Survey on Credit Union Access to Emergency Liquidity




Listed below are a number of statements related to the NCUA advanced notice of proposed rulemaking regarding how credit unions should maintain access to emergency liquidity. Please indicate how strongly you agree or disagree with each statement and answer any follow-up question(s) that apply.
1a. There should be a new regulation to require all federally-insured credit unions to maintain access to backup federal liquidity sources in times of financial emergency and distressed economic circumstances.





1b. If you agree, what do you feel are the standards, provisions, and considerations that should be part of a potential new regulation?

2a. Credit unions under a certain asset threshold should be exempt from these requirements.





2b. If you agree, what should the asset threshold be?

3. NCUA should follow the Basel III international liquidity framework's guideline that a depository institution must maintain “an adequate level of unencumbered, high-quality liquid assets that can be converted into cash to meet its liquidity needs for a 30 calendar day time horizon under a significantly severe liquidity stress scenario specified by supervisors."





4a. Credit unions should be able to satisfy potential liquidity requirements by holding a certain percentage of its assets in highly liquid (maturity of 90 days or less) Treasury securities.





4b. If you agree, please tell us...

5. What is the best way for credit unions to continue to access the Central Liquidity Facility (CLF)? (Please check only ONE.)




6. Are there other sources of credit or liquidity beyond the CLF and Discount Window that you believe credit unions could use for a backup federal liquidity source?



7. What recommendations do you have regarding the current processes and requirements to apply for liquidity from the CLF or the Discount Window?

8. Listed below are three additional statements related to the Central Liquidity Facility. Please indicate how strongly you agree or disagree with each statement.
Agree
strongly		 Agree
somewhat		 Disagree
somewhat		 Disagree
strongly
The CLF should become more like the Discount Window.
Corporate credit unions should continue to provide CLF access.
Corporate credit unons should be encouraged to purchase CLF stock as
agents for natural person credit unions.

9. What changes would you recommend to the CLF statute to modernize the CLF?

10. How should the CLF continue to operate after USC Bridge completes the wind-down process to satisfy future credit union contingency liquidity needs?

11. What recommendations does your credit union have on ways to minimize regulatory burden on credit unions regarding these potential new liquidity requirements?

12. Are you with a credit union or a league?



13. (If applicable) What is your credit union's asset size?










14. Please provide any additional comments or concerns you may have about NCUA's advanced notice of proposed rulemaking regarding how credit unions should maintain access to emergency liquidity.

Thank you for your efforts in responding.