On December 29, 2021, First Financial Credit Union, Skokie, Illinois completed a private placement of $2.0 million of its 4.25% fixed rate subordinated notes due January 1, 2032. The subordinated notes are intended to qualify as secondary capital under NCUA rules.

Luse Gorman served as legal counsel to First Financial Credit Union in the offering. The Luse Gorman team consisted of Jeff Cardone and Ellie Cook.

Beginning January 1, 2022, newly effective NCUA rules have expanded credit union access to regulatory capital by permitting credit unions with at least $500 million in assets and new credit unions to issue subordinated debt. Low-income designated credit unions (regardless of their asset size) are also permitted to issue subordinated debt. Luse Gorman has prepared a memorandum summarizing the new NCUA rules.

To learn more about credit union capital raises, please contact Jeff Cardone, Tom Hutton, Michael Brown or Ellie Cook.