Another comment letter was filed by the Missouri Credit Union Association (MCUA) and the Credit Union National Association (CUNA) with the National Credit Union Administration (NCUA) regarding proposed changes to emergency liquidity from the Central Liquidity Facility (CLF). MCUA stongly opposes the final rule on emergency liquidity and states there is already interagency guidance on liquidity policies, plans and procedures that took effect in May 2010. The other regulators, to MCUA's knowledge, have not found the need to issue regulations on emergency liquidity.
NCUA had not provided sufficient rationale for the proposal and MCUA did not support a requirement for credit unions to secure access to specific types of emergency liquidity beyond what other federally insured depository institutions are required to do. To CUNA's knowledge, NCUA is the only federal financial regulator pursuing a rule on emergency liquidity at this time. Are credit unions really that much more risky than their commercial banking counterparts?
If despite the fact that the legal underpinnings of the proposal were not sufficiently detailed a final rule is pursued, CUNA and MCUA urged a number of changes.
CUNA’s System Liquidity Task Force has been considering the role and future of the CLF. As stated in its comment letter, CUNA believes the CLF has utility, and recognizes the important role that it played during the financial crisis as NCUA developed its course of action regarding corporate credit unions.
However, with the demise of U.S. Central Bridge, MCUA and CUNA want to work with NCUA to develop improvements, a number of which would be legislative, such as to remove the requirement for stock subscriptions to the CLF and to facilitate the ability of credit unions to use the CLF as readily as institutions are able to use the Federal Reserve’s Discount Window.