The Harsh Realities of a CAMEL Code 4 Downgrade

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Episode Summary: 

In this episode of With Flying Colors, host Mark Treichel is joined by Steve Farrar and Todd Miller from Credit Union Exam Solutions to discuss the serious implications of a CAMEL Code 4 rating. A downgrade to CAMEL 4 signals significant risk and increased regulatory scrutiny. What does this mean for your credit union? What immediate actions should management and the board take? How does this impact borrowing, liquidity, and operations? Get expert insights into navigating the challenges of CAMEL 4 and what steps to take to get back on track. 

What You’ll Learn in This Episode: 

✅ What is a CAMEL Code 4? Understanding why it’s a major red flag
✅ How NCUA views CAMEL 4 credit unions and why they ramp up oversight
✅ The consequences of a downgrade – more frequent exams, lost privileges, and reputational risk
✅ NCUA’s administrative actions – what happens when you receive a Letter of Understanding & Agreement (LUA)
✅ How a CAMEL 4 affects your liquidity – Federal Reserve & Federal Home Loan Bank implications
✅ The impact on borrowing & collateral requirements
✅ The role of the board in a CAMEL 4 credit union – what’s expected of leadership
✅ Can a CAMEL 4 credit union recover? Strategies for improvement 

Key Takeaways: 

🔹 CAMEL 4 credit unions face exams every 120 days, meaning examiners are always present
🔹 Expect Letters of Understanding & Agreements (LUAs) and preliminary warning letters
🔹 NCUA and federal agencies (like the Federal Reserve & FHLB) are notified, impacting borrowing & liquidity
🔹 The board and management face increased accountability, with NCUA requiring approval for senior leadership changes
🔹 A downgrade to CAMEL 4 means administrative oversight, and in some cases, public disclosure (depending on state regulations)
🔹 Credit unions in this category must act quickly to stabilize finances and demonstrate improvement to avoid further decline 

Resources Mentioned: 

📌 NCUA’s National Supervision Policy Manual (for details on CAMEL 4 oversight)
📌 NCUA’s Share Insurance Briefing (for trends in CAMEL ratings)
📌 Credit Union Exam Solutions – Expert consulting for navigating NCUA exams 

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