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In preparation for the annual meeting between NAFCU's Board of Directors and the Board of Governors ofthe Federal Reserve System (Fed), we would like to request your input on various issues and learn aboutyour experiences with Fed services. Your responses to these questions are very important to both the Fedand NAFCU, and your help is greatly appreciated. The survey results will be summarized in the 2019NAFCU Report on Credit Unions with a copy provided to you later this year.
Please complete the survey by August 30, 2019. All responses will be kept confidential.
Your Information
NAFCU 2019 Federal Reserve Survey
1. Your Name*
2. Credit Union Name*
3. Charter Number
4. Email Address or Phone Number
Part I of V: Strategic Challenges
NAFCU 2019 Federal Reserve Survey
Slight / none Moderate Significant
Maintaining or increasing capital
Maintaining or improving credit quality
Maintaining or attracting retail deposits
Strengthening net interest margin
Maintaining or increasing non-interest income
Achieving satisfactory mortgage loan volume
Achieving satisfactory business loan volume
Achieving satisfactory consumer loan volume
Meeting regulatory compliance requirements
Maintaining a secure electronic environment
Maintaining access to affordable payments
Expanding your investment in technology
Attracting and retaining skilled staff and management
Managing third party vendors
Slow economic growth within your field of membership
Population loss within your field of membership
Aging member base
Weak housing markets
Decline in a key select employee group (SEG) orcommunity’s primary industry
Lack of growth opportunities
5. Rate the magnitude of the challenges you anticipate over the next three years.
Little to no pressure Moderate pressure Significant pressure
National banks
Community banks
Other credit unions
Fintech firms (e.g.,marketplace andonline lenders, mobilepayment providers,etc.)
6. How much competitive pressure do each of the following place on your credit union?
Significantlydecreased
Moderatelydecreased No change
Moderatelyincreased
Significantlyincreased
National banks
Community banks
Other credit unions
Fintech firms
7. How has the degree of competitive pressure from each of those sectors evolved in recent years?
Little to no concern Moderate concern Significant concern
Credit risk
Interest rate risk
Liquidity risk
Regulatory/ compliance risk
IT/ cyber risk
Operational risk
Fraud risk
Strategic risk (e.g., new business initiatives,succession planning, etc.)
Vendor management risk
8. Indicate expected levels of risk management concerns for the following items over the next threeyears.
9. Which of the following area(s) do you expect to drive spending increases the most over the nextthree years? (please select all that apply)
Information technology
Regulation/ control environment
New products or services
Changes to charter type or field of membership
Acquisitions
Expanding facilities
Advertising and marketing/ branding
Employee compensation/ training
10. Which of the following IT-related projects do you envision your credit union investing in overthe next three years? (please select all that apply)
Core conversion/ upgrade
Servicing/ collection
Mobile banking
Online banking platform
Payments processing
Fraud prevention
Data analytics/ marketing
Automation of compliance or regulatory reporting functions
Customer kiosks/ self-service stations
ATMs
Other (please specify below)
Small vendor Regional vendor
National vendor/core provider/large fintech CUSO In-house
Core conversion/upgrade
Servicing/ collection
Mobile banking
Online bankingplatform
Payments processing
Fraud prevention
Data analytics/marketing
Automation ofcompliance orregulatory reportingfunctions
Customer kiosks/ self-service stations
ATMs
Other (as specified inprevious question)
11. For those projects that you plan to invest in, please identify the most likely technologyprovider(s) or partner(s), if known. (please select all that apply)
12. Roughly what percent of your 2019 operating budget is devoted to cybersecurity?
13. Five years ago, roughly what percent of your operating budget was devoted to cybersecurity?
14. Which of the following issues do you consider critical to your credit union’s continued growthand success? (please select all that apply)
Field of membership
A healthy, appropriate regulatory environment
Capital requirements which are properly aligned with industry risks
Access to secondary mortgage market
A financial marketplace with appropriate safeguards against fraud and data breaches
15. Given the current environment, what is the minimum asset level a credit union needs tosurvive?
$50 million
$100 million
$250 million
$500 million
$1 billion
Other (please specify below)
16. What is the likelihood that your credit union will be involved in a merger in the next three years?
Very likely as a merger
Somewhat likely as a merger
Unlikely
Somewhat likely as a mergee
Very likely as a mergee
Part II of V: Liquidity and Lending
NAFCU 2019 Federal Reserve Survey
Increased available
lines of credit in past 12months
Accessed lines of creditin past 12 months
Tested access inbackup liquidity plan in
past 12 months
Intend to gain access tofunds in next 12
months
Banks
FRB Discount Window
FHLB
Corporate CUs
NCUA CentralLiquidity Facility
Other
For "Other", please specify here
17. With regard to your backup liquidity plan, which of the following options do/did you use?(please select all that apply)
18. How important is a Federal Home Loan Bank (FHLB) to your credit union's daily liquidity needs?
Not an FHLB member
Little to no importance
Somewhat important
Very important
Tightened
considerablyTightenedsomewhat
About thesame
Loosenedsomewhat
Loosenedconsiderably Do not offer
Credit card
Auto loans
First mortgage residential: GSE-eligible
First mortgage residential: All non-GSE
Other residential
Business/ commercial
19. Please indicate how your loan standards have changed in the following categories over the past12 months:
Decreased
substantiallyDecreasedsomewhat
About thesame
Increasedsomewhat
Increasedsubstantially Do not offer
Credit card
Auto loans
First mortgage residential: GSE-eligible
First mortgage residential: All non-GSE
Other residential
Business/ commercial
20. In the past 12 months, how has loan demand changed for the following categories?
21. What are the key factors influencing how heavily you utilize Fannie Mae and Freddie Mac (theGSEs)?
Do not use
Ease of access relative to alternatives
Pricing
Other (please specify below)
22. Other than the GSEs, what options does your credit union use to sell mortgage loans? (pleaseselect all that apply)
None
Mortgage wholesaler
Private placement
CUSO
FHLB
Other (please specify below)
23. What percentage of your first mortgage loans outstanding qualified to be sold to the GSEs as ofJune 2019?
24. Approximately what portion of your residential mortgage originations from the past 12months did you sell to the secondary market?
25. Do you plan to sell a larger or smaller portion over the next 12 months?
Larger
Smaller
About the same
26. Would your mortgage loan originations decrease if FHFA were to raise g-fees?
Yes
No
Not sure
Part III of V: Fee Income
NAFCU 2019 Federal Reserve Survey
Overdraft
NSF
27. How much do you charge for:
28. How often do your members express confusion or dissatisfaction with the required opt-inprocess for overdraft protection?
Never
Rarely
Occasionally
Frequently
29. What percentage of your members have opted in to overdraft protection?
30. Of those who have opted in, roughly what percent used the service during the past 12 months?
31. In general, which of the following best describes the order in which your credit union processestransactions?
As presented
Chronologically
By value, smallest first
By value, largest first
Other (please specify below)
32. The Durbin amendment capping debit interchange rates for issuers larger than $10 billion wentinto effect in October 2011. How would you estimate your credit union’s per-transaction debitinterchange rate changed in that time, after adjusting for any changes in average transactionamount?
Increased
Decreased
About the same
Part IV of V: Regulatory and Legislative Issues
NAFCU 2019 Federal Reserve Survey
Total compliance/ risk management activities
Deposit account compliance
HMDA/ Fair Lending
Unfair, Deceptive, or Abusive Acts and Practices(UDAAP)
Non-mortgage consumer lending regulations
Mortgage regulation compliance
Bank Secrecy Act/ anti-money laundering
IT compliance
Capital rules
33. Please indicate the approximate number of full-time equivalent (FTE) staff members devoted tothe following compliance activities in 2010 (the year of the Dodd-Frank Act).
Total compliance/ risk management activities
Deposit account compliance
HMDA/ Fair Lending
Unfair, Deceptive, or Abusive Acts and Practices(UDAAP)
Non-mortgage consumer lending regulations
Mortgage regulation compliance
Bank Secrecy Act/ anti-money laundering
IT compliance
Capital rules
34. Please indicate the approximate number of full-time equivalent (FTE) staff members devoted tothe following compliance activities currently.
35. Identify the areas in which you expect to increase the number of full-time equivalent (FTE) staffmembers devoted to the following compliance activities in the next three years. (please select allthat apply)
Total compliance/ risk management activities
Deposit account compliance
HMDA/ Fair Lending
Unfair, Deceptive, or Abusive Acts and Practices (UDAAP)
Non-mortgage consumer lending regulations
Mortgage regulation compliance
Bank Secrecy Act/ anti-money laundering
IT compliance
Capital rules
36. Please estimate the approximate dollar amount devoted to compliance activities in 2010 (theyear of the Dodd-Frank Act).
37. Please estimate the approximate dollar amount devoted to compliance activities during themost recent 12 months.
38. Do Regulation D transaction limits generate confusion and questions among your members?
Yes
No
Not sure
39. Do you believe it is necessary to limit the number of monthly transfers on accounts that fallunder Regulation D?
Yes
No
Not sure
40. Does your credit union treat all accounts as transaction accounts for reserving purposes?
Yes
No
Not sure
Yes No Not sure
Number of check fraud attempts
Avg. dollar amount of fraud attempts
41. Has your credit union seen an increase in the number and/or dollar amount of check fraudattempts in recent years?
42. Has your credit union already made business changes (product offerings, balance sheetcomposition, the amount of capital held, etc.) related to risk-based capital requirements or thecurrent expected credit loss (CECL) accounting standard, or do you anticipate doing so in the nearfuture?
Yes
No
Not sure
43. How would you rate the projected combined impact of risk-based capital (RBC) and CECL onyour credit union's ability to serve its members?
No impact
Minimal
Moderate
Significant
Stronglydisagree
Somewhatdisagree Neutral
Somewhatagree
StronglyAgree
The NCUA is appropriately focused on the prudentialconcerns of the credit union system.
The NCUA is responsive to evolving areas of risk within thecredit union system.
44. Based on your credit union’s experience, please indicate the degree to which you agree with thefollowing statements regarding the NCUA’s current regulatory approach.
45. In what areas should the NCUA improve its general examination approach? (please select allthat apply)
IT and data security
BSA/AML compliance
Consumer compliance
Safety and soundness
Other (please specify below)
46. What examination reforms would be most desirable for your credit union? (please select all thatapply)
Improved examiner subject matter expertise
Shortened exam length
Longer exam cycle
Greater utilization of off-site examination
Creation of independent appeals process
Greater advance notification of exam focus areas
Security enhancements to file transfer system
Technology improvements
Other (please specify below)
47. NCUA intends to issue a proposal related to subordinated debt by the end of 2019 to providecredit unions greater capital flexibility. How likely would it be that your credit union would issuesubordinated debt, if permitted to do so?
Very likely
Somewhat likely
Not sure
Somewhat unlikely
Very unlikely
48. What features would be important to you in any subordinated debt proposal?
49. In your most recent NCUA examination, did the examiner apply the Automated CybersecurityExamination Tool (ACET)?
Yes
No
50. If so, what was the highest cybersecurity maturity level achieved across all domains?
Baseline
Evolving
Intermediate
Advanced
Innovative
N/A - we have not been examined with ACET
Not concerning Somewhat concerning Very concerning
GDPR Compliance
California ConsumerPrivacy Act
Compliance with otherstate privacy laws
Potential for NCUA toacquire 3rd partyvendor authority
51. Please indicate your level of concern for the following legal and regulatory issues:
No concern Minimal concern Somewhat concerned Very concerned
Merchant
Payment processor
Third-party vendor
Core service provider
Criminal actor
Insider threat
Non-bank fintechcompany (excludingvendors)
52. Please indicate the level of concern you have for each of the following sources of cybersecurityrisk:
53. Does your credit union currently maintain a diversity or inclusion plan to guide lendingactivities? Such a policy might include a significant unmet needs plan or a section voluntarilyincluded within a general business plan.
Yes
No
Not diverse Somewhat diverse Very diverse
Membershipcomposition
Staff composition
Board composition
54. In terms of race, color, religion/ creed, national origin/ ancestry, sex, age, physical or mentaldisability, and veteran status, how would you describe the level of diversity within your creditunion?
If so, please describe.
55. Does your credit union engage, or plan to engage, in diversity outreach?
Yes
No
56. Is your credit union currently pursuing any of the following changes to your field ofmembership (FOM) or charter? (please select all that apply)
Expansion of FOM
Addition of underserved area
Low income designation
Conversion to state/ federal charter
57. What FOM constraints have imposed the greatest obstacles to growth? (please select all thatapply)
Inability to add underserved area
Small or stagnating SEG groups
Inability to expand into new communities
Slow approval process for FOM amendments
Aging membership
Other (please specify below)
58. In the last 12 months have you turned down a loan application on a non-owner occupied homedue to the 15-year maturity limit?
Yes
No
Not sure
Part V of V: Use of Federal Reserve Services
NAFCU 2019 Federal Reserve Survey
None Some Most All
Corporate CUs
Banks
Federal Reserve
Outside Vendors
59. To what extent does your credit union use the following intermediaries for transaction services?
Very poor
Belowaverage Average
Aboveaverage Excellent Do not use
Coin and Currency Services
Accounting Services
Check 21 Enabled Services
FedImage Services
Paper Check Clearing
FedPayments Reporter Service
FedReceipt Services
Foreign and Canadian CheckServices
FedACH Origination and Receipt
FedGlobal ACH Payments
FedACH SameDay Service
FedComplete Packages
FedTransaction Analyzer Service
National Settlement Service
FedWire Funds Service
FedWire Securities Service
FedLine Direct
FedLine Command
FedLine Advantage
FedLine Web
Fed Discount Window
Educational Services
60. Please rate your experience using the following Fed Services over the past 12 months:
61. Overall, how do you feel the Federal Reserve prices its services?
Very competitive
Competitive
Somewhat competitive
Not competitive
Most competitively priced service
Least competitively priced service
62. Among the services that you use, which do you consider the most and least competitivelypriced?
63. The recently announced FedNow Service will allow depository institutions to settle transactionsin real-time, on a 24x7x365 basis through the Federal Reserve Banks. Although still in development,how will FedNow affect your plans, if any, for faster payment adoption?
Accelerate adoption
Delay adoption
No change
64. FedNow will have an initial transaction limit of $25,000 for real time payments? How would youcharacterize this threshold?
Should be higher
Should be lower
Appropriately balanced