#71: What's Not On NCUA's Supervisory Priority Letter & Why It Matters

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𝙒𝙝𝙖𝙩 𝙞𝙨 𝙉𝙊𝙏 𝙤𝙣 𝙉𝘾𝙐𝘼'𝙨 𝙎𝙪𝙥𝙚𝙧𝙫𝙞𝙨𝙤𝙧𝙮 𝙋𝙧𝙞𝙤𝙧𝙞𝙩𝙞𝙚𝙨 𝙛𝙤𝙧 𝟮𝟬𝟮𝟯?

I write and speak often about NCUA's Supervisory Priorities which come out at this time every year.

Last year NCUA showed a HUGE increase in Priorities (up from 7 and 8 the previous years - to 11 topics).

Yet they didn't increase staff to handle these priorities which reminded me of the old saying - 𝗪𝗵𝗲𝗻 𝗘𝘃𝗲𝗿𝘆𝘁𝗵𝗶𝗻𝗴 𝗜𝘀 𝗔 𝗣𝗿𝗶𝗼𝗿𝗶𝘁𝘆... 𝗡𝗼𝘁𝗵𝗶𝗻𝗴 𝗜𝘀 𝗔 𝗣𝗿𝗶𝗼𝗿𝗶𝘁𝘆...

So I am pleased to see that NCUA has reduced the number of Priorities from 11 to 6!

I will have much content coming here and on my podcast on these 6 priorities soon...

but today I want to mention what "𝗳𝗲𝗹𝗹 𝗼𝗳𝗳" the priority list:

𝗘𝗹𝗲𝗰𝘁𝗿𝗼𝗻𝗶𝗰 𝗣𝗮𝘆𝗺𝗲𝗻𝘁 𝗦𝘆𝘀𝘁𝗲𝗺𝘀: (Odd that it fell off since they only recently hired the new specialists).

𝗕𝗮𝗻𝗸 𝗦𝗲𝗰𝗿𝗲𝗰𝘆 𝗔𝗰𝘁: Ironic that it falls off when they just added BSA Specialists to the Budget - thus making me believe these specialists are being added more to create a career path for staff than expand exams in this area - so that is good for credit unions.

𝗖𝗮𝗽𝗶𝘁𝗮𝗹 𝗔𝗱𝗲𝗾𝘂𝗮𝗰𝘆: This was new to the list last year due to the new rule. Credit union capital is strong and IRR and Liquidity are job 1 and 2 so I get the rationale here also.

𝗖𝗘𝗖𝗟: Implementation is now required and with all the coverage on this topic I am surprised to say it is a non-event for my clients - another good move to take this off the priority list - but not so fast! They just moved it to Other Updates!

𝗟𝗜𝗕𝗢𝗥: goodbye and good riddance!

𝗟𝗼𝗮𝗻 𝗣𝗮𝗿𝘁𝗶𝗰𝗶𝗽𝗮𝘁𝗶𝗼𝗻𝘀: They must have concluded this was more of a good growth trend than a bad growth trend - which also led them to propose changes to the rule to allow more of this down the road (December board proposal).

They also snuck 𝗦𝘂𝗰𝗰𝗲𝘀𝘀𝗶𝗼𝗻 𝗣𝗹𝗮𝗻𝗻𝗶𝗻𝗴 into the "𝗢𝘁𝗵𝗲𝗿 𝗨𝗽𝗱𝗮𝘁𝗲" Category...so the decrease in priorities is actually smaller than it looks on the surface. More to follow from me on this topic soon.

I can't end this post without listing the actual 2023 Priorities - which I will discuss in detail here and elsewhere soon:

𝟭 𝗜𝗥𝗥

𝟮 𝗟𝗶𝗾𝘂𝗶𝗱𝗶𝘁𝘆 𝗥𝗶𝘀𝗸

𝟯 𝗖𝗿𝗲𝗱𝗶𝘁 𝗥𝗶𝘀𝗸

𝟰 𝗙𝗿𝗮𝘂𝗱 𝗣𝗿𝗼𝘁𝗲𝗰𝘁𝗶𝗼𝗻

𝟱 𝗖𝘆𝗯𝗲𝗿 𝗦𝗲𝗰𝘂𝗿𝗶𝘁𝘆

𝟲 𝗖𝗼𝗻𝘀𝘂𝗺𝗲𝗿 𝗙𝗶𝗻𝗮𝗻𝗰𝗶𝗮𝗹 𝗣𝗿𝗼𝘁𝗲𝗰𝘁𝗶𝗼𝗻 (𝗹𝗮𝗻𝗴𝘂𝗮𝗴𝗲 𝗼𝗻 𝗦𝗵𝗮𝗿𝗲 𝗢𝘃𝗲𝗿𝗱𝗿𝗮𝗳𝘁𝘀 𝗶𝘀 𝗾𝘂𝗶𝘁𝗲 𝗶𝗻𝘁𝗲𝗿𝗲𝘀𝘁𝗶𝗻𝗴).