What do You Need to get an S code 2 in NCUA's Newly Proposed CAMELS?

What do You Need to get an S code 2 (Sensitivity to Market Risk) in the new Proposed #CAMELS the #NCUA Board voted on today?


Per the proposal - Code 2 S definition:


1. Market #risk sensitivity is adequately controlled and that there is only moderate potential that the earnings performance or capital position will be adversely affected;


2. Risk management practices are satisfactory for the size, sophistication, and market risk accepted by the #creditunion; and ,


3. The level of earnings and capital provide adequate support for the degree of market risk taken by the credit union


Per the Proposal What is an S - Code 3:


1. Control of market risk sensitivity needs improvement or that there is significant potential that the earnings performance or capital position will be adversely affected;


When might it start? No sooner than Q1 2022... which I view as optimistic... Approved 3-0 ... 60 day comment period...more to follow...


If you would like to discuss this or your current challenge, message me here or at info@marktreichel.com and we can set up a free strategy session.



******************************************************************************************


If you want more details see below: per the Board Action Memorandum (BAM)


"SUMMARY. The attached proposed rule would add the “S” (Sensitivity to Market Risk) component to the existing CAMEL rating system and redefine the "L" (Liquidity Risk) component, thus updating the rating system from CAMEL to CAMELS.


The proposal to add the “S” component will enhance transparency and allow the NCUA, State Supervisory Authorities, and federally insured credit unions to better distinguish between liquidity risk (“L”) and sensitivity to market risk (“S”). The amendment would also enhance consistency between the regulation of credit unions and other financial institutions.


The estimated implementation of this proposal is approximately one year or as early as the first quarter of 2022."


The entire BAM can be found here:


https://www.ncua.gov/files/agenda-items/AG20210114Item5a.pdf


If you want even MORE details here is a bit more on the thought behind the rule and the definitions for all 5 codes:


I. Summary of the Proposed Rule The Board is proposing to add the “S” component to the existing CAMEL rating system and redefine the current “L” component. Evaluation of these as individual components will enhance the communication and monitoring of credit unions’ sensitivity to market risk and liquidity risk. The Board is requesting comments on this proposal, such as, but not limited to, the definitions of both the “L” and “S” components and the criteria for each of the specific 1-5 assigned ratings. For example, the Board may consider modifying the rating descriptions used for the “L” and “S” ratings used by the other banking agencies rating system (The Uniform Financial Institutions Rating System (UFIRS)), detailed below in Sections IIA and IIB of this proposal.15

A. “S” Component for Sensitivity to Market Risk The sensitivity to market risk reflects the exposure of a credit union’s current and prospective earnings level and economic capital position arising from changes in market prices and the general level of interest rates. Effective risk management programs include comprehensive interest rate risk policies, appropriate and identifiable risk limits, clearly defined risk mitigation strategies, and a suitable governance framework. Sensitivity to Market Risk ratings are based on, but not limited to, the following evaluation factors: • Sensitivity of a credit union's current and future earnings and economic value of capital to adverse changes in market prices and interest rates; • Management’s ability to identify, measure, monitor, and control exposure to market risk considering a credit union’s size, complexity, and risk profile; and • The nature and complexity of interest rate risk exposure. Examiners will rate a credit union’s “S” CAMELS rating component on a scale of “1” to “5” using the same rating descriptions for “S” as the other banking agencies.

“S” RatingDescription CODE 1· Market risk sensitivity is well controlled and that there is minimal potential that the earnings performance or capital position will be adversely affected;

· Risk management practices are strong for the size, sophistication, and market risk accepted by the institution; and

· The level of earnings and capital provide substantial support for the degree of market risk taken by the institution CODE 2· Market risk sensitivity is adequately controlled and that there is only moderate potential that the earnings performance or capital position will be adversely affected;

· Risk management practices are satisfactory for the size, sophistication, and market risk accepted by the institution; and

· The level of earnings and capital provide adequate support for the degree of market risk taken by the institution CODE 3· Control of market risk sensitivity needs improvement or that there is significant potential that the earnings performance or capital position will be adversely affected;


· Risk management practices need to be improved given the size, sophistication, and level of market risk accepted by the institution; and


· The level of earnings and capital may not adequately support the degree of market risk taken by the institution


CODE 4


· Control of market risk sensitivity is unacceptable or that there is high potential that the earnings performance or capital position will be adversely affected;


· Risk management practices are deficient for the size, sophistication, and level of market risk accepted by the institution; and

· The level of earnings and capital provide inadequate support for the degree of market risk taken by the institution


The dreaded CODE 5:


· Control of market risk sensitivity is unacceptable or that the level of market risk taken by the institution is an imminent threat to its viability; and


· Risk management practices are wholly inadequate for the size, sophistication, and level of market risk accepted by the institution


If you really like details and want to review the entire proposed rule, you can find it at the link below:


https://www.ncua.gov/files/agenda-items/AG20210114Item5b.pdf