What Credit Unions Should Really Prepare for After NCUA’s 2026 Priority Letter

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In this episode of With Flying Colors, Mark Treichel is joined by former NCUA senior leaders Todd Miller and Steve Farrar for a deep dive into NCUA’s 2026 Supervisory Priorities Letter — and what it means in the real world for credit unions heading into the next exam cycle. 
Deep Dive on NCUA Priority Lett…

With significant staffing reductions at the agency and a shift toward more “risk-based” supervision, the group discusses whether exam programs will truly become more tailored — or whether credit unions should expect more conservative ratings, more findings, and less dialogue.

The conversation also explores what’s emphasized, what’s missing, and how operational realities inside NCUA may shape supervision more than policy statements.

Key Topics Discussed

🏛️ NCUA Operations and Staffing

• How a 27% reduction in staff could affect exam consistency and depth
• Why less-experienced exam teams may lead to more conservative CAMEL ratings
• Concerns about “CYA supervision” and addressing symptoms rather than root causes

📊 Balance Sheet Management and Credit Risk

• Why industry data does not support claims of worsening asset quality
• Continued focus on credit concentrations and underwriting practices
• What outsourcing of lending and collections may trigger in exams

💧 Liquidity and Interest Rate Risk

• Why interest rate risk is often overstated as a failure driver
• Ongoing scrutiny of liquidity forecasting models
• Growing competition for deposits from fintechs and non-banks

💵 Earnings, Capital, and Rising Expenses

• Why operating expenses are growing faster at credit unions than banks
• Technology investments, staffing costs, and post-COVID catch-up spending
• Capital planning expectations despite fewer references in the priority letter

⚙️ Operational Risk, Payments, and Technology

• Increasing complexity of payment platforms and third-party integrations
• Why internal audit functions matter more than ever
• Risks created by rapid fintech adoption

🕵️ Fraud Prevention and Member Protection

• AI-driven fraud and voice spoofing risks
• Why protecting members is now as critical as protecting institutions
• Reputation risk from scams and social media amplification

📋 Compliance and What’s Missing

• Notable reduction in consumer compliance emphasis
• BSA remains a regulatory constant
• What the absence of certain topics may signal about regulatory priorities

🎙️ Practical Exam Strategy

• Why recording exit conferences can protect credit unions
• How appeals and documentation can matter more in constrained environments

Why This Episode Matters

NCUA’s priority letters set expectations — but exam outcomes are often shaped by staffing, experience, and regional risk perceptions. As the agency continues to restructure, understanding how policy meets practice has never been more important.

This episode offers insider perspective on:

• How exam approaches may shift in 2026
• Where credit unions should expect closer scrutiny
• Why communication and documentation will matter more than ever