CUDA welcomes the publication of this awaited ICURN peer review report. It contains several key recommendations which the Regulators Network believes will improve the effectiveness of compliance within credit unions. We note that the report considers the financial performance of credit unions up to year-end 2022, and therefore does not have the benefit of the improvements achieved in 2023.
From our initial read of the report, we welcome suggestions calling for the CBI to update aspects of the Credit Union Handbook related to operational risk, fraud reporting requirements, and increase engagement with credit union boards and staff on risk management practices.
We particularly welcome the suggestion for further development of the Regulatory Framework to accommodate the growing diversification of credit union business lines, provided credit unions demonstrate the necessary capability and competence. This involves acknowledging and supporting the expanding roles and services offered by credit unions while ensuring they remain within a safe and sound operational framework.
The report notes that the CBI “remain of the view that there is no rationale to change to a risk weighted approach” for determination of capital which is disappointing and this ties up excessive capital. That said we look forward to working with the CBI on their ongoing lending framework review and the associated liquidity regulations. CUDA maintains that a ‘One size fits all’ regulation approach damages both large and small Credit Unions, a new model is required for the sector to sustain and achieve its full potential.