March 26, 2012


  • Nice article. The new IRR regs have a listed compliance date of 9/30/12. A significant percentage of CUs have been so focused on credit risk the past few years they have given little attention to IRR and concentration risk. Lots of $1+ billion CUs with woefully inadequate IRR management programs, heavy exposure to >=15yr fixed resi loans and investment portfolios with heavy optionality or overly lengthy durations. This is another accident waiting to happen. Thanks for giving the issue some press.
    Michael Gagliardi
  • Good thoughts - well timed
  • If you have everything to worry about, you have nothing to worry about!

    I'm worried that we have an industry after Debbie Matz and Dave Marquie retire.
  • A ship in harbor is safe, but that is not what ships are built for.
    Steve Bowles