December 16, 2011
RE: Changes to Line of Credit Approval and Reporting Process
To the Chief Executive Officer of the Credit Union Addressed:
This letter serves to notify you that the Division of Banks (Division) has amended its procedures regarding lines of credit.
Currently, under the authority of Massachusetts General Laws chapter 171, section 73, state-chartered credit unions must request approval from the Commissioner of Banks to establish a line of credit and must request approval from the Commissioner every two years to renew said line. In addition, credit unions with existing lines of credit must notify the Division of all drawings and repayments on the line of credit. The Division recognizes that the administrative function associated with maintaining approval with the Division for a line of credit can be burdensome. In addition, during the Regional Roundtable Meetings conducted by the Division and Massachusetts Credit Union League in June 2011, feedback from the state-chartered credit unions indicated that the Division should consider reviewing its procedures in this area.
After a review of the line of credit approval and reporting procedures, the following changes are effective immediately:
|Old Procedure||New Procedure|
|Approval to renew the line is required every two years from the Division||One-time initial approval of the line with no required renewal from the Division|
|Notify the Division of all drawings and repayments on each line of credit||Reporting of drawings and repayments is no longer required|
The Division utilizes other processes, such as off-site monitoring and the examination program, to oversee line of credit activity and risks. Nevertheless, to ensure that we are able to continue to effectively oversee certain borrowing relationships under Massachusetts General Laws chapter 171, section 73, some procedures will not change. For example, initial approval by the Division is required to establish a new line of credit. In addition, the Division would still need to be notified in writing at least thirty days in advance of any material changes to the credit line, such as an increase in the approved amount or if the line is closed.
The Division appreciates the feedback we received during the Regional Roundtable Meetings and always welcomes suggestions you may have. We hope that these changes will result in less regulatory burden for credit union officials, provide greater flexibility to manage your credit union’s liquidity, and allow management to focus its efforts on meeting member and community needs.
Should you have any questions relative to this matter, please contact Chief Director Andrea Cipolla at (617)956-1532 or firstname.lastname@example.org.
David J. Cotney
Commissioner of Banks
cc: Daniel F. Egan, Jr., President
Massachusetts Credit Union League