What's the Dilly-o with treasury & liquidity: a buyer's guide for credit unions

The Dilly-o

Most credit unions should tighten their contingency funding plan (CFP) and test it before they buy anything new. Silicon Valley Bank failed its own liquidity stress tests and had no workable plan to raise cash under stress.⁴ The products we track range from deposit sweeps to a marketplace for buying and selling loan participations.^C Software helps once the plan is sound, so buy for the gap you have.

How we'd size up a vendor

1. Funding reach - does the tool help you reach more than one source of funding, and show what each would cost you in a pinch?
2. Stress testing - can it run your CFP scenarios and repeat them on the schedule your policy sets? Ask to see a test run on your own balance sheet instead of a demo file.
3. Ledger control - when funds move to partner banks, who keeps the record of whose money sits where, and can you see it every day? If the vendor holds the only copy, ask what happens to your members' money if the vendor fails.

What changed this year

NCUA's 2026 priorities say examiners will look at how you build liquidity and rate risk into your CFP and match funding to your risk appetite.⁵ The October 15 CLF proposal would make final the changes NCUA made under two interim final rules.¹ On September 11, 2026, NCUA and the bank regulators proposed new third-party risk guidance, with comments due November 16, 2026.⁶ The proposal would let you tailor contract negotiation and oversight to your size, complexity and risk profile.⁷

Will it work with your systems?

We haven't yet verified how any treasury and liquidity product in our directory fits with a specific core.^C Federal Reserve Financial Services offers Accounting Services, a tool that gives real-time access to Federal Reserve account balances and transaction information for monitoring and reconciliation.^C Cambr says its Sweep product helps manage excess liquidity by routing funds to a network of FDIC-insured institutions.^C Ask your core and digital banking provider which of these they already connect to, how often data refreshes, and who fixes a broken feed.

What your examiner will ask

NCUA's liquidity rule, §741.12, applies to all federally insured credit unions except corporates.⁸ Your CFP should name your backup funding sources, the conditions for using them and when you might draw on them.⁹ The rule also requires you to set how often you test and update the CFP.¹⁰ Federal credit unions must get and reconcile a statement of investments and repurchase collateral in safekeeping each month.¹¹ If you hold over $50 million in assets, you also need a written interest rate risk policy and program.¹² NCUA's 2025 priorities said examiners would compare current and future liquidity sources with funding needs.¹³

What it costs

Ask each vendor for a written quote early. One buyer's guide to liquidity platforms found that implementation often costs as much as the first-year license fee, or more.¹⁴ Budget for both, and ask for a written timeline, since we haven't seen published implementation times. In contract talks, focus on exit terms, data return and price increases at renewal.

Food for thought

Evolve said a network of eight banks held $109 million for customers of the fintech Yotta as of April 11, 2024.¹⁵ In September 2024 the FDIC proposed that banks reconcile each owner's custodial account daily.¹⁶ If your credit union places funds through a sweep or deposit network, we think you should ask the vendor now for a daily view of where your money sits.