Quick Take on NCUA's Exam Plans for 2026

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In this special preview episode of With Flying Colors, Mark Treichel tees up an upcoming live, on-stage discussion from the Florida Q’s Cruise with team members Steve Farr and Todd Miller.

Just days before the cruise, NCUA released its 2026 Supervisory Priorities Letter, and as always, that letter gives us important clues about what examiners will be focused on in the year ahead — and just as importantly, what’s driving examiner behavior behind the scenes.

This episode serves as a primer for the deeper, post-cruise discussion, where we’ll incorporate real-time feedback and questions from credit union leaders attending the cruise.

🧭 Big Picture Theme: NCUA in Chaos

Before diving into technical priorities, Mark frames the conversation around what many credit unions are experiencing operationally:

• Leadership instability and fewer board actions
• Retirements, buyouts, and staffing losses
• Revolving and often less-experienced examiners
• Exams prioritized over approvals and strategic requests

Bottom line:

Chaos upstream is driving impact downstream — and that reality shapes how exams feel, how findings are delivered, and how long approvals take.

📌 What’s in the 2026 Supervisory Priorities Letter?

Mark walks through the major categories NCUA highlighted and why they matter:

🟦 Lending / Credit Risk

• Delinquencies and charge-offs at decade highs
• Focus on underwriting, concentrations, and workouts
• Continued scrutiny of commercial real estate and indirect lending

🟦 Liquidity & Interest Rate Risk

• Stress testing assumptions under closer review
• Structural liquidity constraints getting more attention
• Alignment between balance sheet strategy and risk appetite

🟦 Earnings & Capital Adequacy

• Sustainability of earnings under stress scenarios
• Capital planning tied directly to risk profiles
• More forward-looking analysis expected in exams

🟦 Payment Systems (Back as a Headline Topic)

• Real-time payments and complex integrations
• Vendor risk, data exposure, and cyber vulnerabilities
• Governance and internal controls over payments ecosystems

🟦 Fraud Prevention and Detection

• Internal controls and separation of duties
• Insider abuse explicitly called out
• Exam procedures being updated to reflect evolving fraud risks

🟦 BSA / AML Compliance Risk Management

• Shift away from broad consumer compliance narrative
• Stronger focus on risk-based AML programs
• Programs must be tailored to actual institutional risk

🔄 What’s Notably Different from Prior Years?

Mark also highlights important shifts compared to earlier supervisory letters:

• Cybersecurity is no longer a standalone headline — now embedded in Operational Risk and Payments
• Consumer financial protection is not emphasized as a top category
• Fraud and payment systems return after being absent for several years
• Governance expectations are increasingly embedded in every risk area

These changes align with what many credit unions are already experiencing in exams — more findings tied to process, oversight, and documentation, not just numbers.

🎤 What’s Coming After the Cruise

During the Florida Q’s Cruise, Mark, Steve, and Todd will be discussing:

• What credit unions are actually seeing in recent exams
• Where examiner expectations are rising fastest
• How governance findings are being framed
• What boards should be asking management right now
• How to manage regulatory uncertainty proactively

After the cruise, a full follow-up episode will bring those insights back to the broader audience.

🎯 Key Takeaway

The risks themselves haven’t changed dramatically — but NCUA’s capacity, processes, and delivery of supervision have.

Credit unions that adapt their governance, documentation, and strategic planning to that reality will be better positioned to manage both exam outcomes and approval delays in 2026 and beyond.

You can’t fix NCUA’s chaos — but you can manage how it impacts you.