We hope you are keeping well as you deal with this unprecedented challenge for everyone. We fully appreciate how difficult it is for you and your teams as you try to support concerned members. CUDA will continue to keep you updated and provide you with as much practical supports as we can. We have a good up-take with regard to the new web form and now have non owner member credit unions requesting access to it. Our priority is to get owner member credit unions set up first. The new web form will greatly assist in managing arrears and pre-arrears issues. If you haven’t been in touch already please don’t hesitate to contact us and we will get you set up asap.
Meanwhile, CUDA had a conference call meeting with the Registrar and his senior team today. The Registrar was very sincere in extending best wishes for the health and well-being of all associated with CUDA and their families. The following items were discussed:
- The importance of continuation of provision of critical member services, as they understand the impact it will have on many people if these services cease. CBI see this under three headings:
- Stopping closure of credit union offices;
- Provision of credit union services remotely;
- Containment to temporary closure and resuming service asap
- CCR – The Central Bank informed us that they will ensure consistency across all lenders when developing practical measures so that the credit record of those who avail of a payment break will not be adversely affected during this extraordinary time.
- CBI would like to see feasibility assessment, i.e. identify the operational, accounting and legal issues, to address need for reciprocal arrangements for these without them;
- The importance of communication with members around continuance of service and support to the members.
- Welcomed the CUDA shared approach to management of Loan Flexibility Requests.
- Forbearance, Credit union may seek to adopt measures outside their policies but must act within own risk appetite and revised policies.
- Provisioning, Credit unions should continue to apply the 2018 Provisioning Guidelines whilst adhering to their own risk appetite and policies. Board may want to revisit their risk appetite and policies in this regard. It is a matter for the Board.
- Reserves, Boards are free to determine what reserves should be maintained above the regulatory requirement.
- The CBI are restricted to providing MRR x6 @0%, and additional deposits @-.50bps. We raised a range of concerns relating to investments and these will be revisited.
- We will have further meetings next Tuesday and Friday.
We have a meeting with Dept. of Finance tomorrow and will continue to keep you posted.
Stay safe, regards for now, Kevin