to maintain and increase their productivity.
The NCUA's 2020 capital budget is $25.1 million. The capital budget
funds the NCUA's long-term investments. The Information Technology
Prioritization Council recommended $20.9 million for IT software
development projects and $2.7 million in other IT investments for 2020.
The NCUA facilities require $1.5 million in capital investments.
Detailed descriptions of all 2020 capital projects, including a
discussion of how each project helps the agency achieve its strategic
goals and objectives, are provided in Appendix B.
Summary of Capital Projects
Examination and Supervision Solution and Infrastructure Hosting ($15.8
Million)
The purpose of the Examination and Supervision Solution and
Infrastructure Hosting (ESS&IH) project is to implement a new,
flexible, technical foundation to enable current and future NCUA
business process modernization initiatives, and replace the NCUA's
legacy exam system, AIRES, with a new customized Commercial-Off-The-
Shelf (COTS) solution. In 2020, all NCUA examiners will be trained to
use the new MERIT system, with full implementation expected by the
fourth quarter.
Enterprise Central Data Repository ($1.1 Million)
The Enterprise Central Data Repository (ECDR) project will
implement a central data repository that will serve as the data
integration point for ESS, ONES's analytic tools, the NCUA's legacy
applications and the Data Collection Solution (DCS). The ECDR will
become an enterprise solution for the NCUA allowing the agency to
transition in a phased approach from the existing legacy databases to a
cloud-based data repository serving the agency's needs.
Enterprise Data Program ($0.45 Million)
The purpose of this project is the centralization, organization and
storage of the NCUA data. The primary goal is to enable the NCUA to
manage enterprise data as a strategic asset through its full lifecycle
(create/collect, manage/move, consume, dispose). The Enterprise Data
Program (EDP) will also facilitate the centralization and organization
of the NCUA's data with an authoritative source so analysis is more
accurate, simple and easily distributed across the agency.
Asset and Liabilities Management Application ($2.1 Million)
The purpose of the Asset and Liabilities Management (ALM)
application is for the NCUA to build internal analytical capabilities
to run supervisory stress testing in house and to conduct regular
quantitative risk assessments by procuring and configuring off-the-
shelf analytical tools, models and software used commonly in stress
testing and other risk management activities.
This effort delivers a complete solution that will focus on
modernizing the NCUA's supervision tools and approaches, identifying
material risks facing the covered credit unions, and
[[Page 59151]]
tailoring resources to the material risks and risk focused exams. This
effort will allow the NCUA to reduce the existing third party
contractor's role to only consultation.
Enterprise Learning Management System Replacement ($1.0 Million)
The purpose of the Enterprise Learning Management System (LMS)
Replacement project is to conduct market research, initiate an
acquisition, create a project management plan, and execute the
production and implementation of a cost-effective, cloud-based solution
and training services that provides the NCUA with the full-range of
eLearning functionality associated with a modern LMS. This will allow
for enhanced examiner utilization and accessibility driven by quality
content, ease of use and system reliability, role-based interface,
ability to view personalized pages by role, centralized content and,
adherence to federally mandated reporting requirements and records
management requirements.
Integrated Financial Management System Analysis ($0.4 Million)
The purpose of this project is to analyze financial system
improvements. The NCUA's current financial management system service
provider increased the fee it charges the NCUA in 2019 by 40 percent.
The NCUA plans to review various options to obtain better financial
management results in a cost-effective manner.
Enterprise Laptop Lease ($0.65 Million)
The purpose of the Enterprise Laptop Refresh project is to provide
the NCUA with a more efficient, mobile friendly, and secure tool to
help employees better perform their jobs at a reasonable cost.
Information Technology Infrastructure, Platform and Security Refresh
($2.0 Million)
The purpose of the Information Technology (IT) Infrastructure,
Platform and Security Refresh project is to refresh and/or replace
routers, switches virtual servers, wireless, virtual private network,
infrastructure appliances, end of life and end of service components in
order to ensure that the NCUA data is secure and operations are stable.
NCUA Website Development ($0.1 Million)
The purpose of the Web Services project is to serve the web-related
needs of the internal NCUA stakeholders and the public. The project
provides design, development, and maintenance of the agency's public
websites: NCUA.gov and MyCreditUnion.gov.
Central Office Renovations ($0.5 Million)
NCUA headquarters renovation project will improve overall space
utilization in the NCUA-owned Central Office. The goal of the project
is to improve operational efficiency while decreasing operating cost by
discontinuing commercial office leases and consolidating all
Washington-region operations within one owned building. The project
will increase the NCUA headquarters building capacity and some offices
currently on separate floors will be collocated onto one floor,
increasing operational efficiency.
Central Office Heating, Ventilation, and Air Conditioning (HVAC) System
Replacement ($0.75 Million)
The NCUA central office HVAC system replacement project will
recapitalize the HVAC system in the agency's central office building,
including all cooling towers, air handlers, boilers and HVAC
components. The current HVAC system is original to the facility, 24
years old and obsolete. The current system is at the end of its usable
life and it is not working efficiently.
Austin, Texas Office Building Modernization ($0.27 million)
In 2020, the NCUA will continue its multi-year improvement project
at the Austin, Texas office building. These capital improvements are
required for the facility to continue routine and safe operations, and
align with the lifecycle replacement required for critical
infrastructure.
VII. Share Insurance Fund Administrative Budget
Overview
The Share Insurance Fund Administrative budget funds direct costs
associated with authorized Share Insurance Fund activities. The direct
charges to the Share Insurance Fund include costs associated with the
NCUA Guaranteed Note (NGN) program and administrative costs, and
represent total estimated costs to the Share Insurance Fund.\10\ The
Share Insurance Fund Administrative budget funds five positions that
were formerly part of the Temporary Corporate Credit Union
Stabilization Fund (Stabilization Fund) budget.
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\10\ Note these direct costs are exclusive of any costs that are
shared with the Operating Fund through the Overhead Transfer Rate,
and with payments available upon requisition by the Board, without
fiscal year limitation, for insurance under section 1787 of this
title, and for providing assistance and making expenditures under
section 1788 of this title in connection with the liquidation or
threatened liquidation of insured credit unions as it may determine
to be proper.
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The cost of the NGN program and the Corporate System Resolution
Program, including costs associated with the administration of those
programs, are funded from the Share Insurance Fund Administrative
budget. These costs have no impact on the NCUA's current and future
Operating Fund budgets. The budget for the Share Insurance Fund also
includes funding for expenditures previously authorized as direct
expenses of the Share Insurance Fund for items such as state examiner
computer leases, training and financial audit support.
The 2020 Share Insurance Fund Administrative budget is estimated to
be $6.5 million, $1.9 million, or 23 percent, less than 2019. The
budget decrease is primarily driven by the removal of third-party
stress testing on large credit unions and the decrease in costs for
valuation services for the NGN program. These services enable the NCUA
to continue supporting the NGN program, which includes managing legacy
assets within the NGN trusts. Legacy assets consist of over 1,000
investment securities that are secured by residential mortgages and
other assets.
The 2021 requested budget supports similar workload and resources,
increasing $482,000, or 7.5 percent, compared to the 2020 funding
level.
Budget Category Descriptions and Major Changes
Salaries and Benefits
The employee pay and benefits expense category for the Share
Insurance Fund Administrative budget is estimated to be $1.47 million,
which represents an increase of $232,000 compared to 2019. This
increase is due to aligning the budget to actual payroll costs for
staff on board, as well as an increase to mandatory agency contribution
rates to the FERS retirement program. Personnel compensation is 23
percent of the total budget. The financial analysts on the NGN team
have specialized technical expertise to manage the remaining $6 billion
of legacy assets. Personnel costs are estimated in a manner similar to
the operating budget.
Travel
The estimated travel cost of $52,000 is less than one percent of
the overall 2019 budget and remains the same as the 2020 budget
estimate. These costs cover all of the travel expenses for the five
staff that manage and support the NGN
[[Page 59152]]
program. Two of the five staff are remote employees and are expected to
travel periodically to the NCUA's central office.
Administrative Training
Training expenses, which represent less than one percent of the
budget, are estimated to be remain at $27,000, based on projections of
employee professional development plans and specialized training
requirements.
Support for the NGN Program (Contract Support)
Contract costs to support the NGN program, which represent 42
percent of the budget, are estimated to be $2.7 million, a decrease of
$0.2 million from the 2019 level. Funding is needed to fulfill
Corporate System Resolution Program requirements and includes outside
professional services such as external valuation experts, financial
specialists, and accountants.
These experts assist the NCUA with the following services:
Consulting Services in the amount of $1.0 million support two NCUA
offices: Examination and Insurance and the Chief Financial Officer.
Services include quarterly management reviews of asset valuations, as
well as analyses of emerging issues. Contractors also provide support
for the annual financial audit process and improvements in internal
controls. Tasks include: Supporting complex accounting and financial
requirements for settlements, sale of legacy assets, parity payments,
changing valuation model assumptions, and other asset disposition
activities. Additionally, professional services are used to assist with
accounting, tax, financial reporting, and systems support for the
corporate Asset Management Estates.
Valuation Services in the amount of $0.9 million funds valuation
support for the NGN legacy assets. As supported by the NGN Oversight
Committee, resources are also needed to conduct special analyses,
including valuations for determining reasonable market prices for
securities to be sold by auction.
Software and Data Subscription Services in the amount of $0.8
million supports technical tools used to provide waterfall models,
calculations, and metrics for the structured investment products
underlying the NGN portfolio. The service provides coverage of all
relevant asset classes, waterfall models that are seasoned and tested
throughout the industry, and a broad array of calculations and metrics.
Financial data analytics play a critical role in the surveillance,
modeling, and pricing of the legacy assets that securitize the NGN
Trusts, as well as supporting the management reviews that the NCUA
performs on the cash flow projections. Now that some of the NGNs have
begun maturing, the NCUA has added data subscription services to
provide additional valuation as well as support for the legacy asset
disposition process.
Other annual subscriptions provide important services related to
surveillance of the portfolio of corporate bonds and mortgage-related
bonds. Independent credit research services include fundamental capital
structure research, credit analyses for surveillance of corporate bond
portfolio and monoline insurer exposure, and direct access to various
industry experts for discussion on specific credits.
Other Direct Expenses
Other direct expenses of the Share Insurance Fund are estimated to
be $2.2 million in 2020, a decrease of $1.9 million, or 47 percent,
compared to the 2019 budget level. NCUA is required to conduct annual
stress testing of certain large credit unions to ensure the credit
unions remain financially sound through challenging economic cycles. In
previous years the NCUA engaged BlackRock Solutions as its partner to
challenge the stress test results prepared by the covered credit
unions. Over a multi-year endeavor, the NCUA has procured the
personnel, data, and systems to conduct this analysis internally.
Accordingly, the NCUA has determined it will not engage BlackRock
Solutions for the 2020 stress test cycle and has removed this cost from
the budget. Had BlackRock been engaged for the 2020 cycle, the agency
would have incurred $3 million in costs.
The $0.7 million increase in the estimated costs for state examiner
training is driven by the MERIT travel and training requirement.
BILLING CODE 7535-01-P
[[Page 59153]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.037
BILLING CODE 7535-01-C
The NCUA website has a dedicated section that provides financial
reports for the Share Insurance Fund, \11\ and a separate page that
explains the NCUA Guaranteed Notes Program and provides comprehensive
reporting and analysis on the legacy assets.\12\
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\11\ See: https://www.ncua.gov/services/Pages/share-insurance/reports.aspx.
\12\ See: https://www.ncua.gov/regulation-supervision/Pages/guaranteed-notes.aspx.
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VIII. Financing the NCUA Programs
Overview
As part of the annual budgetary process, the NCUA remains mindful
that its operating funding comes directly from federal and state
chartered credit unions. The agency strives to ensure that any
allocation of these funds follows a thorough review of the necessity of
the expenditures and whether programs are operating in an efficient,
effective, transparent, and fully accountable manner.
To achieve its statutory mission, the NCUA incurs various expenses,
including those involved in examining
[[Page 59154]]
and supervising federally insured credit unions. The NCUA Board adopts
an Operating Budget, including the Capital Budget, in the fall of each
year to fund the vast majority of the costs of operating the
agency.\13\ The Federal Credit Union Act authorizes two primary sources
to fund the Operating Budget:
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\13\ Some costs are directly charged to the Share Insurance Fund
when appropriate to do so. For example, costs for training and
equipment provided to State Supervisory Authorities are directly
charged to the Share Insurance Fund.
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(1) Requisitions from the Share Insurance Fund ``for such
administrative and other expenses incurred in carrying out the purposes
of [Title II of the Act] as [the Board] may determine to be proper'';
\14\ and
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\14\ 12 U.S.C. 1783(a).
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(2) ``fees and assessments (including income earned on insurance
deposits) levied on insured credit unions under [the Act].'' \15\ Among
the fees levied under the Act are annual Operating Fees, which are
required for federal credit unions under 12 U.S.C. 1755 ``and may be
expended by the Board to defray the expenses incurred in carrying out
the provisions of [the Act,] including the examination and supervision
of [federal credit unions].''
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\15\ 12 U.S.C. 1766(j)(3). Other sources of income for the
Operating Budget have included interest income, funds from
publication sales, parking fee income, and rental income.
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Taken together, these dual authorities effectively require the
Board to determine which expenses are appropriately paid from each
source while giving the Board broad discretion in allocating expenses.
In 1972, the Government Accountability Office recommended the NCUA
adopt a method for properly allocating Operating Budget costs--that is,
the portion of the NCUA's budget funded by requisitions from the Share
Insurance Fund and the portion covered by Operating Fees paid by
federal credit unions.\16\ The NCUA has since used an allocation
methodology, known as the Overhead Transfer Rate (OTR), to determine
how much of the Operating Budget to fund with a requisition from the
Share Insurance Fund.
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\16\ https://www.gao.gov/assets/210/203181.pdf.
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To allocate agency expenses between these two primary funding
sources, the NCUA uses the OTR methodology. The OTR is the formula the
NCUA uses to allocate insurance-related expenses to the Share Insurance
Fund under Title II. Almost all other operating expenses are collected
through annual Operating Fees paid by federal credit unions.\17\
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\17\ Annual Operating Fees must ``be determined according to a
schedule, or schedules, or other method determined by the NCUA Board
to be appropriate, which gives due consideration to the expenses of
the [NCUA] in carrying out its responsibilities under the [Act] and
to the ability of [FCUs] to pay the fee.'' 12 U.S.C. 1755(b).
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Two statutory provisions directly limit the Board's discretion with
respect to Share Insurance Fund requisitions for the NCUA's Operating
Budget and, hence, the OTR. First, expenses funded from the Share
Insurance Fund must carry out the purposes of Title II of the Act,
which relate to share insurance.\18\ Second, the NCUA may not fund its
entire Operating Budget through charges to the Share Insurance
Fund.\19\ The NCUA has not imposed additional policy or regulatory
limitations on its discretion for determining the OTR.
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\18\ 12 U.S.C. 1783(a).
\19\ The Act in 12 U.S.C. 1755(a) states, ``[i]n accordance with
rules prescribed by the Board, each [federal credit union] shall pay
to the [NCUA] an annual operating fee which may be composed of one
or more charges identified as to the function or functions for which
assessed.'' See also 12 U.S.C. 1766(j)(3).
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Overhead Transfer Rate (OTR)
The NCUA Board approved the current methodology for calculating the
OTR at its November 2017 open meeting.\20\ The OTR is designed to cover
the NCUA's costs of examining and supervising the risk to the Share
Insurance Fund posed by all federally insured credit unions, as well as
the costs of administering the fund. The OTR represents the percentage
of the agency's operating budget paid for by a transfer from the Share
Insurance Fund. Federally insured credit unions are not billed for, and
do not have to remit, the OTR amount; instead, it is transferred
directly to the Operating Fund from the Share Insurance Fund. This
transfer, therefore, represents a cost to all federally insured credit
unions.
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\20\ 82 FR 55644 (Nov. 22, 2017).
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The OTR formula is based on the following underlying principles to
allocate agency operating costs:
1. Time spent examining and supervising federal credit unions is
allocated as 50 percent insurance related.\21\
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\21\ The 50 percent allocation mathematically emulates an
examination and supervision program design where the NCUA would
alternate examinations, and/or conduct joint examinations, between
its insurance function and its prudential regulator function if they
were separate units within the NCUA. It reflects an equal sharing of
supervisory responsibilities between the NCUA's dual roles as
charterer/prudential regulator and insurer given both roles have a
vested interest in the safety and soundness of federal credit
unions. It is consistent with the alternating examinations the FDIC
and state regulators conduct for insured state-chartered banks as
mandated by Congress. Further, it reflects that the NCUA is
responsible for managing risk to the Share Insurance Fund and
therefore should not rely solely on examinations and supervision
conducted by the prudential regulator.
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2. All time and costs the NCUA spends supervising or evaluating the
risks posed by federally insured, state-chartered credit unions or
other entities that the NCUA does not charter or regulate (for example,
third-party vendors and CUSOs) are allocated as 100 percent insurance
related.\22\
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\22\ The NCUA does not charter state-chartered credit unions nor
serve as their prudential regulator. The NCUA's role with respect to
federally insured state-chartered credit unions is as insurer.
Therefore, all examination and supervision work and other agency
costs attributable to insured state-chartered credit unions is
allocated as 100 percent insurance related.
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3. Time and costs related to the NCUA's role as charterer and
enforcer of consumer protection and other non-insurance based laws
governing the operation of credit unions (like field of membership
requirements) are allocated as 0 percent insurance related.\23\
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\23\ As the federal agency with the responsibility to charter
federal credit unions and enforce non-insurance related laws
governing how credit unions operate in the marketplace, the NCUA
resources allocated to these functions are properly assigned to its
role as charterer/prudential regulator.
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4. Time and costs related to the NCUA's role in administering
federal share insurance and the Share Insurance Fund are allocated as
100 percent insurance related.\24\
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\24\ The NCUA conducts liquidations of credit unions, insured
share payouts, and other resolution activities in its role as
insurer. Also, activities related to share insurance, such as
answering consumer inquiries about insurance coverage, are a
function of the NCUA's role as insurer.
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These four principles are applied to the activities and costs of
the agency, which results in the portion of the agency's Operating
Budget that is transferred from the Share Insurance Fund. Based on the
Board-approved methodology, the OTR for 2020 is modestly higher than
2019, and estimated to be 61.3 percent. Thus, 61.3 percent of the total
Operating Budget is estimated to be paid out of the Share Insurance
Fund. The remaining 38.7 percent of the Operating Budget is estimated
to be paid for through the Operating Fee. The explicit and implicit
distribution of total Operating Budget costs for federal credit unions
and federally insured, state-chartered credit unions is as follows:
[[Page 59155]]
------------------------------------------------------------------------
Federally insured,
Est. share of the operating Federal credit state-chartered
budget covered by: unions (percent) credit unions
(percent)
------------------------------------------------------------------------
Federal Credit Union 38.7 0.0
Operating Fee..............
OTR x Percent of Insured 31.3 (61.3 x 51.1) 30.0 (61.3 x 48.9)
Shares.....................
-------------------------------------------
Total................... 70.0 30.0
------------------------------------------------------------------------
In terms of accounting for funds transferred from the Share
Insurance Fund to the Operating Fund, the OTR is applied to actual
expenses incurred each month. Therefore, the rate calculated by the OTR
formula is multiplied by each month's actual operating expenses and
charged to the Share Insurance Fund. Because of this monthly
reconciliation to actual operating expenditures, when the NCUA's
expenditures are less than budgeted, the amount charged to the Share
Insurance Fund is also less--and those lower expenditures benefit both
federally chartered and state charted credit unions.
The following chart illustrates the share of the Operating Budget
paid by federal credit unions (FCUs, 70.0%) and federally insured,
state-chartered credit unions (FISCUs, 30.0%).
[GRAPHIC] [TIFF OMITTED] TN01NO19.038
The Board delegated authority to the Chief Financial Officer to
administer the methodology approved by the Board for calculating the
Operating Fees, and to set the fee schedule as calculated per the
approved methodology outlined in this section. There is no change to
the underlying approved Operating Fee methodology for 2020; the change
in the assessments for 2020 are due to changes in the OTR rate and to
indexing the fee schedule for projected asset growth.
For 2020, based on the OTR methodology discussed above, the
resulting share of the budget that is funded from the Operating Fee is
$144.8 million. This equates to 0.0181 percent of the estimated federal
credit union assets for December 2019. The overall increase for the
operating fee is 1.2 percent over 2019.
The Operating Fee will be assessed to federal credit unions based
on estimated year-end assets. Credit unions with assets less than $1
million will not be assessed an Operating Fee. To set the assessment
scale for 2020, federal credit union asset growth will be projected
through December 31, 2019. Based on the June 30, 2019, Call Report
data, annual growth is projected to be 5.6 percent at year end. The
asset level dividing points will be increased by this same projected
growth rate. Assets are indexed annually to preserve the same relative
relationship of the scale to applicable asset base.
To establish the rate applicable to each asset level, the factors
outlined in the table below result in an average Operating Fee rate
increase of 1.2 percent for natural person federal credit unions. The
corporate federal credit union rate scale remains unchanged from prior
years.
To illustrate the rate impact for federal credit unions with assets
under $1.5 billion, the fee increases from $269.4 per million dollars
of assets, to $272.7 per one million dollars of assets. This is an
increase of $3.3 per million dollars of assets, or 1.2 percent.
Federal credit union assets between $1.5 billion and $4.8 billion
would be assessed at a rate of $79.48 per million, and assets above
$4.8 billion would be
[[Page 59156]]
assessed at $26.54 per million. As noted above, these tiers were
indexed to the 5.6 percent projected asset growth, and the rates are
increased by 1.2 percent.
The following tables illustrate the methodology and calculations
used to develop the Operating Fee.
BILLING CODE 7535-01-P
[GRAPHIC] [TIFF OMITTED] TN01NO19.039
[[Page 59157]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.040
IX. Appendix A: Supplemental Budget Information
[GRAPHIC] [TIFF OMITTED] TN01NO19.041
[[Page 59158]]
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[[Page 59165]]
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[[Page 59166]]
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[[Page 59167]]
X. Appendix B. Capital Projects
[GRAPHIC] [TIFF OMITTED] TN01NO19.051
[[Page 59168]]
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[[Page 59169]]
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[[Page 59172]]
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[[Page 59173]]
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[[Page 59174]]
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[[Page 59175]]
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[[Page 59179]]
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[[Page 59180]]
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[[Page 59181]]
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[[Page 59183]]
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[[Page 59184]]
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[[Page 59185]]
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[[Page 59186]]
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[[Page 59187]]
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[[Page 59188]]
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[[Page 59189]]
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[[Page 59190]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.081
[[Page 59191]]
[GRAPHIC] [TIFF OMITTED] TN01NO19.082
[[Page 59192]]
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[FR Doc. 2019-23856 Filed 10-31-19; 8:45 am]
BILLING CODE 7535-01-C