The risk of a systemic credit union crisis is growing and is predominantly located within the top 100 who control close onto 80% of assets (loans & investments) and savings. Many will not be able to generate the surpluses required to fund loan losses, maintain regulatory capital and pay a dividend to savers. International experience indicates loan loss experience of between 50-70% on unsecured consumer loan arrears during bank credit crisis. Credit union arrears over ten weeks, a key risk threshold for short term consumer loans is escalating and heading towards 15% on average. Independent entities collective statistics hide individual experience significantly higher then the sectoral arrears of 13.5% reported by the regulator last week.
Investment losses have not yet been worked fully through accounts and some will continue to write down values this year. In 100 loan reviews carried out on the larger operators in the last year for the regulator over 85% were found to have underprovided for bad loans.
Credit union arrears over 10 weeks have jumped by over 100% from 6% to 13.5% (FR) before the new provisioning rules are applied this year which will cause over 300 to increase provisions by between 20-40% (ILCU). 20 are in serious financial trouble (FR)- this group probably includes some of the larger credit unions (€50-400m). One of the top five credit unions with assets >€200m was forced to provide for 10% of its loan book following regulatory intervention last year. Its entire net worth was represented by the value of its building which was conveniently valued at book value in its accounts. It experienced a small run as its agm was delayed.
New loan issues have shrunk on average 27% last year but total loans only declined by 4% which is evidence of the scale of rescheduling non-performing loans. Loan loss experience in crisis elsewhere on consumer unsecured loans is close to 10% - some higher depending on the pathology – credit union lending is undiversified and concentrated within geographic common bonds and employee sectors (public service).
Not all hit the 10% regulatory reserve ratio for last year and some didn’t make the 7.75% interim ratio. Upwards of ten have yet to hold their AGM’s for last year- this group contains some of the top 100. The regulator is concerned the ILCU SPS fund which it says is €120m would not be capable of supporting a solvency crisis. This scheme is legally unreliable, unapproved and unregulated by the FR and FSA and is only available on a discretionary basis to members of the ILCU both North and South (over 500 credit unions). There are a number of large credit unions who are not members of ILCU (North and South). As a backstop to a deposit guarantee scheme, in other words a stabilisation component of a credit union deposit insurance system, it is woefully inadequate and not fit for purpose which is why the FR is issuing a consultation document on credit union stabilisation. Questions have been raised over the liquidity of the fund and its ability to provide the emergency support required to stave off a systemic crisis in savers confidence.
Any analysis of typical credit union operations throws up a host of challenges related not only to rising loan losses but shrinking loan issues, higher liquidity, solvency and provisioning requirements, escalating operating costs and savings migration.
An unknown number of credit unions will not be able to trade their way out of trouble as the business model is bust. Regulatory rules containing risks – the regulatory reserve ratio and rules on rescheduling loans shows a backbone and willingness to grasp the nettle lacking until now. Hence the collective lobbying by credit unionists against amendments to legislation granting the regulator powers to issue binding rules on credit unions. They want light touch regulation to continue. The game is up for credit unions as this state is on the hook for implicitly guaranteeing over €11bn in savers deposits.
Kaplan