Who Sees Your NCUA Exam Before You Do?

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Host: Mark Treichel
Guests: Todd Miller and Steve Farrar, former NCUA examiners

Key Points:

1. NCUA implemented a new policy requiring higher-level review of all examination reports before release to credit unions.

2. The review process varies based on credit union size and CAMEL rating:
   - Under $50 million and CAMEL 1-3: Supervisor review only (10 business days)
   - $50-250 million or CAMEL 4-5: Division of Supervision review (additional 15 days) 
   - Over $250 million: Associate Regional Director review
   - Over $1 billion: Additional reviews, can take up to 55 days total

3. Exam cycles:
   - Well-run credit unions under $1 billion: 14-20 months between exams
   - Most credit unions: Annual exams (8-12 months apart)
   - CAMEL 3 ratings: Follow-up within 180 days 
   - CAMEL 4 ratings: Follow-up within 120 days

4. Challenges with the review process:
   - Can delay report delivery beyond NCUA's 90-day goal
   - May introduce new issues not discussed during fieldwork
   - Lack of transparency for credit unions on report status

5. Additional exam types discussed:
   - Fair lending exams
   - CUSO reviews
   - Special follow-ups for recordkeeping or BSA issues

The hosts emphasize the importance of credit unions staying in contact with examiners if reports are delayed and note that while the review process has benefits, it can sometimes lead to frustrations with timing and new findings.

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