CrossState Submits Comment Letters to Federal Reserve Board, NCUA

On Monday, June 29, CrossState submitted two comment letters. The first letter was submitted to the Board of Governors of the Federal Reserve (Board) continuing our effort to seek clarification of the permanency of the Board’s action to eliminate the numeric limitation of the six convenient transfers from savings accounts. CrossState again expressed its appreciation of the Board’s swift action to amend Regulation D to help consumers during the pandemic; however, it is unclear from the Rule if it is temporary or permanent.  

CrossState also submitted a letter to the National Credit Union Administration (NCUA) in support of NCUA’s amendments to the Rule regarding the Central Liquidity Facility (CLF).  Membership in the Central Liquidity Facility provides credit unions with a back-up liquidity source. The COVID-19 pandemic has created challenges for all businesses, including credit unions, in meeting liquidity needs. NCUA’s amendments are an effort to make the CLF more attractive to new members. Some amendments are temporary and will sunset at the end of 2020 and some amendments are permanent.  

The permanent amendments include the elimination of the six-month waiting period for CLF advances to new members of the Facility, and a change to the collateral requirements. CrossState encourages all credit unions to join the CLF as membership in the CLF permits credit unions to borrow from the Facility to meet their own liquidity needs, but also exponentially increases the amount available for other credit unions to borrow from the Facility. 

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