#132: CAMEL CODE 3 Downgrades Continue: Especially in Complex Credit Unions

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Credit Unions over $500 million in assets are getting downgraded to code 3s more and more each quarter.

NCUA believes this trend will continue. The code 3s are driven by Liquidity, Sensivity, Risk Management, Audit issues, accounting issues, asset quality issues to name a few.

The NCUSIF briefing PowerPoint can be found here:

https://ncua.gov/news/board-meetings-agendas-results/board-agenda-september-21-2023-meeting

In 33 years at NCUA I served as Executive Director, Regional Director, Director of Special Actions, Supervisory Examiner, and Principal Examiner. I began at the ground level as an examiner. I rose to the top. As Executive Director I supervised your Regional Director. I know how NCUA thinks and why they think it. I know the examination process inside and out. I know how to communicate and negotiate with NCUA. I know how to get NCUA to YES instead of NO.

I can help if you are currently dealing with or thinking about:

An examination that did not go as well as you hoped

An Examination that is in process right now

An examination that is coming soon

Responding to an NCUA or state examination

Assessing a letter to you from your Regional Director or State Regulator

Seeking NCUA or State Regulator approval for an action you desire to take

Assessing actions you will take in response to a Document of Resolution

Receiving a Letter of Understanding and Agreement

Document of Resolution (DOR) Issues

Examiner Findings

Supplementary Facts

CAMEL Code Downgrades

Capital Adequacy

Asset Quality

Management Code

Earnings

Liquidity Code

Sensitivity Code

Commercial Lending MBL Issues

Interest Rate Risk (IRR)

Net Economic Value (NEV)

Secondary Capital

Subordinated Debt

Exit Conference / Joint Conference Challenges

Fair Lending Exam Issues

Field of Membership (FOM) Expansions

CECL Issues

Appeals

Reputation Risk

Net Worth Restoration Plans (NWRP)

Credit risk

Interest rate risk

Liquidity risk

Transaction risk

Strategic risk

Reputation risk

Compliance risk

NCUA's Large Credit Union Program

Transition to the Office of National Examinations and Supervision (ONES)

CFPB

Strategic Planning

Safety and Soundness

Supervisory Committee

Corporate Governance

Bank Secrecy Act (BSA)

NCUA Examination Priorities

NCUA's Examination Guide

National Supervision Policy Manual

Bank Purchases

Letters to Credit Unions

NCUA Regulations

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