ALEXANDRIA, Va.–The NCUA board has put out for 60-day comment a proposal related to its Operating Fee Schedule Methodology, with the key being the exclusion of Paycheck Protection Program loans when calculating the operating fee.
Not doing so would mean the temporary boost in CU assets that PPP loans reflect would mean a higher operating fee for those CUs that have made the loans. Most of those loans are expected to be forgiven as per PPP rules.
Currently, total assets are calculated using the FCU’s Dec. 31 Call Report of the preceding year. Under the proposed rule, total assets would be calculated as the average total assets reported on the FCU’s previous four Call Reports available at the time the NCUA board approves the agency’s budget for the upcoming year, adjusted for any excludable programs as determined by the board.
The operating fee methodology determines how it apportions operating fees charged to federal credit unions, which is used to fund part of the NCUA’s annual budget.
NCUA is proposing:
• Clarification of the treatment of capital project budgets when calculating the operating fees
• Clarification of the treatment of miscellaneous revenues when calculating the operating fees
• Modification of the approach for calculating the annual inflationary adjustments to the thresholds for the operating fee rate tiers
Additional Comment
NCUA is also seeking comment on potential future enhancements to the methodology, and has separately proposed amending its rule for determining total assets used as the basis for calculating the operating fee due from any FCU.
The proposed rule would also delete from the current regulation references to the Credit Union System Investment Program and the Credit Union Homeowners Affordability Relief Program, both of which no longer exist. Third, the proposed rule would amend the period used for the calculation of an FCU’s total assets.
Finally, the proposed rule also would make some minor technical changes.
NCUA noted it has separately published a notice and requested public comment about the methodologies it uses for computing the Overhead Transfer Rate and setting the annual operating fee schedule for fees charged to FCUs.