CUNA supports the proposed exclusion of Paycheck Protection Program (PPP) loans from a federal credit union’s total assets for purposes of calculating its operating fee. CUNA believes this change should help ensure federal credit unions interested in making PPP loans do not bear greater financial burdens for doing so.
The proposal would also amend:
- The current rule to exclude from total assets any loan an FCU reports under the PPP or similar future programs approved for exclusion by NCUA for purposes of calculating the annual operating fee; and
- The period used for the calculation of a federal credit union’s total assets as the average total assets reported on the credit union’s previous four Call Reports.
“We support the proposed change to a four-quarter average of reported assets in calculating the operating fee. We agree with the agency that this change will address seasonality and provide greater certainty of upcoming operating fees,” the letter reads. “Further, this change would reduce the risk that the NCUA will collect less in operating fee revenue than it requires if actual assets reported in FCUs’ December Call Reports are below the asset growth assumption used to set the operating fee rates in the budget.
“While we support the proposed change to a four-quarter average, we ask the NCUA to regularly review this change and its impact to ensure it does not cause any unintended consequences, such as a significant and/or inaccurate change in the annual operating fee,” it adds.