Credit Union Exam Solutions Presents With Flying Colors

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.Today's guest will paint us a picture of great value with flying colors!In this episode, Mark Treichel speaks with Geoff Bacino, a former NCUA Board Member, about the NCUA Board. Geoff also shares the work he does managing three associations, and one of the associations he runs is the National Association of State Chartered Credit Unions. There is much more to unpack in this episode, so what are you waiting for? Tune in to this episode now!

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.During his GAC Speech, NCUA Chairman Todd Harper said:"... It doesn't seem fair that credit union members have less protection than bank customers...and it's why we are now creating consumer compliance specialist positions in the field and starting the process to build out an enhanced consumer compliance exam program..."more text from his speech follows:State of the Credit Union SystemIn terms of overall performance, federally insured credit unions remained on a solid footing last year. Total loans, assets, and insured shares all increased. Capital levels also remained strong. Economic activity — however — has begun to cool. Insured share growth has slowed, as some consumers have drawn down their built-up savings. Households are also taking on more debt. And, in the event of an economic slowdown, these factors could hinder borrowers’ ability to repay outstanding debt, exposing your credit union to greater levels of credit risk. That’s why we must all take actions to prepare for a downturn.Interest Rate RiskIn fact, your ability to manage interest rate risk will be a crucial factor in your performance in 2023. Interest rates rose across the yield curve last year. As rates increase in the current economic environment, so does the associated risk that makes short-term liquidity events possible. The potential for sudden changes in either inflation, the rate environment, or the economy mean that you must remain nimble.Consumer Financial ProtectionNow, I know that many of you have heard me say this before, but I’m going to keep saying it because it is part of my core beliefs: All consumers — regardless of their financial services provider of choice — should receive the same level of consumer financial protection. Yet, unlike the federal banking agencies, the NCUA does not conduct separate consumer compliance exams nor does the agency assign a separate consumer financial protection rating. It doesn’t seem fair that credit union members have less protection than bank customers.During my four years on the NCUA Board, the agency has made some strides like increasing its fair lending exams and reviews. And, it’s why we are now creating consumer compliance specialist positions in the field, and starting the process to build out an enhanced consumer compliance exam program. And, as part of its supervisory priorities this year, the NCUA continues to focus on overdraft programs and will dive more deeply into certain features.To that end, NCUA examiners will review website advertising related to overdraft programs, balance calculation methods, and settlement processes. And, examiners at federal credit unions with more than $500 million in assets will dig into authorize positive, settle negative transactions, as well as some other problematic fees. Our supervisory efforts here are aimed at creating a more equitable financial system that enables financial security for credit union members, especially those of modest means.*******************In 33 years at NCUA I served as Executive Director, Regional Director, Director of Special Actions, Supervisory Examiner, and Principal Examiner. I began at the ground level as an examiner. I rose to the top. As Executive Director I supervised your Regional Director. I know how NCUA thinks and why they think it. I know the examination process inside and out. I know how to communicate and negotiate with NCUA. I know how to get NCUA to YES instead of NO. I can help if you are currently dealing with or thinking about:An examination that did not go as well as you hopedAn Examination that is in process right nowAn examination that is coming soonResponding to an NCUA or state examinationAssessing a letter to you from your Regional Director or State RegulatorSeeking NCUA or State Regulator approval for an action you desire to takeAssessing actions you will take in response to a Document of ResolutionReceiving a Letter of Understanding and AgreementReach out to learn how I can assist

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.Liquidity RiskHigher interest rates have caused a slowdown in prepayments for some loans and investment holdings, which has resulted in reduced cashflows. Large increases in share balances from 20202022 may result in an increased level of share sensitivity and share roll off as market rates continue to rise.In evaluating the “L” component of the CAMELS rating to determine the adequacy of your credit union’s liquidity risk management framework, examiners will consider the current and prospective sources of liquidity compared to funding needs. Examiners will review your credit union’s liquidity policies, procedures, and risk limits. Examiners will also evaluate the adequacy of your credit union’s liquidity risk management framework relative to the size, complexity, and risk profile of your credit union.Examiners will assess liquidity management by evaluating:The potential effects of changing interest rates on the market value of assets and borrowing capacity.Scenario analysis for liquidity risk modeling, including possible member share migrations (for example, shifts from core deposits into more rate-sensitive accounts).Scenario analysis for changes in cash flow projections for an appropriate range of relevant factors (for example, changing prepayment speeds).The appropriateness of contingency funding plans to address any plausible unexpected liquidity shortfalls.Resources and guidance on liquidity risk can be found in the NCUA’s Examiner’s Guide.https://www.linkedin.com/in/mark-treichel/In 33 years at NCUA I served as Executive Director, Regional Director, Director of Special Actions, Supervisory Examiner, and Principal Examiner. I began at the ground level as an examiner. I rose to the top. As Executive Director I supervised your Regional Director. I know how NCUA thinks and why they think it. I know the examination process inside and out. I know how to communicate and negotiate with NCUA. I know how to get NCUA to YES instead of NO. I can help if you are currently dealing with or thinking about:An examination that did not go as well as you hopedAn Examination that is in process right nowAn examination that is coming soonResponding to an NCUA or state examinationAssessing a letter to you from your Regional Director or State RegulatorSeeking NCUA or State Regulator approval for an action you desire to takeAssessing actions you will take in response to a Document of ResolutionReceiving a Letter of Understanding and AgreementDocument of Resolution (DOR) IssuesExaminer FindingsSupplementary FactsCAMEL Code DowngradesCapital AdequacyAsset QualityManagement CodeEarningsLiquidity CodeSensitivity CodeCommercial Lending MBL IssuesInterest Rate Risk (IRR)Net Economic Value (NEV)Secondary CapitalSubordinated DebtExit Conference / Joint Conference ChallengesFair Lending Exam IssuesField of Membership (FOM) ExpansionsCECL IssuesAppealsReputation RiskNet Worth Restoration Plans (NWRP)Credit riskInterest rate riskLiquidity riskTransaction riskStrategic riskReputation riskCompliance riskNCUA's Large Credit Union ProgramTransition to the Office of National Examinations and Supervision (ONES)CFPBStrategic PlanningSafety and SoundnessSupervisory CommitteeCorporate GovernanceBank Secrecy Act (BSA)NCUA Examination PrioritiesNCUA's Examination GuideNational Supervision Policy ManualBank PurchasesLetters to Credit UnionsNCUA Regulations Reach out today to discuss how I can assist you and your cr...

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.Interest Rate RiskInterest rates rose significantly across the yield curve during 2022, elevating interest rate risk (IRR) and the related exposure to earnings and capital. This sharp rise in rates has amplified market risk because a credit union’s assets and liabilities do not reprice equally, potentially impacting net economic values and credit unions’ projected earnings.In September 2022, the NCUA issued Letter to Credit Unions 22-CU-09, Updates to Interest Rate Risk Supervisory Framework, and Supervisory Letter 22-01, Updates to Interest Rate Risk Supervisory Framework, updating the NCUA supervisory framework for IRR.With the April 2022 addition of the Sensitivity to Market Risk, or “S,” component to the CAMELS rating system, the agency has formalized the focus on IRR as a specific rating category separate from liquidity risk.High levels of IRR can increase your credit union’s liquidity risks, contribute to asset quality deterioration and capital erosion, and put pressure on earnings.Well-managed credit unions are prudent and proactive in managing IRR and the related risks to capital, asset quality, earnings, and liquidity. As such, examiners will review your credit union’s IRR program for the following key risk management and control activities:Key assumptions and related data sets are reasonable and well documented.The credit union’s overall level of IRR exposure is properly measured and controlled.Results are communicated to decision-makers and the board of directors.Proactive action is taken to remain within safe and sound policy limits.Additional references for IRR are in the Examiner’s Guide under Workpapers and Resources In 33 years at NCUA I served as Executive Director, Regional Director, Director of Special Actions, Supervisory Examiner, and Principal Examiner. I began at the ground level as an examiner. I rose to the top. As Executive Director I supervised your Regional Director. I know how NCUA thinks and why they think it. I know the examination process inside and out. I know how to communicate and negotiate with NCUA. I know how to get NCUA to YES instead of NO. I can help if you are currently dealing with or thinking about:An examination that did not go as well as you hopedAn Examination that is in process right nowAn examination that is coming soonResponding to an NCUA or state examinationAssessing a letter to you from your Regional Director or State RegulatorSeeking NCUA or State Regulator approval for an action you desire to takeAssessing actions you will take in response to a Document of ResolutionReceiving a Letter of Understanding and AgreementDocument of Resolution (DOR) IssuesExaminer FindingsSupplementary FactsCAMEL Code DowngradesCapital AdequacyAsset QualityManagement CodeEarningsLiquidity CodeSensitivity CodeCommercial Lending MBL IssuesInterest Rate Risk (IRR)Net Economic Value (NEV)Secondary CapitalSubordinated DebtExit Conference / Joint Conference ChallengesFair Lending Exam IssuesField of Membership (FOM) ExpansionsCECL IssuesAppealsReputation RiskNet Worth Restoration Plans (NWRP)Credit riskInterest rate riskLiquidity riskTransaction riskStrategic riskReputation riskCompliance riskNCUA's Large Credit Union ProgramTransition to the Office of National Examinations and Supervision (ONES)CFPBStrategic PlanningSafety and SoundnessSupervisory Committee

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.Fraud Prevention, Cyber-Security and Consumer Protection - are covered today relative to NCUA's Supervisory Priority Letter. We also discuss succession planning, transparency, and more!Per the letter:

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.NCUA's 2023 Priority Letter was recently released. In this episode I discuss the top 3: Interest Rate Risk, Liquidity Risk, and Credit Risk with two members of my team: Todd Miller and Steve Farrar.Per NCUA:Supervisory Priorities for 2023Interest Rate RiskInterest rates rose significantly across the yield curve during 2022, elevating interest rate risk (IRR) and the related exposure to earnings and capital. This sharp rise in rates has amplified market risk because a credit union’s assets and liabilities do not reprice equally, potentially impacting net economic values and credit unions’ projected earnings.In September 2022, the NCUA issued Letter to Credit Unions 22-CU-09, Updates to Interest Rate Risk Supervisory Framework, and Supervisory Letter 22-01, Updates to Interest Rate Risk Supervisory Framework, updating the NCUA supervisory framework for IRR.With the April 2022 addition of the Sensitivity to Market Risk, or “S,” component to the CAMELS rating system, the agency has formalized the focus on IRR as a specific rating category separate from liquidity risk.High levels of IRR can increase your credit union’s liquidity risks, contribute to asset quality deterioration and capital erosion, and put pressure on earnings.Well-managed credit unions are prudent and proactive in managing IRR and the related risks to capital, asset quality, earnings, and liquidity. As such, examiners will review your credit union’s IRR program for the following key risk management and control activities:Key assumptions and related data sets are reasonable and well documented.The credit union’s overall level of IRR exposure is properly measured and controlled.Results are communicated to decision-makers and the board of directors.Proactive action is taken to remain within safe and sound policy limits.Additional references for IRR are in the Examiner’s Guide under Workpapers and Resources(opens new window).Liquidity RiskHigher interest rates have caused a slowdown in prepayments for some loans and investment holdings, which has resulted in reduced cashflows. Large increases in share balances from 20202022 may result in an increased level of share sensitivity and share roll off as market rates continue to rise.In evaluating the “L” component of the CAMELS rating to determine the adequacy of your credit union’s liquidity risk management framework, examiners will consider the current and prospective sources of liquidity compared to funding needs. Examiners will review your credit union’s liquidity policies, procedures, and risk limits. Examiners will also evaluate the adequacy of your credit union’s liquidity risk management framework relative to the size, complexity, and risk profile of your credit union.Examiners will assess liquidity management by evaluating:The potential effects of changing interest rates on the market value of assets and borrowing capacity.Scenario analysis for liquidity risk modeling, including possible member share migrations (for example, shifts from core deposits into more rate-sensitive accounts).Scenario analysis for changes in cash flow projections for an appropriate range of relevant factors (for example, changing prepayment speeds).The appropriateness of contingency funding plans to address any plausible unexpected liquidity shortfalls.Resources and guidance on liquidity risk can be found in the NCUA’s Examiner’s Guide.Credit RiskCredit risk is a supervisory priority for 2023 as high inflation and rising interest rates are putting financial pressure on credit union members. High inflation and the increasing likelihood of an increase in unemployment rates could negatively impact borrowers’ ability to repay outstanding debt. Rising interest rates could also result in higher loan payments for borrowers.

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.NCUA just approved its Annual Performance Plan. It included a goal of achieving CAMELS code 4s and 5s of less than 2 percent of assets. This would allow an a ten fold increase of current numbers!Per NCUAThe National Credit Union Administration’s Annual Performance Plan, in concert with the agency’s budget, outlines the resources and strategies the NCUA will use to set priorities and improve performance. This plan is guided by the NCUA’s 2018–2022 Strategic Plan, which includes the following strategic goals: 1. Ensure a safe and sound credit union system; 2. Provide a regulatory framework that is transparent, efficient and improves consumer access; and 3. Maximize organizational performance to enable mission success. The Annual Performance Plan sets out performance measures and targets in support of the goals in the Strategic Plan. The NCUA’s Annual Performance Plan has five components: (1) strategic goals; (2) strategic objectives (3) performance goals; (4) performance measures and associated targets; and (5) means and strategies to accomplish the strategic objectives.About Credit Union Exam Solutions:In 33 years at NCUA I served as Executive Director, Regional Director, Director of Special Actions, Supervisory Examiner, and Principal Examiner. I began at the ground level as an examiner. I rose to the top. As Executive Director I supervised your Regional Director. I know how NCUA thinks and why they think it. I know the examination process inside and out. I know how to communicate and negotiate with NCUA. I know how to get NCUA to YES instead of NO. I can help if you are currently dealing with or thinking about:An examination that did not go as well as you hopedAn Examination that is in process right nowAn examination that is coming soonResponding to an NCUA or state examinationAssessing a letter to you from your Regional Director or State RegulatorSeeking NCUA or State Regulator approval for an action you desire to takeAssessing actions you will take in response to a Document of ResolutionReceiving a Letter of Understanding and AgreementDocument of Resolution (DOR) IssuesExaminer FindingsSupplementary FactsCAMEL Code DowngradesCapital AdequacyAsset QualityManagement CodeEarningsLiquidity CodeSensitivity CodeCommercial Lending MBL IssuesInterest Rate Risk (IRR)Net Economic Value (NEV)Secondary CapitalSubordinated DebtExit Conference / Joint Conference ChallengesFair Lending Exam IssuesField of Membership (FOM) ExpansionsCECL IssuesAppealsReputation RiskNet Worth Restoration Plans (NWRP)Credit riskInterest rate riskLiquidity riskTransaction riskStrategic riskReputation riskCompliance riskNCUA's Large Credit Union ProgramTransition to the Office of National Examinations and Supervision (ONES)CFPBStrategic PlanningSafety and SoundnessSupervisory CommitteeCorporate GovernanceBank Secrecy Act (BSA)NCUA Examination PrioritiesNCUA's Examination GuideNational Supervision Policy ManualBank PurchasesLetters to Credit UnionsNCUA Regulations Reach out today to discuss how I can assist you and your credit union.

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.Winston Churchill said never let a good crisis go to waste. This is why NCUA should have approved a rule allowing Federal Credit Unions to grant loans up to 21%.Per NCUA:Board approval to maintain the current temporary 18 percent interest rate ceiling, for loans made by federal credit unions (FCUs), for a new eighteen-month period from March 11, 2023, through September 10, 2024. 12 USC §1757(5)(A)(vi)(I). Notwithstanding this action, nothing in the Federal Credit Union Act precludes the NCUA Board from acting on the 18 percent interest rate ceiling earlier than 18 months.The Federal Credit Union Act, 12 USC §1757(5)(A)(vi)(I), requires the NCUA to consult with the following external parties before establishing an interest rate ceiling above 15 percent: the appropriate committees of Congress, the Department of the Treasury, and the Federal financial institution regulatory agencies. The agency has received letters from the Senate Committee on Banking, Housing and Urban Affairs and the Department of Treasury in support of maintaining the loan rate ceiling at 18 percent.If the Board does not take action before March 11, 2023, to renew a maximum loan interest rate ceiling of greater than 15 percent, the maximum FCU loan interest rate ceiling will revert to the statutory level of 15 percent, including rates on Payday Alternative Loans. 1 In accordance with the requirements set forth in 12 U.S.C. §1757(5)(A)(vi)(I), staff analyzed recent market and financial conditions to advise the Board whether it should continue to establish a maximum interest rate ceiling for loans made by FCUs that exceeds the 15 percent limit established in the Federal Credit Union Act. Specifically, §1757(5)(A)(vi)(I) provides that: [T]he rate of interest may not exceed 15 per centum per annum on the unpaid balance inclusive of all finance charges, except that the Board may establish, after consultation with the appropriate committees of the Congress, the Department of Treasury, and the Federal financial institution regulatory agencies, an interest rate ceiling exceeding such 15 per centum per annum rate, for periods not to exceed 18 months, if it determines that money market interest rates have risen over the preceding six-month period and that prevailing interest rate levels threaten the safety and soundness of individual credit unions as evidenced by adverse trends in liquidity, capital, earnings, and growth. Staff concludes that the two statutory conditions have been met. Money market rates have risen over the preceding six-month period and lowering the interest rate ceiling below the current temporary 18 percent maximum would threaten the safety and soundness of individual credit unions due to the anticipated adverse effects upon liquidity, capital, earnings, and growth. Staff has determined that a significant number of FCUs would be adversely affected absent a Board action to sustain a maximum FCU loan interest rate ceiling at 18 percent. There are 2,177 FCUs that hold over $24 billion in loan balances with rates above 15 percent. Of those 2,177 FCUs, 877 FCUs have loan balances of $21.0 billion with average rates greater than 17 percent. Staff recommends the loan interest rate ceiling be maintained at the current level of 18 percent per annum. More detailed information regarding the results of the analysis is included in the attachment entitled “Supplemental Information and Interest Rate Statistics.”In 33 years at NCUA I served as Executive Director, Regional Director, Director of Special Actions, Supervisory Examiner, and Principal Examiner. I began at the ground level as an examiner. I rose to the top. As Executive Director I supervised your Regional Director. I know how NCUA thinks and why they think it. I know the examination process inside and out. I know how to communicate and negotiate with NCUA. I know how to get NCUA to YES instead of NO.

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.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 𝗜𝗥𝗥𝟮 𝗟𝗶𝗾𝘂𝗶𝗱𝗶𝘁𝘆 𝗥𝗶𝘀𝗸𝟯 𝗖𝗿𝗲𝗱𝗶𝘁 𝗥𝗶𝘀𝗸𝟰 𝗙𝗿𝗮𝘂𝗱 𝗣𝗿𝗼𝘁𝗲𝗰𝘁𝗶𝗼𝗻𝟱 𝗖𝘆𝗯𝗲𝗿 𝗦𝗲𝗰𝘂𝗿𝗶𝘁𝘆𝟲 𝗖𝗼𝗻𝘀𝘂𝗺𝗲𝗿 𝗙𝗶𝗻𝗮𝗻𝗰𝗶𝗮𝗹 𝗣𝗿𝗼𝘁𝗲𝗰𝘁𝗶𝗼𝗻 (𝗹𝗮𝗻𝗴𝘂𝗮𝗴𝗲 𝗼𝗻 𝗦𝗵𝗮𝗿𝗲 𝗢𝘃𝗲𝗿𝗱𝗿𝗮𝗳𝘁𝘀 𝗶𝘀 𝗾𝘂𝗶𝘁𝗲 𝗶𝗻𝘁𝗲𝗿𝗲𝘀𝘁𝗶𝗻𝗴).