Samantha: Hello, this is Samantha Shares.
This episode covers N C U Aâs
September 20 24 Board Meeting
regulation Simplifying Share Insurance.
Earlier this week we provided
the entire long rule in my voice.
Today is the NCUA Board and staff
in their own words and voices.
This podcast is educational
and is not legal advice.
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And now the rule.
Chairman Harper: The second item
of business is final rule part 745,
simplification of insurance rules.
Staff presenting are Tom Zells.
Senior Staff Attorney, Office of General
Counsel, and Paul Dibble, Consumer
Access Program Officer, Office of
Credit Union Resources and Expansion.
Um, I have to give it to you,
uh, Tom for having a great soccer
game today, and Paul for having a
fantastic shirt tie combination.
Uh, good morning to both of you.
Please start whenever you are ready.
staff (3): Thank you so much.
Uh, good morning, Chairman Harper
and Vice Chairman Hauptman.
We are here today to present a final
rule to amend Part 745 of the NCOA's
Regulations Governing Share Insurance.
The primary intent of the final rule is
to simplify the NCOA's share insurance
coverage rules related to trust accounts.
Before we get into the specifics about the
final rule, I'm going to provide a little
bit of background on how the Federal
Credit Union Act, or FCU Act, addresses
share insurance and a general description
of the current share insurance rules.
Under the FCU Act, the NCUA is responsible
for paying share insurance to any person
with funds lawfully held in a member
account in the event of a federally
insured credit union's failure up to the
standard maximum share insurance amount,
which is currently set at 250, 000.
In general, the FCU Act is not
overly prescriptive on how the share
insurance process works, but does
specify specific treatments for a
few types of accounts, for example,
accounts held by government depositors
and certain retirement accounts.
Otherwise, the FCU Act provides
substantial discretion to the NCOA.
The NCOA has implemented share insurance
requirements in Part 745 of its rules.
Generally, the NCOA determines whether
a member account is insured by grouping
particular categories of accounts
held by a member, such as single
ownership accounts, joint ownership
accounts, revocable trust accounts,
and irrevocable trust accounts.
If an account meets the requirement
for a particular category, the account
is insured up to the 250, 000 limit.
Separately from shares held by the member
in a different account category at the
same federally insured credit union,
for example, provided all requirements
are met, shares in the single ownership
category will be separately insured
from shares in the joint ownership
category held by the same member at the
same federally insured credit union.
We'll now discuss specifics
of the final rule.
I'll turn it over to Paul so
that he can discuss the changes
to the trust account coverage.
Thank you, Tom.
Good morning, chairman Harper.
Good morning, vice Chairman.
Good morning.
staff (4): Uh, the share insurance
process is fairly straightforward
for most types of accounts.
One exception, however, is trust accounts.
The N2A's current regulations
recognize two different types of
insurance categories for funds
held in connection with trust.
Revocable trusts and irrevocable trusts.
The share insurance rules include
additional complexity related to
the number of beneficiaries that
would receive funds, from revocable
trusts and whether irrevocable
trusts include certain contingencies.
Despite previous NTU A efforts to address
confusion related to trust accounts,
the NTU A has received over 8, 500
share insurance questions related to
trust accounts since the end of 2019.
Additionally, the complexity also
causes a potential for delay in
insurance payouts when the NTU A has
been appointed as liquidating agent.
The FDIC, which has deposit
insurance coverage rules that are
comparable to the NQA's rules, has
experienced similar issues related
to its rules on trust accounts.
The final rule makes several changes to
simplify the treatment of trust accounts.
First, the final rule merges the
revocable and irrevocable trust categories
into a new trust accounts category.
This new category includes informal
revocable trust accounts, such
as payable on death accounts.
Formal revocable trust accounts
and irrevocable trust accounts.
The final rule also treats irrevocable
trusts like revocable trusts and
the fact that contingencies would
no longer impact potential coverage.
While the change creates simplicity
as all trust accounts, regardless of
legal form will be treated the same,
it has the potential to reduce share
insurance coverage as the existing
rule provides per the potential for
increased coverage, depending on
whether the member is set up revocable.
So, for members who establish both large
revocable trusts and large irrevocable
trusts to the same beneficiaries, the
final rule may result in reduced coverage.
However, for other members with
irrevocable trusts, the final rule
could result in increased insurance
coverage as irrevocable trusts with
contingencies to multiple beneficiaries
will now have greater insurance coverage.
Second, the rule simplifies the
treatments for shares held in trust
with more than five beneficiaries.
Under the final rule, additional
share insurance coverage would not
be provided if a member leaves trust
funds to more than five beneficiaries,
regardless of the number of
trusts that establish those funds.
Therefore, the maximum amount of
share insurance coverage for trust
funds under the final rule would be 1.
25 million.
This change streamlines the rule,
but has the potential to reduce share
insurance coverage for certain members.
The proposed rule included a question
on the potential effect of this change.
As expressed in the proposed rule,
we do not believe in practical
terms that this change will have
a substantial effect on the shared
insurance coverage for most members.
The comments received also did not
provide an indication to the contrary.
Therefore, under the final rule, the
calculation of insurance coverage for
trust accounts is similar to the rule,
to the rule currently used for revocable
trust for five or fewer beneficiaries.
An account holder's trust account
will be insured in the amount
up to 250, 000 multiplied by.
By the number of trust beneficiaries
not to exceed five, this is regardless
of whether the trust is revocable
or irrevocable, or regardless of
contingencies or the allocation
of funds among the beneficiaries.
This, in effect, limits coverage for each
grantor's trust accounts at each federally
insured credit union to a total of 1.
25 million.
This treatment of trust for share
insurance purposes creates more
parity between the NCOA and the new
trust rules adopted by the FDIC that
became effective on April 1st, 2024.
The final rule adopts the
changes recommended in the
proposed rule as proposed.
Under the final rule, the effective
date of the trust account changes will
be delayed until December 1st, 2026.
This delayed effective date provides
a very similar implementation timeline
to the one provided by the FDIC.
And we'll provide the NCUA staff at
credit unions and credit union members
necessary time to prepare for the changes.
I will now hand it back to Tom so that he
can discuss the comments received on the
proposed trust account changes and some
other changes made by the final rule.
staff (3): Thanks, Paul.
In terms of comments on the trust
account changes, all 11 substantive
comments that the NCUA received
indicated support for the changes.
Common reasons that the commenters
provided for supporting the rule
included providing parity with FDIC
coverage and reducing confusion
regarding coverage of trust accounts.
As noted, commenters did not
express real concern with the new
trust rules effectively limiting
each grantor to a maximum of 1.
25 million in coverage for
their trust account funds.
One commenter specifically stated
that they did not think the 1.
25 million per grantor cap was too
low, as the vast majority of accounts
are well below the level, but did
ask the NCA to track liquidations
to ensure it is not too low.
Other issues commenters addressed
included membership requirements for
trust accounts, reporting of insured
shares on the call report, and whether
the NCOA should provide a delayed
effective date or otherwise insure
already existing accounts or legacy
accounts under the current rules.
The final rule also makes a few
other changes in addition to the
simplified approach to trusts.
The final rule clarifies the
coverage provided to mortgage
servicing accounts for funds that the
mortgage servicer or another party
deposits on behalf of the borrower.
The NCOA's current rules include a
separate insurance category for mortgage
servicing accounts that are comprised
of principal and interest funds.
The current regulations, however,
do not address funds paid in to
a mortgage servicing account by
someone other than the borrower.
By not treating funds deposited
by the servicer the same as funds
deposited by the member, NCOA's
current rules result in inconsistency
in the potential for instability
during periods of economic stress.
The final rule clarifies that these funds
receive similar share insurance treatment,
The This is identical to the treatment
under the FDIC's recent final rule.
The NCUA received six comments
specifically addressing this change.
All of these comments
supported the change.
The final rule makes no alterations to the
changes recommended in the proposed rule.
As this change would provide more
expansive coverage and should not
impose additional burden on credit
unions or account holders, the final
rule does not delay its effect.
It would become effective 30
days after the final rule is
published in the Federal Register.
The final rule also makes some changes
to the NCOA, NCOA's record keeping
regulations for share insurance coverage.
These changes are favorable to members
and provide more flexibility to the
NCOA to include additional documentation
evidencing the intent of the account when
making share insurance determinations.
These changes pose no additional
burden to credit unions.
The NCUA received seven comments
specifically addressing these changes.
All of these comments
supported the changes.
The final rule makes no
substantive changes to the changes
recommended in the proposed rule.
As these changes only explicitly clarify
the flexibility the NCUA has in terms
of records the agency can look to in
evaluating share insurance coverage
and would not impose additional burden
on credit unions or account holders.
The final rule does not delay its effect.
It would become effective 30
days after the final rule was
published in the Federal Register.
That concludes our presentation.
We are happy to answer any
questions you may have.
Chairman Harper: Thank you, Tom and
Paul, for your presentation on the
final rule to simplify certain share
insurance requirements related to
trust accounts and mortgage servicing
accounts, among other things, such as
the record keeping you just mentioned.
And thank you to the many
team members across the agency
who worked collaboratively.
It's a common sense package of
regulatory changes that I fully support.
By establishing a unified trust
accounts category that treats coverage
of funds in both revocable trusts
and irrevocable trusts deposited at
federally insured credit unions in
the same manner, I fully support.
This final rule simplifies the share
insurance regulations and brings the
National Credit Union Share Insurance
Fund into greater alignment with the
Federal Deposit Insurance Corporation's
Deposit Insurance Fund's rules.
That's a positive change not only
for credit union staff who will have
streamlined procedures when working on
such trust accounts, but it's also a
benefit for credit union members who will
better understand their coverage options.
It's also a time saver for the
NCUA's Share Insurance Fund, uh, Fund
Specialists who, I'm sorry, Share
Insurance Specialists who during the
last five years have fielded thousands
of calls, as you've noted, Paul, uh,
about share insurance coverage for
different types of trust accounts.
This rule change will also lead to
greater efficiency in the NCUA's
Asset Management Assistance Center
when managing future liquidations.
Specifically, the final rule, as I
mentioned, eliminates distinct and
separate sets of rules and insurance
coverage calculations for shares of
revocable trusts and irrevocable trusts.
Those rules led to public confusion
about the share insurance coverage
of trust accounts maintained at
federally insured credit unions.
This final rule aligns the coverage
standards for both types of trust accounts
and establishes a simplified formula for
calculating coverage for funds deposited
at federally insured credit unions.
This final rule also allows for more
time for share insurance, more timely
share insurance fund determinations
by NCUA trust, by the NCUA of trust
accounts, which will facilitate faster
payments to account holders in the
event of a credit union liquidation.
In fact, Paul, as I understand,
uh, we've sometimes had to spend
months sorting through trust
records to determine just how much.
Exactly what we've had
to pay and a payout.
In addition, this rule provides members
at federally insured credit unions with
the same protections as consumers who
use trust accounts at banks and thrifts.
Yes, such parity between the
two federal deposit insurance
programs promotes greater public
confidence in the dual systems for
protecting shares and deposits.
And as one commenter noted, such parity
is crucial for maintaining consistency
and fairness in the financial system.
I couldn't agree more.
Public trust in our financial system
must never be taken for granted.
We saw firsthand the effects on consumers
and turmoil in the markets caused by
several large bank failures last year.
Deposit insurance at federally
insured credit unions and banks is
vital as it stabilizes the financial
system during periods of economic
uncertainty and financial stress.
More importantly, it gives consumers
confidence to entrust their hard
earned savings and nest eggs to a
federally insured financial institution.
Additionally, the final rule modifies
the treatment of share insurance
coverage for mortgage servicing
accounts, bringing those standards for
the credit union system into greater
alignment with the banking system when
it comes to deposit insurance coverage.
Credit unions have had pronounced
increases in their mortgage lending
and servicing in the 16 years since
we last updated this portion of the
share insurance coverage rule in 2008,
so this change is an important one.
By giving credit union members Um,
credit union members and members of
the public who use trust accounts and
credit unions who service mortgage
accounts in the same level of protection,
whether the accounts are maintained at
federally insured credit unions or banks.
We must ensure parity to the extent
possible and maintain confidence in our
nation's credit union and banking systems.
I therefore support
this change to our rule.
That said, before closing,
I do have several questions.
First, will the merger of revocable
and irrevocable trust categories
into one single group for share
insurance affect the application,
um, of, or operation of state law?
staff (3): No, it should not.
The rule really just affects the
NCUA's coverage of share insurance and
should have no impact on state law.
Chairman Harper: So, federalism standards,
states can still set their own laws.
This is just for ourselves.
Thank you.
It's good to know that our
regulatory change will not
affect state law in any way.
Second, um, many credit union staff
members, um, staff and members rely
on the NCUA's Your Insured Funds
brochure, as well as MyCreditUnion.
gov to answer questions about
share insurance coverage.
Once we publish these regulatory
changes in the Federal Register.
How quickly do we anticipate
having both resources updated?
staff (4): We can take that.
Um, we're fully committed to
updating the year insured, um,
funds brochure and mycreditunion.
gov as quickly as possible.
Appreciate the importance
of those resources to credit
union staff and members.
Staff have already started working
on the scope of defining, uh, the
necessary updates and assuming, um,
the board approves this final rule
today, we will immediately start an
update on all the relevant materials.
Chairman Harper: And if I recall
though, your insured funds brochure
is, it's a lengthy document, so
it may take a little bit of time.
Forty six
staff (4): pages, I think.
Yeah.
Apparently.
Um, we also recognize the importance of
developing materials that accommodate
the delayed effective date for both,
uh, for the trust account changes.
We're committed to making sure
that those resources are available.
Um, that both help clarify existing share
insurance coverage and, uh, what future
share insurance coverage will, will be.
We plan to post the updated
materials as they are ready.
CURE staff will also continue to
be available to answer any share
insurance questions, um, that staff
and crediting members may have.
Chairman Harper: Yeah.
And I know that the FDIC provided
for a long time frame for
implementation of its change.
Are we providing, uh,
equally a long time frame?
staff (4): Yes.
I believe it's almost identical.
Yes.
It's almost identical to the FDIC one.
Great.
Thank you.
Chairman Harper: I know that I would
like to have the updated resources in
place as soon as possible and appreciate
the hard work of the NCUA team that
will go into completing those tasks.
Finally, in the preamble to
this rule, we note that the 1.
25 million per grantor cap
is unlikely to be too low.
What evidence do we have for
reaching that conclusion, Tom?
What, for example, is the median
size of a trust fund or the
amount of the average inheritance?
staff (3): Sure.
So, uh, the final rule actually cites
survey data indicating that the median
size of a trust fund is around 285, 000,
which is obviously well short of the
maximum coverage available under the rule.
Uh, additionally, comment or input
addressing this issue agreed that the 1.
25 million per grant or cap was unlikely
to be too low as the vast majority of
accounts are well below that level.
Uh, this aligns with, you know,
staff's general experience as well.
Um, that commenter did, however, ask that
the NCOA track liquidations to ensure
the cap is not too low, and the final
rule actually notes that the agency does
plan to continue to track uninsured,
uh, amounts in liquidations, if any, and
can further, uh, Uh, can explore further
changes if that should become warranted.
And in fact,
Chairman Harper: the call report
changes that the Vice Chairman and I
have been both talking about, uh, have
changes related to uninsured shares.
Um, thank you for those answers.
That concludes my remarks.
I now recognize the Vice Chairman.
VC Hauptman: Thank you, sir.
Chairman Harper: Uh, what was 46 pages?
staff (4): You mentioned?
Uh, your insured funds brochure.
Uh, don't, um, don't quote me.
I think it's somewhere on there.
Oh, yeah.
That's a pretty lengthy guidance.
It's lengthy.
VC Hauptman: Today's, uh, rule.
I was looking at 72 pages.
I know it can be a, it gives me pause.
Hey, we're simplifying things.
Here's a 72 page government
document on the simplification.
It can feel a little weird, but I will,
um, I think this is a positive change.
I'm going to be supporting it.
I'll say regulatory relief
can come in a lot of forms.
The best kind is what we're doing
today, which is regulatory relief
that isn't taking on more risk.
Or reducing government oversight.
It's just adding clarity.
I think this is a good time to remind
ourselves that the question of how easy
it is to follow the rules It's determined
solely by those who have to follow
them, not those of us who write them.
NCUA insurance specialists
in the last five years have
received over 17, 000 calls.
Staff estimates that over half of
those are related to coverage for trust
accounts, revocable and irrevocable.
And that 17, 000 Again, just
over half we think are related
to this issue, trust accounts.
That does not include
inquiries we got via email.
It does not include
inquiries from MyCreditUnion.
gov or inquiries received
by NCUA staff directly.
It also doesn't include credit unions
that had questions but got the answer from
another credit union, nor does it include
credit unions that had questions but
were too nervous to tell their regulator.
That, by definition, happens more
often than regulators realize.
So today's action is
Smart Regulatory Relief.
We at the NCUA are also saving
ourselves time and effort.
Both rules on today's board agenda
provide much needed improvements on
consistency, simplification, and clarity.
Today's final rule on insurance
coverage is substantially
unchanged from the proposed rule.
Thank you to the 13 stakeholders
who put, uh, who submitted comments.
These comments were universally supported.
It provides some suggestions
for some changes.
They appreciate the benefits of a
simpler calculation and being at parity
essentially with what the FDIC does.
This rule simplifies and reduces
the number of rules governing
the treatment for trust accounts.
The regulation establishes a
single category for trust accounts
using a common calculation for
both revocable and irrevocable.
The final rule is also intended
to streamline the currently
time consuming trust review
process and facilitate faster.
Payouts to beneficiaries by
reducing unclear and confusing
elements of this rule.
Credit unions, their employees and NCA
staff are better able to serve the public.
The ultimate beneficiary
should be credit union members.
Uh, one last thing on this
topic directly, uh, the way we
really help small credit unions.
It's not by increasing our budget
and adding lots of more exam
hours to answer questions about
our own rules that we wrote.
The way to help is you make it
less burdensome to operate and
start a small credit union.
Succession planning is also easier when
NCUA can help make the job of running a
small credit union a more attractive job.
Sometimes these are labors of love
in some small credit unions and it
could be a little bit more than that.
Um, that concludes my remarks directly
on this, except just to make a public
service announcement, which is, folks,
please update your beneficiaries.
When my mother passed away of her three
children, for some reason, I was the one
that had to do all the paperwork, and
she didn't have a whole lot of money.
But boy, was it easier that the three
of us were named as beneficiaries,
including her credit union account.
Um, got the money quickly to, Dave
Ramsey says, uh, you know, the
one thing you want to leave your
heirs is peace and simplicity.
Um, so, my mother thankfully
updated beneficiaries, that was
a good scenario, and nobody wants
to be, you know, the worst case.
If you remember Atlanta 2016, woman
hired a guy, had her new husband
killed for the insurance money,
but the check went to the ex wife.
You know,
staff: so,
VC Hauptman: moral of the story,
update your beneficiaries.
You know, so.
A couple questions, uh, all right, a
member has a trust account worth over
one and a quarter million, right?
Mm hmm.
Got more than five beneficiaries
at a single credit union.
Is there a mechanism to allow
credit unions and members the
ability to restructure their
accounts to accommodate the changes?
I can
staff (4): take that question.
Uh, it's true that there may be
some instances where a single
member, um, with more than 1.
25 million in trust at a single credit
union may see their coverage reduced.
However, because of some of the
simplifications, um, of what are currently
insured as irrevocable trust accounts.
Um, Regarding restructuring accounts,
members with funds in excess of
the maximum insured amount would
have until the new trust account
coverage provisions go into effect
to restructure their accounts.
The trust account changes in the Final
Rule would not go into effect until
December 1, 2026 over two years from now.
The delayed effective date mirrors the one
the FDIC provided in, in their own rule.
Members with funds over the insured
limit have multiple potential options for
rearranging their accounts depending on
their specific facts and circumstances.
They may just want to move the excess
funds into a different federally
insured credit union to ensure that
all of their funds are insured.
Alternatively, they may be able to
restructure their funds within their
current federally insured credit union so
that the excess funds are insured under
a different insurance category, such as
the single ownership account category.
Uh, in the rare event a member has
a sheriff's certificate that exceeds
a two year delayed effective date
and has trust funds that are over 1.
25 million that would be uninsured,
the member may need to work with their
credit unit to determine the best path
to restructuring the impacted funds
in advance of December 1st, 2026.
I do also want to stress that
I'm only referring to the
restructuring of trust accounts at
a federally insured credit unit.
The final rules impact should be
limited to the insurance coverage of
those accounts, Should not require
an individual's actual formal
trust document to be restructured.
Finally, I think it's worth noting
that where two individuals are co
owners of a trust account, such as a
payable unduty account with updated
beneficiaries and correct beneficiaries,
each co owner is entitled to up to 1.
25 million in coverage if they
have at least five beneficiaries.
In other words, a couple
could have as much as 2.
5 million in coverage of
their trust accounts at one
federal insurance credit union.
That concludes my response.
staff: Whew.
VC Hauptman: Gotcha.
Uh, um, one of the commenters suggested
grandfathering existing trusts.
What's the reasoning for not
doing the grandfathering?
staff (3): Sure.
I can, uh, take that one.
So, that's correct.
We had three commenters that
expressed support for some form of
grandfathering of existing accounts.
Um, in discussing this, the
final rule of preamble refers
to this as legacy coverage.
Those comments were strongly considered.
However, it's staff view that providing
legacy coverage for existing accounts
poses complications and burdens to
federally insured credit unions,
account holders, and the NCUA that
makes such a system largely unworkable.
Uh, you know, in short summary, legacy
coverage would undo the benefits
of simplifying the proposed rule.
Uh, to provide legacy coverage,
the NCOA would have to effectively
maintain two sets of rules, the new
simpler trust rules and also the
entire current regime of trust, uh,
which have generated so much confusion
and resulted in so many questions.
With two sets of rules in place,
there's yet another step which would
need to, which would involve, uh,
adding the multiple existing account.
Which would add to the multiple
existing steps we already have under
the current rules for trust accounts.
So, in evaluating coverage, NCUA,
credit unions, and members would
then first have to ask whether an
account was in existence at the time
the NCUA adopted this new rule, or
the new trust account coverage rule.
Accounts that did exist at that time
would still have the existing complicated
analysis applied to their funds.
In addition to largely undermining the
simplification, clarity, and burden
reduction benefits the rule would
provide, legacy coverage would also pose
yet new questions that could further
complicate share insurance rules.
So just by example, the rule would
need to address what impact change in
beneficiary, an account restructuring,
or other similar action meant for
the legacy status of the account.
Um, so basically add yet another
complication to an already
complicated set of rules.
I also want to reiterate that the
NCUA has consistently tried to make
sure that where it's possible there's
parity between NCUA coverage and
FDIC deposit insurance coverage.
If we were to provide a, you know,
legacy account situation, we would
then not have complete parity
with what FDIC is currently doing.
Uh, our hope is that by providing a
substantially delayed effective date,
which is in excess of two years,
federally insured credit unions and
their account holders should have
enough time to make any needed changes
to their accounts to, uh, essentially
make legacy accounts not necessary.
Yeah,
VC Hauptman: I think that's a fair answer.
I think the comment is not unreasonable.
It's one we sort of expected.
Right.
But I get it.
Uh, we're trying to reduce
everybody's effort and somebody
would say, well, my neighbor just
told me they don't have to do this.
And then we'd have to
explain that to them.
The person answering this question would
have to know that way back in the day.
I mean, this conversation
could be in 20 years.
Yeah.
Um, and it also creates some
strange situations where maybe
you want to take your business
elsewhere, but you're tied in.
Right.
To this old legacy account.
You don't want to disturb that.
Um, so I agree, uh, not a person who
sent that in, not a strange request.
Grandfathering is routinely done.
Uh, in state and federal law, uh, but
our purpose here is simplification,
and I think it's the right call.
Um, and where are we, just give me a
rundown, uh, updates to the forms, the
website, uh, our internal training,
because people are going to maybe
ask questions about this change.
Where are we on preparing people for that?
staff (4): We have the scope
defined, um, so as soon as, you
know, assuming you approve the rule,
today we'll get started, um, on
creating those materials right away.
Thank
VC Hauptman: you both
Chairman Harper: for that.
Back to you, Mr.
Chairman.
Uh, thank you, Mr.
VC Hauptman: Vice Chairman.
Is there a motion?
Yes, sir.
I move that the board approve final rule
part 745 of N2A's rules and regulations as
attached to the board action memorandum.
Chairman Harper: I second the motion.
All those in favor say aye.
Aye.
Aye.
All those opposed say nay.
Let the record show that the ayes have
it and the motion passes two to zero.
Samantha: This concludes the N C U Aâs
September 20 24 Board Meeting action on
regulation Simplifying Share Insurance
If your Credit union could use assistance
with your exam, reach out to Mark Treichel
on LinkedIn, or at mark Treichel dot com.
This is Samantha Shares and
we Thank you for listening.