Comment from QuantyPhi, LLC

Comment on NCUA Voluntary EGRPRA Review – Regulatory Publication and Voluntary Review Docket: NCUA‑2024‑0014 QuantyPhi appreciates the opportunity to comment on the National Credit Union Administration’s voluntary review under the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA). We support the Board’s objective of reducing outdated, unnecessary, or unduly burdensome regulatory expectations while preserving safety and soundness and enabling credit unions, particularly small and less complex institutions, to focus limited resources on managing material risks and serving members. QuantyPhi is a credit‑union‑aligned shared‑services provider supporting federally insured credit unions with balance sheet risk analytics, consulting, and decision support across interest rate risk (IRR), asset‑liability management (ALM), CECL, and liquidity. Our perspective reflects direct experience working with many institutions and observing how regulatory expectations are implemented in practice, especially at small credit unions with limited staffing, data infrastructure, and operational capacity. We encourage the NCUA to explicitly recognize simplified, Call Report‑based ALM modeling, when implemented to clear methodological and governance standards, as a permissible and appropriate compliance option for less complex credit unions, including institutions at or below approximately $100 million in assets. When executed properly, Call Report‑based ALM modeling is not a shortcut. It is a disciplined approach that uses NCUA Call Report (Form 5300) data within established balance sheet risk frameworks to produce reproducible and decision‑useful measures of Net Economic Value (NEV) sensitivity, Net Interest Income (NII) sensitivity, and liquidity position, while materially reducing operational and data‑maintenance burden. This approach is consistent with existing NCUA regulations and supervisory guidance, which emphasize that a credit union’s IRR and ALM program should be commensurate with its size, complexity, and risk profile. In practice, however, many small credit unions remain uncertain about examiner expectations and may feel pressure to adopt modeling approaches that are disproportionate to their complexity. Explicit supervisory recognition of simplified, Call Report‑based ALM modeling would reduce uncertainty, improve consistency across examinations, and reinforce the NCUA’s commitment to proportional, risk‑focused supervision. Standardized simplified ALM analytics could also support supervisory efficiency. For smaller institutions, Call Report‑based NEV, NII, and liquidity analytics could provide examiners with a consistent baseline view of balance sheet risk prior to examinations, support more effective scoping, and reduce duplicative data requests. Between examination cycles, periodic updates based on reported data could assist in identifying emerging risk trends or outliers relative to peers without replacing institution‑level ALM responsibility. QuantyPhi appreciates the Board’s leadership in undertaking this voluntary EGRPRA review. We respectfully encourage the NCUA to recognize Call Report‑based ALM modeling, implemented to defined standards and supported by shared‑service delivery, as a practical means of reducing burden for small, less complex credit unions while strengthening consistency, usability, and supervisory efficiency across NEV, NII, and liquidity risk management. Please see the attached letter for additional detail.