Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Exam Solutions Inc.·136 episodes
This podcast provides you the ability to listen to new regulatory guidance issued by the National Credit Union Administration, and occasionally the F D I C, the O C C, the F F I E C, or the C F P B. We will focus on new and material agency guidance, and historically important and still active guidance from past years that NCUA cites in examinations or conversations. This podcast is educational only and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated. We also have another podcast called With Flying Colors where we provide tips...
Episodes
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Proposes to Eliminate Prescriptive Limits on Third-Party Serviced Indirect Vehicle LoansThe NCUA Board is seeking comment on a proposed rule that would remove the agency's longstanding regulation governing federally insured credit union purchases of indirect vehicle loans serviced by third parties. Comments are due by May 26, 2026.What NCUA is proposing:Remove Section 701.21(h), which currently caps indirect vehicle loans and participations purchased from any one third-party servicer at 50% of net worth (rising to 100% after 30 months of experience with that servicer)Remove the parallel requirement in Section 741.203(c) that applies these same limits to federally insured, state-chartered credit unionsRemove the related waiver process, the associated Regional Director timelines, and the related citation in the appeals rule at Section 746.201(c)Why the change:The 2006 rule was built around a rigid, one-size-fits-all framework that the Board now views as unduly burdensomeThe Board believes each credit union's board is in the best position to tailor policies to its own size, risk profile, and complexity of transactionsThe action is consistent with a principles-based supervisory approach and is expected to qualify as a deregulatory action under Executive Order 14192It is also intended to reduce administrative costs and compliance complexity so credit unions can serve members more efficientlyWhat is NOT changing:Credit union boards are still responsible for safety and soundness, due diligence, and appropriate controls over indirect lending programsNCUA will continue to monitor third-party indirect vehicle lending through the examination processThe underlying legal authority, and NCUA's ability to act on unsafe or unsound practices, remains intact10,000-foot takeaway: NCUA is trading a bright-line concentration cap for board-level judgment. Credit unions gain flexibility, but the expectation is that internal policies, third-party due diligence, and concentration management become more robust, not less. If this is finalized, examiner scrutiny of indirect program governance will matter more, not less.MarkTreichel.com Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand s
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA is proposing to streamline its rule on the purchase, sale, and pledge of eligible obligations (12 CFR 701.23).What NCUA is proposing:Remove the prescriptive lists of items that FCUs must address in their written purchase, sale, and pledge policiesRemove the detailed code of conduct in paragraph (g) governing conflicts of interest and compensation tied to these transactionsMake a conforming redesignation (current 701.23(h) becomes 701.23(g)) and update the cross-reference in the appeals rule at 12 CFR 746.201(c)Comments are due April 27, 2026Why NCUA is making the change:The current one-size-fits-all framework is viewed as unduly burdensome, especially for smaller FCUsThe FCU Act requires NCUA to issue rules in this area but does not require a detailed framework for internal credit union policiesAn FCU's board is in the best position to scale policies to its own activities and risk profileThe existing compensation prohibition, with a narrow list of exceptions, is seen as inflexible and may hinder legitimate incentive structuresFCUs are already governed by broader conflict of interest provisions in their bylaws and by the fiduciary duties of their officialsThe change aligns with a more principles-based supervisory approachWhat is NOT changing:FCUs must still maintain written policies covering purchase, sale, and pledge of eligible obligationsBoard approval remains required, and transactions must be conducted at arm's length and in the best interest of the credit unionThe underlying statutory authority under section 107(13) of the FCU Act is unchangedExaminer oversight of these activities continuesThe rule applies only to FCUs — the basic framework for FISCUs is unaffected10,000-foot takeaway: NCUA is shifting from prescriptive checklists to principles-based expectations for eligible obligation policies. FCUs get more flexibility to tailor their written policies and incentive structures, but they also keep full responsibility for safe and sound operations. Boards should start thinking now about how their existing policies would hold up under a principles-based exam — the guardrails are coming out, but the accountability is not.If your credit union would like help preparing for an NCUA exam, visit MarkTreichel.com. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issu
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA's 2025 Annual Report audio book style Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA request for feedback on data collections. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA just released its 2026 Annual Performance Plan, and it offers a clear look at where the agency is focusing its resources this year. Here are the highlights:What NCUA is announcing:17 annual performance goals supported by 23 performance indicators, all aligned to the new 2026-2030 Strategic PlanA commitment to issue at least 30 regulatory actions or policy revisions that reduce regulatory or administrative burden on credit unionsPlans to eliminate unnecessary or unduly burdensome examination scope stepsFinal regulations on permissible stablecoin activities for all federally insured credit unionsDeployment of the Analytics 2.0 Phase I upgrade to the MERIT examination system by Q1 2026Key milestones in NCUA's AI roadmap, including a large language model pilot, an AI Steering Committee, and a refined AI strategyAt least three joint NCUA-State Supervisory Authority engagements to strengthen the dual chartering systemWhy the change is occurring:NCUA is reorganizing to focus on core statutory functions, eliminate duplication, and reduce non-essential activitiesThe agency wants to reallocate resources toward material risks while reducing lower-priority work for both examiners and credit unionsRapid changes in technology, digital assets, and payment systems require updated regulations and guidanceStronger data, analytics, and AI capabilities are needed to keep pace with an increasingly complex credit union systemWhat is NOT changing:NCUA's core mission to safeguard federally insured credit unions and protect the Share Insurance FundThe statutory requirement to maintain the Share Insurance Fund equity ratio at or above 1.2 percentTimely follow-up examinations for troubled credit unions - target is at least 97 percent initiated within established timeframes for CAMELS 4/5 credit unions and CAMELS 3 credit unions over $250 millionCommitment to an unmodified ("clean") opinion on financial statement audits and a FISMA maturity rating of at least Level 4Ongoing support for low-income credit unions through Congressionally appropriated grantsThe 10,000-foot takeaway: NCUA is signaling a leaner, more risk-focused agency in 2026. Expect meaningful burden reduction, a final stablecoin rule, smarter use of data and AI in examinations, and continued organizational realignment - all while maintaining the financial resilience of the Share Insurance Fund. Credit unions should watch closely for the 30-plus regulatory and policy revisions coming this year, as many will directly affect exam scope, compliance expectations, and innovation opportunities.If your credit union wants help preparing for an NCUA exam, visit MarkTreichel.com. Are you worried about an NCUA exam in
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA just released its 2026-2030 Strategic Plan, laying out the agency's priorities for the next five years. Here's what credit union leaders should know.What NCUA is announcing:Three strategic goals: safeguarding federally insured credit unions, enabling access to cooperative financial services and responsible innovation, and strengthening the agency's own capabilities and performanceA comprehensive review of the regulatory framework to remove rules that are outdated, duplicative, or unnecessarily burdensomeExpanded use of data, analytics, and AI tools in examination and supervisionA push to foster responsible adoption of financial technology, digital assets, and blockchain-based innovationStreamlined chartering, field of membership, and expansion processesInternal restructuring focused on core statutory functions, merit-based hiring, and reduced duplicationWhy the change is occurring:Feedback from NCUA's first-ever Strategic Planning Town Hall in September 2025 with credit unions, leagues, trade associations, and CUSOsA financial services environment evolving rapidly with AI, digital assets, and shifting member expectationsPresidential executive orders and laws like the GENIUS Act driving new regulatory responsibilitiesA recognition that disciplined, risk-focused supervision serves both safety and soundness and member accessWhat is NOT changing:NCUA's core mission: enabling access to financial services by facilitating safe, sound, and resilient credit unionsStatutory responsibility to protect the Share Insurance Fund and credit union membersRisk-focused examination framework (it's being refined, not replaced)Coordination with FFIEC, FSOC, and state regulatorsAgency values: results, integrity, teamwork, and accountability10,000-foot takeaway: NCUA is signaling a lighter, more targeted regulatory touch paired with a modernized, tech-enabled supervisory approach. Expect continued focus on material risks, fewer administrative burdens, and more room for credit unions to innovate responsibly, while the Share Insurance Fund and safety-and-soundness remain non-negotiable. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Proposes to Loosen Associational Common Bond RulesThe NCUA Board has issued a proposed rule that would amend the associational common bond provisions of its Chartering and Field of Membership Manual. Comments are due by June 8, 2026.What NCUA is proposing:Eliminate the automatic bar that currently disqualifies an associational group from FCU field of membership eligibility when the group requires purchasing a product or service as a condition of membership.Replace the bright-line rule with a totality of the circumstances review, looking at the group's structure, scope, degree of activities, and other operational factors.Clarify that a client-customer relationship can exist, even as a condition of membership, as long as it remains incidental to the group's overall purpose and activities.Use an example of a fraternal association that requires insurance purchase - under the proposal, this would no longer be automatically disqualifying.Why the change:The Board believes the automatic bar goes beyond what the FCU Act actually requires.Neither the FCU Act nor the Credit Union Membership Access Act of 1998 (CUMAA) specifies that a client-customer relationship is automatically disqualifying.The change is intended to enhance consumer access to financial services and eliminate an inflexible restriction, consistent with Executive Order 13563 and deregulatory goals under Executive Order 14192.Moves NCUA toward a principles-based approach rather than a rigid rule.What is NOT changing:Associations based primarily on a client-customer relationship still do not qualify.Health clubs, including YMCAs, remain examples of groups that do not meet the associational common bond requirements.Retail loyalty clubs still would not qualify, since their core reason for existence is the client-customer relationship.The rule does not affect occupational common bond charters, community charters, or federally insured state-chartered credit unions.The core associational common bond definition - members of a recognized association who participate in activities developing common loyalties, mutual benefits, and mutual interests - remains intact.Pre-approved categories of groups under the 2015 automatic qualification amendments are unaffected.10,000-foot takeaway: NCUA is moving from a rigid "if you require a purchase, you're out" standard to a more flexible "look at the whole picture" standard. Associational groups that previously couldn't qualify because membership required buying a product or service may now have a path forward - but only if the client-customer piece is genuinely incidental to why the group exists. If selling something is the core reason the group was formed, the group still doesn't qualify
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The NCUA just released its 2026 Supervisory Priorities (Letter 26-CU-01), giving credit unions a heads-up on where examiners will be focusing this year.Here's what you need to know:The NCUA is doubling down on balance sheet management, with particular attention to lending, interest rate risk, liquidity, earnings, and capital adequacy. Loan delinquency and loss rates are at their highest in over a decade, and examiners will be looking closely at underwriting, loss mitigation, ACL reserves, and charge-off practices.Operational risk is a major theme. Payment systems, fraud prevention, and cybersecurity will all get heightened scrutiny as the payments landscape grows more complex and fraud risks continue to rise.BSA/AML compliance remains a priority, with an emphasis on risk-based programs tailored to each credit union's profile. Expect regulatory changes throughout the year as FinCEN and the NCUA continue implementing provisions of the Anti-Money Laundering Act of 2020.The agency is also signaling a shift toward a more efficient and tailored examination program, building on its 2025 efforts to reduce burden for both credit unions and NCUA staff. Defined scope exams will continue for most federal credit unions with $50 million or less in assets.What is NOT changing: The NCUA will continue enforcing all existing laws and regulations, including consumer financial protection and information security requirements. Risk-focused procedures remain the standard for larger credit unions.The 10,000-foot takeaway: Asset quality and earnings pressure are the story of 2026. Credit unions that can demonstrate strong risk management practices across lending, liquidity, and capital planning will be well positioned. Now is the time to review your ACL methodologies, stress testing, contingency funding plans, and BSA programs before examiners come knocking.One more thing worth noting: the NCUA reminds credit unions they may record their final exit meeting or joint conference for documentation and training purposes.If your credit union could use help preparing, visit MarkTreichel.com or reach out to Mark Treichel on LinkedIn. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieve
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Changes for Corporate Credit Unions – 12 CFR 704.8 and 704.15NCUA is proposing to amend its regulations for corporate credit unions by removing the requirement that a corporate credit union’s asset and liability management committee (ALCO) must have at least one member who is also a member of the corporate credit union’s board of directors. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ the Board, seeks comment on a proposed rule to remove the segregated deposit and collateral requirements when a federally insured credit union, referred to as a F I C U, acts as a surety and guarantor. Removing this regulation will provide F I C U s with greater flexibility to design products that meet member needs. F I C U s would remain subject to the other requirements regarding surety and guaranty agreements. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA's 2026 Priority Letter to Credit Unions is out! Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ The NCUA Board, referred to as the Board, is issuing this proposed rule to streamline its regulations governing advertising and the notice of insured status. This proposed rule would eliminate provisions concerning the official advertising statement. This action is undertaken to reduce regulatory complexity, and the intended effect is to reduce the administrative burden and costs for federally insured credit unions, referred to as FICU s, and provide them with greater flexibility in their advertising activities. The proposed rule would not amend requirements related to displaying the official sign. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ The NCUA Board seeks comment on a proposed rule to remove the regulations related to approval and policies on making loans to other credit unions. While this provision would no longer be codified in regulation, Federal Credit Unions would remain subject to statutory requirements related to making loans to credit unions. Federally insured state-chartered credit unions would remain subject to any other applicable NCUA or state law or regulation. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ The N C U A Board is publishing this proposed rule to amend the requirements for federally insured credit unions to report catastrophic acts to the agency. By providing more time for federally insured credit unions to notify the agency of the occurrence of a catastrophic act and by eliminating the specific list of items to be documented, the Board expects the proposed rule to reduce the compliance burden and allow federally insured credit unions to focus their resources on recovery and core functions without compromising safety and soundness. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Episode TitleCredit Card Risk, Consumer Stress, and the 18 Percent RealityEpisode DescriptionIn this episode, Samantha Shares reviews key findings from the Consumer Financial Protection Bureau’s latest Consumer Credit Card Market Report and explains what they mean for credit unions.The discussion focuses on how credit card usage has evolved since the pandemic, where growth is occurring, and why consumer stress signals remain elevated even as delinquency rates normalize. Samantha also explains how credit unions manage credit card risk differently from large banks, particularly given the statutory 18 percent loan-rate cap.This episode is designed to provide practical context for credit union leaders, board members, and exam preparation conversations.Key Topics CoveredHow large the credit card market has become and how embedded cards are in daily lifeWhy recent credit card spending growth is concentrated among higher-credit-score borrowersWhat rising balances and minimum-payment behavior signal about consumer stressWhy normalization in delinquency rates does not necessarily mean household finances are healthyHow credit cards are increasingly used for essential expenses rather than discretionary spendingWhy smaller issuers hold a larger share of higher-risk credit card balancesHow credit unions manage credit card risk under the 18 percent loan-rate capThe growing importance of underwriting discipline, credit limits, monitoring, and servicing controlsOperational risk trends, including disputes tied to recurring transactionsHow innovation, artificial intelligence, and alternative payment methods may shape future card usageWhy This Episode MattersCredit unions operate in a high-rate environment with uneven consumer stress while serving a membership base that often includes higher-risk borrowers. Understanding how credit card risk is distributed across the market—and how credit unions manage that risk structurally rather than through pricing—is essential for strategy, governance, and exam readiness.Sponsor MessageThis podcast is sponsored by Credit Union Exam Solutions Incorporated. Their team has over two hundred and forty years of National Credit Union Administration experience and helps credit unions prepare for and navigate NCUA examinations.Learn more at MarkTreichel.com.Related ContentWith Flying Colors podcastCredit Union Regulatory Guidance podcastArticles and resources at MarkTreichel.com Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Changes for Guidelines for Safeguarding Member Information – 12 CFR 748 Appendix ANCUA is proposing to remove Appendix A to part 748, guidelines for safeguarding member information, from the Code of Federal Regulations. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Show Notes In this episode of Samantha Shares, we present an audio version of the Semiannual Risk Perspective from the National Risk Committee, Fall 2025, issued by the Office of the Comptroller of the Currency.This report provides a comprehensive overview of conditions in the federal banking system, including balance sheet strength, capital and liquidity levels, earnings performance, and emerging risks. The document discusses trends in credit quality across major loan categories, underwriting standards, commercial real estate conditions, and market and liquidity risk. It also highlights key operational and compliance considerations, including cybersecurity threats, fraud risk, and the evolving regulatory environment.The report examines the role of financial innovation, including artificial intelligence and payment system developments, and outlines how banks are balancing innovation opportunities with governance and risk management expectations. It concludes with an assessment of the economic environment and bank performance, including interest rate trends, profitability, and resilience under potential stress.This episode is a near-verbatim spoken reading of the source document. It is provided for educational purposes only and is not legal advice.Sponsor This episode is sponsored by Credit Union Exam Solutions Incorporated. Our team has over two hundred and forty years of National Credit Union Administration experience and assists credit unions with NCUA examinations so they can save time and money. Learn more at Mark Treichel dot com.Related Podcast Be sure to also check out our companion podcast, With Flying Colors, where we share practical insights and strategies to help credit unions achieve success with NCUA. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Changes for Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice – 12 CFR 748 Appendix BNCUA is proposing to remove Appendix B to part 748, guidance on response programs for unauthorized access to member information and member notice, from the Code of Federal Regulations. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/"Most banks maintained relatively consistent reliance on Federal Home Loan Bank advances — including during periods of financial stress."— Government Accountability OfficeThe GAO just dropped a detailed report examining the Federal Home Loan Bank system during COVID-19 and the March 2023 banking stress.Here's what they actually found (without the noise):What the data shows:• FHLBank advances functioned as a stabilizing liquidity tool — not a risk amplifier• Especially true for institutions under $10 billion in assets• Consistent usage patterns even during stress periods• No evidence of panic borrowing or destabilizing effectsWhy it matters: While everyone was wringing their hands about liquidity risk, most community institutions used FHLBanks exactly as designed — as a reliable backstop when deposits got shaky.The real takeaway: For smaller institutions, FHLBank membership provided stability when they needed it most. Not a crutch. Not a risk factor. Just a tool that worked.I've posted a ~9-minute audio summary walking through what the GAO actually found.🎧 Listen at MarkTreichel.com or on your favorite podcast app (Samantha Shares).Translation: FHLBanks did their job. The system worked as intended. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Changes for Supervisory Committee Audits and Verifications – 12 CFR 715NCUA is proposing to amend its regulations governing supervisory committee audits to eliminate unnecessary, redundant, and overly prescriptive provisions. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Announces Deregulation Project and First Round of Proposed Regulatory ChangesStakeholders Are Encouraged to Review Notice of Proposed Rulemaking and Submit CommentsALEXANDRIA, VA (December 10, 2025) – The National Credit Union Administration today announced the first round of proposed regulatory changes associated with a new initiative to review and potentially revise the agency’s regulations. This initiative, NCUA’s Deregulation Project, follows This is an external link to a website belonging to another federal agency, private organization, or commercial entity.Executive Order 14192, Unleashing Prosperity Through Deregulation(Opens new window).NCUA’s Deregulation Project will involve a comprehensive review of regulations documented in Title 12, Chapter VII of the Code of Federal Regulations. This review will ensure the regulations are focused on the safety, soundness, or resilience of credit unions. Further, NCUA will propose changing or removing regulations that are:Obsolete;Duplicative of statutory requirements;Intended to serve as guidance, not requirements; orOverly burdensome.In addition to announcing the project, NCUA is requesting comments on four proposals that would clarify agency guidance or eliminate unduly burdensome or obsolete requirements in This is an external link to a website belonging to another federal agency, private organization, or commercial entity.the Federal Register(Opens new window).The four proposals include:Changes for Corporate Credit Unions – 12 CFR 704.8 and 704.15NCUA is proposing to amend its regulations for corporate credit unions by removing the requirement that a corporate credit union’s asset and liability management committee (ALCO) must have at least one member who is also a member of the corporate credit union’s board of directors.For more information on this proposal, please see: This is an external link to a website belonging to another federal agency, private organization, or commercial entity.https://www.federalregister.gov/public-inspection/2025-22487/corporate-credit-unions(Opens new window)Changes for Supervisory Committee Audits and Verifications – 12 CFR 715NCUA
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/n this episode of Samantha Shares, we present the verbatim text of the N C U A’s proposed rule on Elimination of Reputation Risk.The document covers:A Summary of the proposed rule to eliminate reputation risk from N C U A’s supervisory framework.Background and Policy Objectives — why reputation risk is subjective, inconsistent, and prone to examiner bias.Legal Authority — the Federal Credit Union Act provisions that give N C U A power to regulate.Description of the Proposed Rule and Changes — prohibiting examiners from citing, criticizing, or taking action against credit unions for reputation risk, including political, cultural, or religious reasons.Expected Effects — how this will affect all 4,370 federally insured credit unions, their members, and business partners.Regulatory Procedures — transparency, cost analysis, and references to Executive Orders and statutory requirements.The proposal directly addresses concerns that reputation risk was being misused in examinations, particularly around politically sensitive or lawful but disfavored activities.This audiobook-style episode presents the full Federal Register text as released, unedited and verbatim, for educational purposes. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers the Fair Credit Reporting Act; Preemption of State Laws. The following is an audio version of that document. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming, or in-process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors, where we provide tips on how to achieve success with N C U A. And now, the Fair Credit Reporting Act; Preemption of State Laws.The Consumer Financial Protection Bureau is issuing this interpretive rule to clarify that the Fair Credit Reporting Act broadly preempts state laws that attempt to regulate credit reporting. This action reflects Congress’s original intent to create national standards for the credit reporting system. This interpretive rule replaces an earlier Bureau rule from July twenty twenty-two, which had taken a narrower view of preemption. That rule was withdrawn in May twenty twenty-five.The Fair Credit Reporting Act, or F C R A, was enacted in nineteen seventy and has been amended several times since. It established a national system for credit reporting and set rules for consumer reports and the use of consumer information. From the beginning, the law preempted state laws that were inconsistent with its provisions. In nineteen ninety-six, Congress strengthened this preemption by adding a new clause that barred states from regulating in certain specifically identified areas. This was meant to avoid a patchwork of conflicting rules. Originally, this stronger preemption was set to expire in two thousand four, but in two thousand three, Congress made it permanent. The intent was clear: to preserve uniform national standards and support the growth of the national credit reporting system.In July twenty twenty-two, the Bureau published an interpretive rule suggesting that section sixteen eighty-one tee, subsection b, paragraph one, had only a narrow sweep. It concluded that many state laws affecting consumer reports could stand alongside federal law. For example, it suggested that state laws regulating medical debt, rental history, or arrest records could coexist with the F C R A. That interpretation was controversial. In May twenty twenty-five, the Bureau withdrew that interpretive rule, stating that it was unnecessary and that agencies lack special authority to interpret preemption unless Congress specifically delegates it. The Bureau also found that the twenty twenty-two rule created confusion and risked imposing higher compliance burdens. The Bureau now clarifies that the prior interpretation w
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers Frequently Asked Questions. The following is an audio version of that document. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel dot com. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements. October 3, 2005. The Financial Crimes Enforcement Network, jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision, is issuing interpretive guidance in response to questions received regarding the filing of Suspicious Activity Reports. The purpose of this guidance is to clarify the regulatory expectations and requirements for financial institutions with respect to the reporting of suspicious activity. Financial institutions are reminded that Suspicious Activity Reports are one of the most important sources of information available to law enforcement and regulatory agencies for detecting financial crime, and are used in a wide range of investigations and enforcement actions. Below are answers to frequently asked questions regarding suspicious activity reporting requirements. Question 1: S A R Filings for Potential Structuring related Activity. Is a financial institution required to file a S A R for transactions or a series of transactions in which a person or persons are structuring transactions to avoid the C T R threshold, even though the total amount of currency involved does not exceed ten thousand dollars? Yes. The mere purpose of structuring is evidence of suspicious activity regardless of the amount. If one person or two or more persons act together to break up currency transactions to avoid the ten thousand dollar C T R threshold, then information sufficient to identify the activity should be reported on a S A R. For example, if an individual conducts multiple cash deposits of nine thousand five hundred dollars or less into different accounts to evade a C T R, the financial institution is required to file a S A R. A financial institution is required to file a S A R for a transaction conducted or attempted by, at, or through the institution if it involves or aggregates at least five thousand dollars in funds or other assets, and
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers Chairman Hauptman on Regulation by Enforcement. The following is an audio version of that document. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel dot com. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the document. Chairman Hauptman On Regulation by Enforcement ALEXANDRIA, VA, October 1, 2025 – The National Credit Union Administration Chairman Kyle S. Hauptman issued the following statement about N C U A’s No Regulation-by-Enforcement Policy: Today’s policy statement fulfills a goal listed back in January upon being designated as Chairman: “Codifying our procedures to protect Americans from regulation-by-enforcement. For example, no enforcement action should ever set―or even clarify― policy. In America and other free societies, the sequence is: set speed limits, then give speeding tickets (no one has any obligation to be aware of someone else’s ticket).” To be clear, this agency has a good track record regarding regulation-by-enforcement, so this statement shouldn’t be viewed as being the result of any recent N C U A actions. After all, it’s counterproductive for a deposit insurer to engage in regulation-by-enforcement against the same institutions we insure. That said, it’s important to put in writing a policy of fairness, whereby government employees give regulated credit unions the same due-process that they, under civil servant protections, rightly expect in their own careers. Today’s statement is born partly of my frustrating interactions with regulators, both in my time on Capitol Hill and in the private sector. I know that millions of others share the frustration of being told ‘if you want to figure out the rules, look at our prior settlements.’ Americans expect better from their government, including financial regulators. No Regulation-by-Enforcement Policy Statement Regulation-by-enforcement is unethical and not permitted at N C U A. Enforcement actions shall only occur in the case of clear and significant violations of law or regulation. Therefore, no person or entity regulated by N C U A has any obligation to be aware of any prior N C U A enforcement actions because no new policy is ever set via an enforcement action. No enforcement action, nor the timing of enforcement actions, shall be motivated by trying to boost the
Take a Cruise with CUES and With Flying Colors!https://www.cues.org/professional-development-and-events/cues-florida-council-spring-2026-cruise
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ N C U A Discontinues Risk Ratings and Reputational RiskShow Notes In this episode, Samantha Shares provides an audio version of the recent N C U A communications announcing the discontinuation of risk ratings and the elimination of reputational risk in credit union examinations.In early September, N C U A emailed CEOs and Board Chairs that it would stop using individual risk ratings for categories like Credit, Liquidity, and Strategic risk. Later that month, the agency issued a press release confirming it would no longer use reputational risk or equivalent concepts, in line with White House Executive Order Fourteen Three Three One.Listeners will hear the original text of these letters and announcements, voiced audiobook-style, without added commentary. This principle-based guidance is designed to streamline examinations, reduce duplicative scoring, and focus examiner attention on material issues reflected in CAMELS ratings.Key points covered in the episode include:The removal of duplicative risk ratings for the seven traditional risk categories.Confirmation that N C U A examiners will still assess risk, but only in the context of CAMELS ratings.The elimination of reputational risk as a supervisory concept.Clarification that issues such as litigation exposure or insider abuse will still be reviewed under material financial impact.An emphasis on more streamlined examination reports and communications with credit unions.This audiobook-style presentation is intended as an educational resource for credit union leaders and boards.Disclaimer This podcast is educational and is not legal advice.Sponsor Message Credit Union Exam Solutions Incorporated provides consulting support from a team with more than two hundred and forty years of N C U A experience. If your credit union is preparing for or undergoing an N C U A exam, visit MarkTreichel.com to learn more. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Tips on Starting an Exam Efficiently Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Show Notes: OCC Semiannual Risk Perspective Spring 2025Episode OverviewThis episode covers the Office of the Comptroller of the Currency's Semiannual Risk Perspective for Spring 2025, providing valuable insights for credit unions on key banking risks and industry trends.Key Topics CoveredFederal Banking System Key ThemesOverall system strength remains sound despite economic uncertaintyCommercial credit risk increasing due to geopolitical risks and sustained higher interest ratesRetail credit risk stable but consumer sentiment decliningMarket and liquidity risk stable with improved net interest marginsOperational risk elevated due to cyber threats and digitalization challengesCompliance risk remains elevatedEconomic Operating EnvironmentGlobal: Slow growth forecast for 2025, trade policy uncertainty, geopolitical tensionsDomestic: GDP 12% above pre-pandemic peak, unemployment at 4.2%, but economic uncertainty growingProjections: 1.2% growth in 2025, 1.3% in 2026; PCE inflation expected to reach 3.6% by Q3 2025Credit Risk InsightsCommercial CreditCRE market conditions vary by property typeOffice vacancies projected to continue rising into 2026Multifamily market expected to stabilize later in 2025Refinance risk high for loans underwritten during low-rate periodsTrade disruptions may compress industry marginsRetail CreditDelinquency rates manageable but trending upwardConsumer payment prioritization favoring low-rate mortgagesTighter lending standards across consumer categoriesNatural disaster impacts on insurance and collateral administrationMarket RiskNet interest margins improved in second half of 2024Unrealized investment losses remain a concern10-year Treasury yield volatility affecting portfolio valuesInterest rate risk scenario testing critical given uncertaintyOperational RiskCybersecurityContinued targeting by threat actors with ransomwareIncrease in "double extortion" attacksATM jackpotting attempts risingThird-party dependencies creating single points of failureInnovation & TechnologyCautious AI adoption with focus on fraud detection and credit underwritingLegacy system challenges amid digitalization demandsNew OCC guidance on crypto-asset activities (IL 1183 and IL 1184)Board oversight responsibilities for new technologiesFraud Risk ManagementTraditional payment methods still targetedSocial engineering and phishing schemes prevalentFirst-party fraud a
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Show Notes: FDIC Consumer Compliance Supervisory Highlights - July 2025Episode SummaryIn this episode, we break down the FDIC's latest Consumer Compliance Supervisory Highlights report, covering 2024 examination results and compliance trends. While focused on FDIC-supervised institutions, this principle-based guidance serves as an excellent roadmap for credit unions and all financial institutions.Key TakeawaysOverall Performance97% of FDIC-supervised institutions rated satisfactory or better for consumer compliance800 consumer compliance examinations conducted in 2024Risk-focused examination approach targets areas with greatest potential for consumer harmTop 5 Most Cited Violations (73% of all violations)Truth in Lending Act (TILA) - 470 violations (37%)Periodic statement disclosure failuresGood faith estimate timing issuesLoan cost breakdown requirementsFlood Disaster Protection Act (FDPA) - 143 violations (11%)Failure to provide required flood insurance45% of FDPA violations related to this single issueTruth in Savings Act (TISA) - 129 violations (10%)Inadequate deposit account disclosuresPre-opening disclosure failuresElectronic Fund Transfer Act (EFTA) - 122 violations (10%)Error investigation procedure failuresTiming and reporting requirement violationsHome Mortgage Disclosure Act (HMDA) - 65 violations (5%)Incomplete data collection and reportingMissing required borrower and loan informationEnforcement Actions & Restitution31 formal and 23 informal enforcement actions$5.6 million in civil money penalties$33.3 million in voluntary restitution to ~400,000 consumers3 referrals to Department of Justice for discrimination violationsConsumer Complaint Trends26,451 complaints closed (14% increase from 2023)100% acknowledgment within 14 days98.6% response rate within performance goalsTop Complaint Categories:Credit cards: 4,733 complaints (29%)Checking accounts: 3,152 complaints (19%)Installment loans/CLOC: 2,708 complaints (12%)Residential real estate: 844 complaints (5%)Most Common Issues:Credit reporting disputes (18%)Transaction errors (9%)Accounts opened without knowledge (6%)Disclosure problems (6%)Service availability issues (5%)</u
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This podcast is educational and is not legal advice.Banking agencies have curtailed issuance of new guidance and regulations under the current administration. As a result, and to continue providing our listeners with valuable new episodes, we're excited to share our new initiative and cohost. We'll be providing AI-powered summaries of evergreen episodes from our sister podcast With Flying Colors. These episodes will highlight the key points in an easy-to-digest eight to twelve minute format.We continue to embrace Artificial Intelligence, and like my voice, these new episodes will be introduced by me and then narrated by our guest AI voice. Today, Daniel will discuss 'NCUA Exam Alert: Risk Management Framework Essentials That Pass Exams.' This episode is also available on YouTube in AI video format, so be sure to check that out as well!Now, here's Daniel with your summary. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/https://www.linkedin.com/in/mark-treichel/ Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Episode: Fighting Payments Fraud - Federal Banking Agencies Launch Major InitiativeEpisode SummaryThree major federal banking agencies have joined forces to combat the explosive growth in payments fraud across America. In this episode, we break down the comprehensive Request for Information issued by the OCC, Federal Reserve, and FDIC on June 20, 2025, seeking public input on how to better protect consumers, businesses, and financial institutions from fraud schemes.Key Takeaways🚨 Alarming Statistics:Non-card payments fraud losses increased 271% between 2020-2024Suspicious Activity Reports for check, ACH, and wire fraud up 489% since 2014Check fraud alone has risen 385% since COVID-19Check fraud accounts for 30% of all fraud-related SARs filed in 2023💰 Financial Impact:Fraud reports for payments apps, bank transfers, wire transfers, and checks resulted in $2.99 billion in losses in 2024, up from $806 million in 2020Five Key Areas Federal Agencies Are TargetingExternal Collaboration - How can stakeholders work together more effectively?Education - Better fraud prevention education for consumers, businesses, and industryRegulation & Supervision - Potential regulatory changes and clearer guidanceData Collection - Standardizing and centralizing fraud data sharingReserve Bank Tools - Enhanced fraud detection and prevention servicesNotable Quotes"Payments fraud has the potential to erode public trust in—and undermine the safety, accessibility, and efficiency of—the nation's payments system, upon which the U.S. financial system depends.""No agency or private-sector entity can address payments fraud on its own."Payments fraud data is currently "collected in an incomplete, non-standardized, ad hoc, and fragmented way."What's at StakeCheck Vulnerability: Paper checks contain sensitive information including account numbers, routing numbers, addresses, and signatures that criminals can exploitMulti-Institution Schemes: Fraud often involves multiple banks and payment methods across different regulatory jurisdictionsTrust in the System: Continued fraud growth threatens confidence in the entire U.S. payments infrastructureRegulatory Focus AreasRegulation CC ChangesThe Federal Reserve is considering amendments to funds availability rules, asking whether:Technological advances allow for shorter hold periodsCurrent fraud detection capabilities justify faster fund accessBetter dispute resolution mechanisms are neededIndustry Pain Points</p
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/https://www.linkedin.com/in/mark-treichel/ Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/https://www.linkedin.com/in/mark-treichel/www.marktreichel.com Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Enforcement actions range from formal to informal, and minor to drastic. Today we discuss what NCUA's philosophy is in this regard. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The Federal Credit Union Act allows NCUA to remove officials. We explain how. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/enterprise-risk-management-erm Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The National Credit Union Administration (NCUA) today liquidated Unilever Federal Credit Union of Englewood Cliffs, New Jersey. The NCUA made the decision to liquidate Unilever Federal Credit Union and discontinue operations after determining the credit union was insolvent and had no prospect for restoring viable operations.Member deposits are federally insured by the National Credit Union Share Insurance Fund to at least $250,000. NCUA’s Asset Management and Assistance Center will issue correspondence to individuals holding verified share accounts in the credit union within one week. Members may direct questions and other inquiries concerning their accounts to NCUA’s Asset Management and Assistance Center:Unilever Federal Credit Unionc/o National Credit Union Administration10910 Domain Dr., Suite 200Austin, Texas 787581.877.715.0777 or [email protected] with additional questions about their insurance coverage may contact NCUA’s Consumer Assistance Center toll free at 800.755.1030. The Center answers calls Monday–Friday between 8 a.m. and 5 p.m. Eastern. Individuals may also visit the MyCreditUnion.gov(Opens new window) website at any time for more information about their insurance coverage.Unilever Federal Credit Union served 1,448 members and had assets of $46,669,599, according to the credit union’s most recent Call Report. Chartered in 1948, Unilever Federal Credit Union primarily served employees of UNUS, Unilever United States, Inc, and its directly or indirectly wholly owned subsidiaries who work in or are paid from Englewood Cliffs, New Jersey. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers NCUA’s reopening the public comment period on two recently finalized rules that haven’t fully taken effect yet. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.Today, we’re diving into an important update from the National Credit Union Administration. This update comes straight from the April twenty-third Federal Register. If you’re a board member, executive, or compliance officer, you’ll want to pay close attention.On April twenty-third, the NCUA announced something a little unusual—they are reopening the public comment period on two recently finalized rules that haven’t fully taken effect yet. Here’s why this matters.Earlier this year, the White House issued what’s called a “Regulatory Freeze Pending Review.” In plain English, that means federal agencies were asked to hit pause and review any major new rules that hadn’t already kicked in. NCUA, just like other agencies, is now inviting the public—yes, that means you—to weigh in again on two big rules.The first is called Simplification of Share Insurance. This rule was finalized back in September twenty twenty-four and is scheduled to fully take effect December first, twenty twenty-six. The goal is to make NCUA’s share insurance rules simpler and clearer for both credit unions and your members. With this new comment window, you have another chance to raise questions, flag concerns, or support the parts of the rule you think are working.The second rule is about Succession Planning. This one was finalized in December twenty twenty-four and is set to take effect January first, twenty twenty-six. It’s designed to make sure credit unions have solid plans in place for leadership succession—a big deal, especially for smaller credit unions and those with retiring executives. This new comment period is your opportunity to share whether you think the rule strikes the right balance, or if it creates any challenges for your operations.So how can you submit your comments? You have until June twenty-third, twenty twenty-five. You can go online to regulations dot gov and look up the docket numbers for each rule, or send your comments to the NCUA Secretary in Alexandria, Virginia. If you’re old school, you can even hand deliver them.You might be thinking, didn’t we already comment on these rules? Yes, many did—but t
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ NCUA Releases Staff Message on the Current NCUA Board Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Understanding Conflicts of Interest in Asset Management: Show NotesIn this episode, Samantha Shares explores the critical topic of conflicts of interest in asset management based on the OCC Comptroller's Handbook. While originally created for banks, these principle-based guidelines provide an excellent framework for credit unions managing conflicts in their asset management activities. The episode covers what constitutes a conflict of interest, common scenarios where conflicts arise, the four main risk categories (compliance, operational, reputation, and strategic), and key components of effective risk management. Samantha details specific conflict situations including self-deposits, proprietary investment products, brokerage allocation, and soft dollar arrangements, while outlining four essential principles for handling conflicts: proper authorization, full disclosure, fairness and reasonableness, and maintaining the client's best interest. The episode emphasizes that managing conflicts effectively isn't just about regulatory compliance—it's fundamental to maintaining client trust and protecting your institution's reputation. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ Show Notes: Model Risk Management (OCC Comptroller's Handbook) In this episode, Samantha Shares discusses the OCC's "Model Risk Management" handbook (Version 1.0, August 2021). This comprehensive handbook provides guidance on how financial institutions should manage risks associated with their use of models. Key topics covered: Definition of models and model riskTypes of risk associated with model useGovernance framework requirementsThree lines of defense in model risk managementModel development, testing and implementationValidation process and requirementsThird-party model risk managementDocumentation and inventory requirementsThis handbook is essential knowledge for anyone dealing with model risk management in financial institutions, particularly those subject to OCC supervision. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Reach out to learn how we assist our clients. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA wants you to build a good contingency funding plan. We discuss their guidance on this important topic. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers NCUA Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data The following is an audio version of that STATEMENT. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the STATEMENT N C U A Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data N C U A Board Member Tanya F. Otsuka issued the following statement about the agency’s decision to remove total overdraft and non-sufficient fund (NSF) fee data for federally insured credit unions with more than $1 billion in assets from Call Reports beginning with the first quarter of 2025.Member empowerment is a cornerstone of the cooperative credit movement. For credit unions, which are built on the philosophy of “people helping people,” increasing transparency is a simple way to demonstrate the credit union difference, enable consumers to make informed financial decisions, and help maintain trust and confidence in our cooperative system of credit. In that spirit, the N C U A began collecting and publishing quarterly Call Report data on revenues credit unions with over $1 billion in assets made from overdraft and non-sufficient funds (NSF) fees last year.Unfortunately, the fourth quarter 2024 data published today will be the last to include information on overdraft and NSF fee income. On March 3, 2025, Chairman Hauptman unilaterally announced changes to the way the N C U A collects overdraft and NSF fee information.1 Specifically, starting on March 31, 2025, the agency would “no longer publish overdraft and non-sufficient fund fee income for individual credit unions” and this information would ostensibly be collected during supervisory examinations.This is a step in the wrong direction. There is no data to suggest credit unions limited the services they provide low-income or underserved consumers last year simply to avoid having to report fee income on the N C U A’s Call Reports. Credit unions with higher overdraft and NSF fees also do not appear to offer lower fees to members for other services, nor better interest r
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers NCUA Board Member Todd Harper Statement on the Decision to Curtail the Collection of Overdraft and Non-sufficient Fund Fees The following is an audio version of that Statement This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the Statement. NCUA Board Member Todd Harper issued the following statement about the agency’s decision to curtail the collection of total overdraft and non-sufficient fund (NSF) fees for federally insured credit unions with more than $1 billion in assets beginning with Call Reports for the first quarter of 2025.For markets to work efficiently, transparency is needed. That’s a bedrock principle of economics. And, it’s one of the many reasons why credit union member-owners and the public should have clear visibility into the income a credit union generates from overdraft and NSF fees charged to its member-owners.To advance credit union efforts to benchmark fees against other financial institutions, improve marketplace competition, and increase consumer understanding of the fees they’re charged within the credit union system, the NCUA required federally insured credit unions with more than $1 billion in assets to disclose, separately, income from overdraft and NSF fees beginning with the 2024 first quarter Call Report. With today’s release of the 2024 fourth quarter Call Report results, however, that desirable transparency experiment will regrettably end.During the last year, we’ve found that reporting institutions have collected $3.8 billion in such fees. Some charged no fees at all. For most reporting credit unions, overdraft and NSF fees accounted for between 2 and 5 percent of revenue. Some outliers charged fees amounting to as much as 18 percent of income. For those billion-dollar-plus credit unions with higher overdraft and NSF fees, we also found that they did not use those fees to subsidize better interest rates or lower other fees.Federally insured banks with more than $1 billion in assets began reporting these numbers in 2015. Since then, consumers have benefitted as banks have lowered their reliance on such fees. In fact, the Consumer Financial Protection Bureau found that roughly two out of three banks with $10 billion or more in assets have eliminated NSF fees, saving consumers $2 billion annu
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Board Member Tanya F. Otsuka Remarks at the 2025 Governmental Affairs ConferenceAs Prepared for Delivery on March 4, 2025Thank you to Jim, Carrie, and everyone at America’s Credit Unions for the invitation. Special thanks to the convention center staff and everyone behind the scenes who helped put this event together and are making sure it runs smoothly. And of course, thank you all in the audience for being here.It is an honor to serve on the Board of the NCUA and to see the great work credit unions are doing for their members every day. The NCUA’s mission of protecting the cooperative credit system is imperative for the millions of families that rely on credit unions for a checking account, buy a car or a home, or save for retirement.Congress has entrusted the NCUA with the responsibility to protect credit union members and the credit union system, and our ability to do so depends on a strong, independent agency, with dedicated staff who understand the unique role that credit unions play in our economy.Our independence is critical to maintaining confidence and stability in the credit union system. If you put your money in a credit union with the words “insured by the NCUA” emblazoned on the door, you can trust that you won’t lose your life savings if that credit union fails. Share insurance creates confidence in the credit union system, which not only protects Americans’ hard-earned money, but also helps credit unions attract new members and continue to grow."Congress has entrusted the NCUA with the responsibility to protect credit union members and the credit union system, and our ability to do so depends on a strong, independent agency, with dedicated staff who understand the unique role that credit unions play in our economy. Our independence is critical to maintaining confidence and stability in the credit union system."As the primary federal regulator of credit unions, the NCUA understands the unique characteristics of credit unions and their members. Our independence from politics and distinction from other financial regulators allows us to focus on what matters to the credit union system. It also allows us to maintain long-term stability, mitigate risks and act quickly during a crisis, and prudently manage the share insurance fund.We must not lose sight of why these guardrails are in place. The NCUA, as we know it today, is the product of one too many dark periods in our nation’s history. During the Great Depression, the stock market crashed, our economy collapsed, and thousands of banks failed, wiping out many Americans’ entire life savings. In response, Congress created independent financial agencies and consumer protections – like deposit insurance – to promote stability and provide a safety net for American families. Congress also encouraged the creation of federal credit
www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/This episode covers NCUA's Guidance to Credit Unions on Concentration Risk. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.
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