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.Earlier this month NCUA issued a Letter to Credit Unions that revises and updates NCUA's Interest Rate Risk Supervisory Guidance. NCUA also conducted an industry webinar on 9/14/22. On this episode I interview Subject Matter Expert Todd Miller on the letter, and the webinar. We recorded this podcast immediately after the webinar to get our instant response to what was said, and what wasn't said.Clarifying When a DOR to Address IRR Is WarrantedA DOR is not required for any NEV Test or ENT risk classification alone. Similarly, a credit union is not expected to have a plan of action just because their IRR classification is high. Instead, the need for a DOR and a written plan of action are to be determined on a case-by-case basis. The following are examples of when a DOR should be considered:The credit union’s level of IRR represents an undue risk to the Share Insurance Fund, and the credit union is not taking appropriate and prompt action to address its level of IRR.9The credit union has high IRR and has not adequately updated its approach to managing its interest rate, liquidity, and related risks for current market conditions.The credit union has a material governance deficiency (identify, measure, monitor, and control) relative to its level of IRR.10The following are examples of when a DOR may not be necessary:The migration to a high risk classification in the NEV Test or ENT is primarily from a rapid change in interest rates. However, examiners should focus on how the credit union’s management of IRR has been adjusted to the new interest rate environment.The credit union has already acted or has an adequate plan to adapt to the current interest rate environment.11Providing Examiners More Flexibility in Assigning IRR Supervisory Risk Ratings12Examiners will assign the IRR rating based on the quantitative NEV Test or ENT but may improve the rating on other factors. If the NEV Test or ENT show a high or moderate risk classification, examiners may adjust the IRR rating up or down. While these instances may occur, it would be unusual for an examiner to improve the IRR rating when the NEV Test or ENT results in a high risk classification. This scenario will most often result from borderline moderate- to high-risk classifications, though could occur in low- to moderate-risk classifications, as well. For example, in a borderline case, conservative assumptions in the IRR model combined with a low risk qualitative rating may be sufficient for the examiner to improve the credit union’s IRR rating, whereas the opposite may warrant a downgrade. When considering a change to the IRR rating, examiners will fully document the quantitative and qualitative factors that warranted the change to the rating.The review of a credit union’s IRR may result in a high IRR rating and may also warrant a change in the “S” (Sensitivity to Market Risk) CAMELS component rating.Revising Examination Procedures to Incorporate Updated Review Steps When Assessing How a Credit Union’s Management of IRR Is Adapting to Changes in the Economic and Interest Rate EnvironmentExaminers use the IRR Workbook as a job aid when considering topics and questions during the review of IRR. Recognizing the current volatility of economic and interest rate environments, the following topics will be integrated into the IRR Workbook along with a new resource tab (High IRR Job Aid) to understand the range of scenarios and mitigation strategies.The integration of these topics will expand on existing review steps, when applicable for a credit union. For example, if a credit union holds total assets between $500 million and $10 billion with a high NEV Test risk classification, the examiner review will include the source of high IRR, risk management and controls, and potential impact on earnings and capital. Credit unions with total assets exceeding $10 billion require all review steps in the IRR Workbook, regardless of the risk classification.

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.In this episode of With Flying Colors, Mark Treichel interviews Dan Prezioso, a Partner at Olden Lane. Olden Lane provides financial services to credit unions throughout the United States including advising and assisting in the raising of subordinated debt (previously known as secondary capital). We discuss the topics below (and many more):●       Current Trends In Sub Debt●        Purposes of Sub Debt●        NCUA Letter to Credit Unions – Evaluating Credit Union Plans●        Low Income Designated Credit Unions●        ECIP●        Risk-Based Capital With respect to an Issuing Credit Union that is a complex credit union (500M) and not a LICU, the aggregate outstanding principal amount of Subordinated Debt is included in the credit union's RBC Ratio. If a credit union is both a LICU and complex, the aggregate outstanding principal amount of Subordinated Debt, including Grandfathered Secondary Capital, will count towards that credit union’s net worth ratio and RBC Ratio.

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, we discuss NCUA Letter to Credit Union's #22-CU-08 Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence with returning guest Deborah Arndell, President of ARMOR Advisory Services. The National Credit Union Administration (NCUA), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the U.S. Department of Treasury's Financial Crimes Enforcement Network have prepared a statement. It clarifies the long-standing position that banks and credit unions must take a risk-based approach to assess individual customer risk. The attached joint statement reinforces the NCUA's position that no single customer type automatically presents a high risk of money laundering, terrorist financing, or another illicit financial activity risk. The regulations established in the Bank Secrecy Act (BSA) establish a risk-based approach to assessing customer relationships and conducting customer due diligence. The NCUA expects credit unions to assess the risks posed by each customer individually. Further, the NCUA advises against refusing or discontinuing service to an entire class of customers based on perceived risk. Credit unions that comply with BSA and anti-money laundering (AML) requirements and have an effective customer due diligence program are well-positioned to manage customer relationships and risks appropriately, based on each customer relationship. The Federal Financial Institutions Examination Council's BSA/AML Examination Manual (Manual) identifies specific customer types to guide examiners regarding unique characteristics. The Manual is not intended to suggest that those characteristics represent a higher money laundering, terrorist financing, or illicit finance risk. Ultimately, each credit union decides to provide or maintain financial services to any customer. Don't hesitate to get in touch with your Regional Office or state supervisory authority if you have questions about this letter or the attached statement.

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.At its July Board Meeting NCUA conducted a briefing on the budget year to date and discussed plans for this year's public budget briefing.I provide you with my thoughts on the statements of NCUA staff and NCUA's board during the briefing, with actual footage from NCUA's youtube recording of the meeting.NCUA's full July Board Meeting can be found here: https://www.youtube.com/watch?v=bj7kUqbc2o4&t=5530s

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.NAFCU's recent letter to NCUA has suggestions on how to improve the bank purchases and credit union to credit union mergers.In this episode I provide my take on their suggestions.Marktreichel.com

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.In this episode I discuss NAFCU's recommendations to NCUA relative to subordinated debt for Low Income Designation Credit Unions.The legal costs for small credit unions is indeed a burden and preventing many from getting subordinated debt that would help the credit union and its members.Marktreichel.com

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.NAFCU recently wrote NCUA and requested many regulation changes. In this episode I discuss their proposals on NAFCU's letter on Bylaws, Member Expulsion and frequency of credit union board meeting requirements.www.marktreichel.com

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.At its July Board meeting, NCUA proposed changes to its rules for credit unions on Cyber Incident Notification Requirements. In this episode I provide commentary on the rule, and also include publicly available discussions at the board table from the NCUA Board: Todd Harper, Kyle Hauptman, and Rodney Hood, as well as NCUA staff.NCUA's full board recording can be found here: https://www.youtube.com/watch?v=bj7kUqbc2o4&t=5530sNCUA's proposed rule language can be found here:https://www.ncua.gov/files/agenda-items/cyber-incident-proposed-rule-20220721.pdf

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.NAFCU wrote NCUA on regulations it recommends be changed. In this podcast I discuss my take on NAFCU's suggestions on Capital Adequacy relative to large credit union of $10 billion in assets.www.marktreichel.com

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.A CUSO (Credit Union Service Organization) is an organizational entity owned by credit unions that provides at least four types of loans: residential mortgage, business, student, and credit card. Unfortunately, as the years progressed, it became quite archaic for CUSO not to have the lending powers assist credit unions in all types of loans. And in October 2021, changes were made that expanded its activities and services. Helping you keep up to date with the latest on CUSO, Mark Treichel invites a guest who has been assisting credit unions in finding ways to collaboratively work with other credit unions and third-party services. In this episode, Brian Lauer of Messick Lauer & Smith P.C. helps untangle the knots made by the movements of CUSO and dives deep into the new CUSO regulation, CUSO trends, and why every credit union should consider investing in a CUSO. He also talks about it in relation to FinTech and cryptocurrency. Interested to learn more? Tune into this conversation!