All Posts By

dawn.kennedy@cuda.ie

Loan Underwriting Level 4 – Introduction to Small Business Lending

By Competency and Training, Owner Members

CUDA are hosting a Half Day Loan Underwriting Level 4, Introduction to Small Business Lending on Wednesday 13th November at Clayton Hotel, Fonthill Road, Liffey Valley, Dublin, D22 X4W6.  Registration will take place at 9.00am.

This half day Introduction to Small Business Lending will primarily target Credit Unions who are currently providing or intend to provide Small Business Loans to members.  The training will be provided by Noel McArdle, Credit Knowledge Limited.

The material content for this training programme will include the following:

Loan Underwriting Level 4: Introduction to Small Business Lending

  • Understanding specific issues that arise when lending to the self-employed members
  • Understanding sole trader, partnership and limited company trading structures
  • Understanding the different types of trading accounts that will come in from self-employed members
  • Understanding how to deal with business plans and projections
  • Practical sole trader case study practice techniques to:
    • Understand the profit and loss account and what it tells the lender. Use four key profit ratios
    • Understand the balance sheet and what it tells the lender and work the gearing ratio
    • Change profit into cash and check the business has cash to meet is commitments
    • Check ability to repay for loans to the business and/or to the member for personal purposes
    • Understand the implications of taxation for the sole trader
    • Review key underwriting checks

3 CPD Hours are accredited from LIA & IOB for this programme.

 Tea/Coffee will be provided on arrival and lunch will also be provided.

We would greatly appreciate if you could let us know at your earliest convenience, who from your CU would like to attend  to roisin.smith@cuda.ie  as soon as  possible.   We very much look forward to hearing from you.

Leadership Masterclass – Succession Planning for CUs – 6th November

By Competency and Training, Owner Members

CUDA is delighted to announce as part of our Leadership Masterclass series this evening event “Succession Planning for Credit Unions”, which will take place from 6pm on Wednesday 6th November 2019 at the Clayton Hotel in Liffey Valley (https://www.claytonhotelliffeyvalley.com/contact-us/).

Credit unions are obliged to have a detailed succession plan for the board and management team to ensure that the credit union maintains an appropriate level and mix of skills and competencies at non-executive and executive level in order to support the credit union’s strategic goals. This purpose of this training event is to provide guidance and support to Credit Unions in meeting their obligations in relation to succession planning – both in terms of the Board, committees and more broadly at an executive level.

It should be noted that the Central Bank of Ireland have identified succession planning weakness as a common governance risk emerging in credit unions [PRISM Supervisory Commentary 2019] and in this regard we would propose that this event is attended by members of the Board, including members of the Nomination Committee, members of the Board Oversight Committees  and executive personnel proving the Board and/or Nomination Committee  with support in this area. We are delighted that Laura Powney & Frank Scott Lennon from HR For Better Workplaces will be presenting at this event and sharing their years of experience in this area.

This event will focus on the legal and regulatory requirements for succession planning for Boards and Committees and how to meet those requirements, in particular:

  • Recruiting in line with your Credit Union’s Strategic Plan
  • Identifying skill strengths and weaknesses on Board and committees
  • Identifying volunteer competencies
  • Screening applications against desired competencies
  • Putting arrangements in place to avoid over-reliance on any one individual
  • Providing mechanisms for delegation of responsibility, including revolving roles where appropriate

And on a boarder level, we will look at supplemental requirements when considering succession planning at senior management level.

Registration, with tea, coffee & sandwiches, will take place from 5.30pm for a 6pm start, to end around 8.30pm.  If you would like to register any attendees for this event, please email their details to dawn.kennedy@cuda.ie.

Hive User Group

By Owner Members, Strategic Development

Hive, the Solution Centre managed CRM system is the digital platform or place where all other plug-ins can and will reside, e.g. the loan application form, the member application form, Percolate etc. It is also the platform to support a wide range of sales and service processes. A good example of the combining of these two functions is the ‘member consent’ gathering facility which is being delivered in an incredibly low-cost relative to competition, low

This will be a quarterly forum dedicated to driving this collaborative platform to support participants lending business and operational efficiency.

For further information please contact Cathal or Kevin at cathal.tyther@solutioncentre.ie or kevin.johnson@cuda.ie

Solution Centre Programme Update

By Owner Members, Strategic Development

We are in the process of communicating with each of the ten participating credit unions in relation to the Digital Transformation Programme 2018 (DTP18) of which they were a contributing partner. The goal is to provide an update on the programme of work, conclude this phase and outline for them how they can benefit from the knowledge and solutions developed. We conducted a full review of DTP18, recognising certain shortcomings, notably in communication, we are adjusting our approach based on these learnings, and this has been factored into the CUDA strategic plan.

Our review concluded that 16 of the original 21 deliverables are complete, with 5 of the original deliverables not live today. Of these, 3 are being actively worked upon and can reasonably be expected to be launched in coming months, 2 must be revisited in light of learnings and changing requirements. These are all set out in the communication and a sample of that detail is provided below:

Scope based on Investment Invitation

Category Projects Target Delivery Status Dec 2018 Status Today Next Step
Digital Transformation

Hive

Projects to digitise current business practices and new digitally enabled services

1.      Hive, lead management integrated with digital marketing

 

Goals: Revenue growth, process efficiency

Q1 Delayed

Additional legal work required to ensure compliance, contracts with participating credit unions.

Completed

Live in 4 CUs, 11,000 loan enquiries processed since launch, 67% conversion, €23.5 million issued.

User group meeting in Microsoft HQ on 22.10.2019 (provisional)

Solution Centre New Deliverable

By Owner Members, Strategic Development

The on-line loan application for credit union members has now gone live. While noting that each loan related Solution Centre feature has its standalone benefits, the new loan application form facility connects the flow from Digital Marketing [e.g. Facebook and google adword campaigns], with Percolate which uses eircodes to confirm residence or employment within common bond, ID Pal to upload Member ID Verification [noting via CUDA was the only compliant way in which this can be achieved], On-line Loan Application that allows prospective borrower enter details with minimum questions based on answers provided, and then upload to Hive where the application can be managed appropriately to conclusion.

Beneficial Ownership Register – 4th EU Money Laundering Directive

By Compliance, Owner Members, Representation

CUDA attended the AML Private Sector Consultative Forum (PSCF) last month and provided an update to your CUs.  The Department of Finance (DOF) and Central Bank were in attendance.  CUDA wish to give you an update in relation to the Beneficial Ownership Register, requirements under the 4th EU Money Laundering Directive and European Union (Anti-Money Laundering: Beneficial Ownership of Corporate Entities) Regulations 2016.

CUDA previously communicated with your Credit Union, in February 2017 and provided guidance in relation to the setting up the Beneficial Ownership Register (BOR) at your CU.  There have been significant delays at government level in the setting up of the Beneficial Ownership Register due to delays in implementing legislative provisions etc.  Ireland has been under significant pressure to finalise this element of the 4th AMLD and EU infringements are imminent if Ireland cannot comply ASAP.   Draft regulations on Beneficial Ownership of Corporate Entities) Regulations 2019 have already been circulated to your CU.

While CUs are unlikely to be as significantly impacted as other financial institutions, a number of requirements were set out in the 2017 guidance.  The following is a summary of requirements for CUs.

 

  1. Establish the beneficial owners of the credit union

Establish the beneficial owners of the credit union.  For the purposes of the Regulations, a “beneficial owner” is a person who ultimately owns or controls the relevant entity, in this case the credit union…..   The credit union must, at a minimum, record the information in respect of each director and the chief executive officer/manager of the credit union in the Register as its beneficial owners.   

  1. Obtain the required information and enter it on the Beneficial Ownership Register

 When the credit union has established its beneficial ownership, the requisite information and supporting documentation for the purposes of the Regulations must be obtained from them and entered on to the Register.  As this is most likely to apply to the senior managing officials of the credit union, the following sets out the matters that should be included in respect of them

  • Name
  • Date of Birth
  • Nationality;
  • Residential Address;
  • Statement of the nature and extent of interest held by that beneficial owner (We would suggest that the position held by the person in the credit union could be included here).
  • Date on which that person was entered in the Register as a beneficial owner; and
  • Date on which that person ceases to be a beneficial owner (whenever applicable).
  • PPSN — It is noted in the new draft regulations that a further requirement for PPSN is now also included and hence will need to be captured on the beneficial ownership register.

Credit Unions Reserves – transfers in and out

By Compliance, Owner Members, Representation

In 2017, CUDA sought and obtained a practical interpretation to the restrictive and prescriptive reserve requirements contained in the 2016 Regulations. Despite the Regulations requiring that reserves must be “perpetual in nature”, we obtained CBI confirmation that transfers can be made by a credit union into and out of reserves held in excess of the 10% RR requirement. Please find below June 2017 Info Briefing post on this, and we attach the RCU/CUDA correspondence as circulated following our progress on this topic. Where required, please circulate the attached letter to your auditors.

June 2017 Info Briefing

We have now circulated correspondence between the RCU and CUDA to your credit unions following concerns relating to the perpetual and non-distributive nature of all reserves.           
The concerns centred on the apparent restrictive nature of the 2016 Regulations with respect to reserves (namely, Reg 3(1) (a-c)). Setion 45(1), 1997 Act, as amended, requires a credit union to ensure that the regulatory reserve is unrestricted and non-distributable. Section 45(2) requires that a credit union ensure all reserves remain adequate. However, Regulation 3(1) went a step further by requiring that all reserves are perpetual in nature, unrestricted and non-distributable. The difficulty is that this presents the possibility that credit unions are unable to utilise funds in their reserve accounts for distribution as dividend or otherwise intended.
Whilst it is acceptable that the regulatory reserve is defined as realised financial reserve (i.e. unrestricted and non-distributable), ensuring all reserves (as required under the Regulations) are perpetual and non-distributable was hampering credit unions effectively utilising the funds and ensuring that the accounts are maintained adequately taking into account the nature, scale and complexity of the credit union. 
We sought and obtained direction from the RCU in relation to Regulation 5, which requires a credit union to ensure compliance with Part 2 of the Regulations and Section 45, i.e. how can a credit union maintain the adequateness of the reserve if additional reserves (i.e. the reserve minus the regulatory reserve) cannot be decreased as well as increased in line with credit union requirements? 
The correspondence, now circulated, confirms that:
  • it is for the board of directors of each credit union to decide on the amount of reserves to hold in excess of this minimum requirement having taken prudent account of the scale and complexity of the credit union’s business, its risk profile and prevailing market conditions.
  • transfers can be made by a credit union into and out of reserves held in excess of the 10% minimum RR requirement so long as the credit union has satisfied itself that the total level of reserves held are appropriate taking prudent account of the scale and complexity of the credit union’s business, its risk profile and prevailing market conditions.

Credit Unions should refer to the correspondence for further analysis and if you have any queries, please contact us at the CUDA Offices (elaine.larke@cuda.ie or kevin.johnson@cuda.ie).

Revised Credit Agreement

By Compliance, Owner Members, Representation

As you know we have been working on a revised Credit Agreement. Recently, we concentrated on PPI and considered options in relation to the removal of reference to PPI from the credit agreement.  The preferred option is that separate correspondence will issue in relation to PPI alongside the Credit Agreement. We have also been working closely with NALA with the intent of obtaining the Plain English Mark for the credit agreement going forward.  The revised credit agreement is with the CBI. They are carrying out their internal assessment of the proposed amendments and once they revert to us, our next step will be to talk to the IT Providers. Further updates on the revised Credit Agreement can be found on CUDA connect.

Accrued Interest

By Compliance, Governance, Owner Members

Historical / Current Cases

CUDA requested an update from the Registrar at our recent quarterly meeting. The RCU noted that the assessment is still ongoing but indicated that they are prioritising year end and observing what credit unions are putting in their accounts. Central Bank will be dealing with credit unions on a case by case basis with regard to the treatment of legacy cases in the annual accounts.

If you require any further information on this please don’t hesitate to speak directly to us in the CUDA office (kevin.johnson.cuda.ie / elaine.larke@cuda.ie).