Credit Union Exam Solutions Presents With Flying Colors

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/1. NCUA's Document of Resolution (DOR):   - Issued for serious, systemic problems within credit unions   - Indicates deep-rooted issues that require immediate attention   - Not a routine action, but a significant regulatory step2. Management Concerns:   - NCUA issues DORs when they conclude management is:     a) Unwilling to address the underlying problems, or     b) Unable to effectively tackle the issues   - Suggests a breakdown in the credit union's leadership or operational practices3. NCUA's Approach:   - These actions are not taken lightly by the NCUA   - Thorough investigation and consideration precede a DOR   - Indicates NCUA's serious concerns about the credit union's stability or compliance4. Rarity of Action:   - DORs of this nature are issued on rare occasions   - Underscores the severity of the situation when they are issued5. Professional Assistance:   - Expert help is available for credit unions facing NCUA actions   - Proper guidance can lead to time and cost savings   - May help in addressing NCUA concerns more effectivelyCall to Action: Reach out to learn how our experienced team can assist your credit union in navigating NCUA actions. We specialize in helping clients save time and money while addressing regulatory concerns.Background Context:The National Credit Union Administration (NCUA) is the federal agency that regulates, charters, and supervises federal credit unions. Their actions, especially severe ones like issuing a DOR, can have significant implications for a credit union's operations and future.Is there any specific area you'd like me to elaborate on further?

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.Guest: Vin Vieten, former commercial lender and NCUA regulatorhttps://www.linkedin.com/in/mark-treichel/Key Points:1. Credit risk rating systems are a standard practice in commercial lending and now required by NCUA regulations2. A good credit risk rating system should be dynamic, accurate, and updated regularly3. Credit risk ratings typically use a scale of 1-8, with 1-4 being "pass" grades and higher numbers indicating increasing risk4. Both quantitative and qualitative factors should be considered when assigning credit risk ratings5. Regular monitoring and updating of credit risk ratings can benefit both the credit union and the borrowerKey Quotes:"Rating credit risk is a standard practice accepted practice. In managing commercial loan risk, all the other regulators focus on it...""To be effective, the risk rating system should be accurate at all times...""I personally believe that the quantitative is the easy part. It's that qualitative. And that's where your skills as a lender come in."Resources Mentioned:1. NCUA Part 723 (MBL/Commercial Lending Rule)2. NCUA Examiner's Guide on Rating Credit Risk3. Interagency Guidance on Credit Risk Review4. OCC Handbook on Rating Credit Risk (2001)Takeaway: Implementing and maintaining an accurate credit risk rating system is crucial for effective commercial lending management and regulatory compliance.

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Host: Mark TreichelGuests: Todd Miller and Steve Farrar, former NCUA examinersKey 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 total3. 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 days4. 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 status5. Additional exam types discussed:   - Fair lending exams   - CUSO reviews   - Special follow-ups for recordkeeping or BSA issuesThe 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. Are 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.Understanding HMDA## Episode SummaryIn this episode of With Flying Colors, host Mark Treichel interviews Joe Goldberg, a retired NCUA consumer compliance expert, about the Home Mortgage Disclosure Act (HMDA). Joe provides an in-depth overview of HMDA, its purpose, requirements, and importance for credit unions.## Key Points1. HMDA Background and Purpose   - Enacted in 1975 to address housing issues and prevent discrimination   - Provides over 45 years of good mortgage data2. HMDA Requirements   - Applies to credit unions meeting specific criteria (asset size, location, loan activity, and volume)   - Requires collection and reporting of 48 data points on mortgage applications and loans3. Data Collection and Reporting   - Data must be recorded in a Loan Application Register (LAR)   - LARs must be updated quarterly   - Annual submission deadline: March 1st of the following year4. Partial Exemptions   - Available for institutions originating fewer than 500 covered closed-end mortgages or open-end lines of credit   - Reduces reporting requirements from 48 to 22 data points5. Use of HMDA Data   - Regulators use it for fair lending programs and compliance checks   - Credit unions can use it to assess their performance and improve fair lending programs6. Compliance Tips   - File data even if late to avoid more serious violations   - Utilize resources like FFIEC's "Getting It Right Guide" and CFPB's website## Notable Quotes"HMDA goes back to 1975, which is when it was enacted. And so, as a result of that, we actually have mortgage data, good mortgage data, going back for over 45 years.""Even if you're late, file the data.""I just think it's important for credit unions to understand, though, that even though complying with HMDA can be a chore, that there is a valid reason for collecting the HMDA data, and that is to try and ensure that mortgage credit is offered and extended to everybody based on mortgage related criteria."## Resources Mentioned- NCUA Regulatory Alerts- FFIEC Website (www.ffiec.gov)- FFIEC's "Getting It Right Guide"- Consumer Financial Protection Bureau Website (consumerfinance.gov)- Lending Patterns software by Compliance Tech (used by NCUA)## About the GuestJoe Goldberg is a retired NCUA consumer compliance expert with over 40 years of experience as a lawyer. He has taught consumer law and worked in various aspects of financial regulation.## SponsorThis episode is sponsored by Credit Union Exam Solutions by Mark Treichel. Visit marktreichel.com for more information on optimizing your results with NCUA.

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.Why Does NCUA Ask to Meet with CU Board without CU Staff Present?Join Mark Treichel and his team as they delve into the rare but important topic of why the National Credit Union Administration (NCUA) might ask to meet with a credit union's board of directors without staff present. In this episode, Mark, Steve Farrar, and Todd Miller share personal experiences and insights from their extensive careers in credit union examination and supervision. Learn about the reasons behind such requests, how to handle these meetings, and the implications they might have for your credit union.  Guest Introductions Steve Farrar's Background Todd Miller's Background Increasing NCUA Board Meetings without Staff Board Chair vs. Full Board Meetings Meeting with Specific Board Members Supervisory Committee Conversations Handling Full Board Meetings without Staff Considerations for Board Responses Recording Meetings and Legal Counsel Emotional Responses and Agreement Caution Conclusion 

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.Guest: Vin Vieten, former NCUA Senior Credit SpecialistKey Topics:- Financial analysis for commercial lending- Credit proposal best practices - Global cash flow analysisKey Takeaways:1. Financial Analysis:   - Should be well-organized, consistent, and comprehensive   - Analyze 3+ years of financial performance to establish trends   - Examine income statement, balance sheet, and cash flow   - Provide value to borrowers through expert financial review2. Credit Proposals:   - Use a standard, logical format    - Include key information like ownership structure, industry analysis, repayment ability   - List all direct and related debt to show total relationship exposure   - Assign and justify an appropriate risk rating   - Highlight exceptions to policy on the cover page3. Global Cash Flow:   - Analyzes borrower, guarantor, and related entities to understand overall risk   - Depth of analysis depends on transaction complexity and risk level   - Should drive understanding of risk, not just regulatory compliance   - Default expectation is to obtain guarantees; exceptions must be well-documentedResources Mentioned:- NCUA Examiner's Guide on financial analysis and credit approval documents- Preamble to the proposed MBL rule from July 2015Contact: https://www.linkedin.com/in/mark-treichel/

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.# With Flying Colors Podcast: CAMEL Code 4 - What You Need to Know Episode SummaryMark Treichel discusses CAMEL Code 4 ratings for credit unions with guests Steve Farrar and Todd Miller, both former NCUA employees. They explore what a Code 4 rating means, its implications, and what credit unions should expect.## Key Points1. CAMEL Code 4 Definition:   - Indicates unsafe and unsound practices or conditions   - Risk management practices considered unacceptable for credit union size/complexity   - NCUA may have concerns about management's ability to correct problems2. Implications of a Code 4 Rating:   - Administrative action (usually unpublished Letter of Understanding and Agreement)   - Examinations every 120 days (6-12 weeks of examiner presence annually)   - Potential loss of Federal Reserve daylight overdrafts   - Possible assignment to NCUA's Division of Special Actions   - Federal Home Loan Bank may eventually be notified, potentially affecting borrowing terms3. Board and Management Responsibilities:   - Increased expectation for board to hold management accountable   - More frequent progress reporting to the board   - Need to authorize resources for problem resolution4. Financial Implications:   - May affect NCUSIF equity ratio, especially for larger credit unions   - Potential collateral requirements from lenders   - Possible issues with mortgage sales on secondary market5. Regulatory Oversight:   - NCUA approval required for changes in senior management and board members   - More detailed Document of Resolution (DOR) requirements6. Comparison to CAMEL Code 5:   - Code 5 indicates imminent failure risk   - Limited options, often leading to regulator-driven mergers or conservatorship## Guest Backgrounds- Steve Farrar: 30-year NCUA career, split between field work and central office roles- Todd Miller: 34-year NCUA career, including roles as examiner, capital market specialist, and director of special actions## Additional Notes- Discussion of historical tools like PUED (Prior Undivided Earnings Deficit) no longer available to NCUA- Emphasis on the challenging but potentially rewarding nature of working with troubled credit unions

Credit risk management takes center stage as experts discuss NCUA's priorities for 2024. Economic shifts, rising inflation, and surging delinquencies are testing credit unions' resilience. The podcast examines the impacts of consumer financial struggles, especially among lower-income groups. Key insights reveal the challenges in unsecured lending and the significance of the CECL accounting standard. With a focus on concentration risk, it's clear that adapting risk management strategies is crucial for navigating the evolving financial landscape.

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.Here are some suggested show notes for this podcast episode:Title: So You're a CAMEL Code 3 - Now What?Summary:Mark Treichel, Steve Farrar, and Todd Miller discuss what it means when a credit union receives a CAMEL 3 rating from NCUA and what to expect in terms of increased supervision and requirements. They cover recent trends in CAMEL 3 ratings, how NCUA's oversight changes, and advice for credit unions on responding effectively.Key Points:- Recent trend of more large credit unions moving to CAMEL 3 ratings- NCUA increases supervision for CAMEL 3 credit unions, including:  - Follow-up exams every 6 months   - Documents of Resolution with specific deadlines  - Regional Director letters emphasizing concerns  - Monthly reporting requirements in many cases- Credit unions should expect it to take 14-20+ months before potentially being upgraded back to CAMEL 2- Importance of addressing core issues identified in Documents of Resolution- Boards should implement tracking/reporting on progress resolving issues- Management should provide regular updates to board on addressing concernsGuests:- Steve Farrar - Former NCUA examiner and central office staff member- Todd Miller - Former NCUA examiner and Director of Special ActionsHost: Mark Treichel, Credit Union Exam Solutions

Delve into the evolution of the National Supervision Policy Manual and its impact on credit union examination practices. Discover the shift from the outdated Examiner's Guide and the ongoing frustrations surrounding regulatory transparency. Hear insights on vital chapters, including management and regulatory waivers, and the challenges of accessing crucial information. Former examiners share their personal experiences while unraveling the complexities of navigating the exam processes, emphasizing the importance of preparation and understanding concentration risk thresholds.