Earlier this summer, the Department of Insurance and Financial Services apprised MCUL & Affiliates of a proposed Advisory Bulletin to provide guidance to examiners and credit unions related to deferred compensation arrangements.
As part of the pending bulletin, DIFS will augment guidance on collateral assignment split dollar (CASD) deferred compensation arrangements. An increasing number of credit unions in Michigan are using CASD plans to provide effective and attractive executive compensation packages.
MCUL and several industry partners have worked with DIFS throughout the summer and continue to work toward a final version that will address industry and regulator concerns and that will have as minimal substantive impact as possible for well-constructed deferred compensation plans, including CASD arrangements. When the final Advisory Bulletin is ready for release from DIFS this fall, MCUL will host a conference call seminar to discuss it, targeting participation from credit unions, the regulator and key accounting and legal experts in the field.