Date: Wednesday, September 29, 2021
Time: 11:00 am – 12:00 pm
Location: Videoconference
FSRA hosted an information session with the credit union and caisses populaires sector to roll out the implementation of the Recovery Planning Guidance released on July 5, 2021. Canadian Credit Union Association representatives were also invited to the information session.
General comments
Aligned to FSRA’s principles-based and outcomes-focused regulation, FSRA shared its desired outcomes of the Recovery Planning Guidance: to enhance the crisis preparedness and overall resiliency of the credit unions and caisses populaires sector.
Scope and highlights of the discussions are as follows:
- Rationale and background of the Recovery Planning Guidance and what was completed prior to the roll out
- FSRA’s interpretation of recovery planning requirements under By-Law No. 5 and the Credit Union and Caisses Populaires Act, 1994
- The benefits of recovery planning
- The difference between recovery plans and other plans
- How recovery plans focus on severe stress scenarios that could threaten the viability of an institution
- The importance of integrating the recovery plan with key risk management policies, processes, risk appetite and frameworks
- FRSA’s practices and processes when employing its assessment of credit union’s adherence with the interpretation including the application of the principle of proportionality
- The interim submission is focused on three elements: B. Key measures and associated triggers; C. Recovery options; and D. Scenario analysis
- The interim submission on January 14, 2022 is intended to provide credit unions with an opportunity to receive directional feedback to ensure the development of a credible plan for the final submission on January 13, 2023 as listed in the Guidance
Session attendee Q&A:
Credit unions in attendance asked questions about the availability of templates, whether recovery plans duplicate other plans (e.g., DRP, BCP, ICAAP), timelines, content, liquidity and capital measures and dashboards.
Some credit unions were also interested in copies of the presentation materials.
FSRA staff responded to the questions and will also be available to answer additional questions in the follow-up Q&A sessions scheduled for early October.
Next steps
FSRA will hold four Q&A sessions. Session groupings were determined by institution size.
The Q&A sessions are designed to facilitate more in-depth discussion of the key elements of recovery planning and allow credit unions to ask more specific questions.