Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

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Where to find the entire NCUA report:

https://ncua.gov/files/publications/analysis/quarterly-data-summary-2024-Q1.pdf

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Hello, this is Samantha Shares. This episode covers N C U A Board Member Tanya Oatska’s statement on the agency’s Collection of Overdraft and Non-Sufficient Fund Data

The following is an audio version of that statement.    This podcast is educational and is not legal advice.  We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union  Administration experience.  We assist our clients with N C U A so they save time and money.  If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM.  Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

NCUA Board Member Tanya  Oatska Statement on N C U A’s Collection of Overdraft and Non-Sufficient Fund Data

during a meeting of the NCUA Board.

As Prepared for Delivery on May twenty second, twenty twenty four

The N.C.U.A. has a responsibility to ensure we have a safe and sound system of cooperative credit and a mandate to ensure that credit unions are following all applicable laws. The actions that N C U A has taken over the years with respect to overdraft and fee income is consistent with those responsibilities.

It’s important for the N C U A to understand the data both at the individual institution level and system wide. We also need to make sure that it is transparent for credit unions, credit union members and the public. Overdraft practices and fees should already be disclosed to members and in compliance with applicable laws.

An overreliance on overdraft and NSF fees adversely affects both members and their credit unions. Institutions that rely more on fee income have greater concentration risk.

N C U A’s supervisory priorities have included overdrafts for several years. In 20 18 and 20 19, N C U A examiners reviewed credit union overdraft practices, including opt-in disclosures, and conducted transaction testing to verify that credit unions were complying with the applicable regulatory provisions.

In 20 22, examiners requested information about a credit union’s policies and procedures governing its overdraft programs.

In 20 23, NCUA examiners started conducting reviews of overdraft website advertising, balance calculation methods, and settlement processes for federal credit unions with assets totaling 500 million dollars or more.

I think it is prudent to not prejudge the data or assume a narrative before assessing the data in aggregate. Our very capable staff is currently assessing the newly collected data and I look forward to reviewing it to get a better sense of the bigger picture.

This concludes the statement. 

If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com.  This is Samantha Shares and we Thank you for listening.

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 expertise

With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves 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.

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Hello, this is Samantha Shares. This episode covers N C U A Vice Chairman and Board Member Kyle S. Hauptman statement on the agency’s Collection of Overdraft and Non-Sufficient Fund Data

The following is an audio version of that statement.    This podcast is educational and is not legal advice.  We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union  Administration experience.  We assist our clients with N C U A so they save time and money.  If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM.  Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

N.C.U.A. Vice Chairman Kyle S. Hauptman Statement on Nonsufficient Funds (N.S.F.) Fees

N.C.U.A. Vice Chairman Kyle S. Hauptman during a meeting of the N.C.U.A. Board.

As Prepared for Delivery on May twenty second, 20 24

“No regulation or law passed by government repeals the laws of economics.”

I would like to use this meeting to talk about the N.C.U.A.’s recent decision to require credit unions with 1 billion in assets and over to publicly publish their revenue from overdraft fees and fees for insufficient funds.

No one likes paying those fees. I have paid them myself. But anytime you wake up and owe $X that day but have less than X dollars available, there are only a series of bad options. We are pressuring credit unions to limit what is often the least-bad option for members under financial stress.

I’m also aware that there are policy changes the federal government can make to reduce those sticky financial situations, just by making the existing financial system work better. As much as one-third of all late fees and overdrafts could be eliminated with faster payments that get people their money quicker, which is something Senator Schatz of Hawaii often mentions.

The reason for my comments today is that we have not discussed change in the fifty three hundred Report at a Board Meeting, and yet I can’t go to any event without being asked the same questions: “Why are you doing this to us? Do you realize how harmful it is to members?”

"No one likes paying those fees. I have paid them myself. But anytime you wake up and owe $X that day but have less than X dollars available, there are only a series of bad options."

My answers are, I wish the N.C.U.A. was not doing this – especially on such short notice – and finally yes, I do realize how harmful it is to consumers.

I found out about this burdensome requirement in January. In lieu of repeal, I have suggested several ways to make it less damaging to both credit unions and to the Share Insurance Fund. For example, the same data could be collected in a manner where it’s available to N.C.U.A. examiners and we only publish aggregate data. We could also listen to those pleading for adequate time to prepare, and not publish the data until next year, especially since it’s been harder than expected to figure out what numbers are to be used for each category. All my ideas were rejected. Credit unions will now face reputational risk for data that neither the N.C.U.A. nor the credit union knows to be correct.

So, we are now yet another agency mathematically incentivizing institutions to avoid serving low-income people. This policy is very clear: don’t serve the underserved.

We are now working against the Federal Credit Union Act, which states credit unions are “to create credit…for those of modest means.” Well, it’s not the rich that are going to worry about overdraft protection being removed. It’s not those with secure, high-paying jobs that will suffer from a further reduction in offers for ‘free checking accounts.’ And make no mistake, the N.C.U.A.’s requirement is designed to pressure those fees downward, since one of the main reasons credit unions want more time to comply is to lower these fees and to try to raise revenue in other ways and re-evaluate their business models.

We have seen this movie before. In 2010, the Dodd-Frank Act reduced access to free checking. The bill had a provision on debit cards that contained government price-setting, a provision that mathematically made it less profitable to serve low-income people. The outcome was as painful as it was predictable: ‘free checking’ fell away significantly as new requirements kicked in for direct-deposits, higher minimum balances, etc. Anyone who can’t meet those requirements has to pay monthly account fees or lose access to the banking system.

Doesn’t it seem odd for someone to support the regulations that make it infeasible to serve low-income people, and then talk about ‘financial inclusion’ and lament the millions of Americans who are unbanked? It reminds me of the story about the guy who killed his own parents and then asked for leniency because he’s an orphan.

"That’s the real-world reality people live in every day."

Can we guarantee the SIF is better off because of this? Nope. And yet we are adding regulatory burden.

But two beneficiaries of this misguided interference are two interest groups: 1) those who benefit politically, and 2) members of the media, who get to write click-bait articles that are often devoid of financial or business literacy. We have already seen this happen.

It goes without saying that none of the people supportive of these policies will be there with their own money to you offer a better deal when you’re a few bucks short and desperately want to avoid a 500 dollar late fee.

That’s what will eventually happen. Overdraft protection, in particular, will become less common. Overdraft is when a credit union pays part of your bills for you when your account doesn’t have enough. Anyone at a banking institution will tell you the most distraught customers are not those whose bills were paid via overdraft, much as they may not like the 30 dollar fee. Nope, the distraught customers are those customers upset that a bill wasn’t paid due to insufficient funds, forcing them to pay much higher costs.

Anyone would rather pay 30 dollar than a 500 dollar late government fee. What about someone in my position, a few years ago, who owed four thousand dollar to my state government, and was forced to pay one thousand dollars extra for being one day late. If my account was a few bucks short of four thousand dollars, would I rather pay a 30 dollar overdraft fee or the extra 1,000 dollars to the government?

Years ago, I was trying to live in an expensive city on 27,000 dollars a year salary while paying student loans. I went to go to work and saw that my car was gone and called the police. Turns out it was towed for late registration. Back then, I was constantly juggling payments trying to avoid the highest costs of being broke. The highest costs were, and are, invariably charged by the same governments that lecture the private sector. Governments charge fees and use coercive tactics that are significantly worse than anything labeled a ‘junk fee.’ And yet, we rarely hear about that from self-proclaimed ‘consumer protection’ advocates.

"We can’t pretend that government artificially forcing down the price of something won’t have major negative effects. We also can’t pretend that it makes sense for the N.C.U.A. to make interest rate ri...

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• 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 expertise

With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves 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.

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This episode of Samantha Shares presents an audio version of NCUA Chairman Todd Harper's written testimony before the Senate Banking, Housing, and Urban Affairs Committee. The testimony covers the performance and challenges of the credit union system in 2023, including mixed outcomes due to market competition and rising interest rates, financial stresses, and increases in delinquency rates. Harper discusses the state ofthe National Credit Union Share Insurance Fund, legislative requests for enhancing NCUA's authority, efforts to improve cybersecurity, consumer financial protection, support for minority depository institutions, and initiatives for diversity, equity, inclusion, and accessibility within the credit union system. Sponsored by Credit Union Exam Solutions Incorporated, the episode also mentions ways Credit Union Exam Solutions assists clients with NCUA examinations and highlights the importance of managing liquidity risk, cybersecurity threats, and ensuring adherence to consumer protection laws.

00:00 Introduction to NCUA Chairman's Testimony
00:18 Sponsorship and Additional Resources
00:47 Overview of NCUA's Work and Credit Union System State
03:03 Credit Union System Performance Analysis
05:22 External Factors and AI in the Credit Union System
07:57 Share Insurance Fund Performance Insights
09:26 Central Liquidity Facility's Role and Performance
12:29 NCUA's Initiatives for System Protection and Enhancement
12:56 Cybersecurity Enhancements and Consumer Financial Protection
19:41 Support for Minority Depository Institutions and DEIA Efforts
27:59 Rulemaking Activities and Legislative Requests
37:28 Conclusion and Contact Information

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• Insider knowledge of NCUA procedures and expectations

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Hello, this is Samantha Shares. This episode covers N C U A’s Board Member Tanya Oatska’s Remarks at Treasury’s Roundtable for Providing Financial Access to Justice-Impacted Individuals

The following is an audio version of those remarks.    This podcast is educational and is not legal advice.  We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union  Administration experience.  We assist our clients with N C U A so they save time and money.  If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM.  Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

Before the remarks you may wonder what the definition of a Justice-impacted individuals is.

Justice impacted individuals include those who have been incarcerated or detained in a prison, immigration detention center, local jail, juvenile detention center, or any other carceral setting, those who have been convicted but not incarcerated, those who have been charged but not convicted, and those who have been arrested. 

And now the remarks.

As Prepared for Delivery on April 24, twenty twenty four

Good afternoon and thank you to Deputy Secretary Adeyemo and everyone at Treasury for convening this critical and timely discussion.

The credit union system is an important and unique part of our financial system because it is centered around a cooperative business model that is driven not by a profit motive or shareholder interests, but by the needs of credit union members. Many credit unions were created to serve communities that the traditional financial system has long forgotten. So, it is fitting that the NCUA and credit unions are at the table when it comes to providing financial access to justice-impacted individuals and marginalized communities.

One of the challenges justice-impacted individuals face when looking to open a bank account is the lack of a driver’s license or other IDs typically preferred or required by banks. The NCUA previously issued an opinion indicating that it is acceptable to use an individual taxpayer identification number (ITIN) to open an account, and credit unions have led in this space.

For example, Stepping Stones Community Federal Credit Union, which is here today, serves justice-impacted individuals at three local prisons in Delaware by partnering with the Delaware Department of Corrections. They use ITINs to open accounts for members and work with the business office at the prison to gain identification information to establish the account. The prison provides documents certifying the authenticity of the members and names. As of November 2023, the program had 482 active accounts totaling more than $300,000.

Several credit unions in New York City, including the Lower East Side People’s Federal Credit Union, Neighborhood Trust Federal Credit Union, Urban Upbound, and USAlliance currently accept IDNYC, a municipal ID card that New York City started issuing in 2014. It is available to all residents of New York City, including people from some of the most vulnerable communities, such as those who are unhoused, justice-impacted individuals, immigrants, and others who may have difficulty obtaining a government-issued photo ID.

Lastly, the NCUA recently updated its policy on preserving minority depository institutions (MDIs) -- a main priority for me. As a regulator whose focus is to ensure fair, safe, and accessible banking services to credit union members, the NCUA is committed to preserving minority depository institutions, providing technical assistance and support, and encouraging new ones to form.

M D I’s have a long history of bridging the gap to underserved communities. Many of the credit unions doing the work of helping justice-impacted individuals are M D I’s. Indeed, four out of the five credit unions I mentioned today are designated MDIs.

I am encouraged by the steps the agency and credit unions have taken to address the financial gap justice-impacted individuals face. However, we know that more needs to be done, and I look forward to hearing from you all on how we can continue to expand access and economic empowerment to more people and communities. Thank you.

This concludes the remarks. 

If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com.  This is Samantha Shares and we Thank you for listening.

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.

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• 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 expertise

With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves 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.

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Hello, this is Samantha Shares. This episode covers America’s Credit Union’s  Letter to the National Credit Union Administration’s Board on Permitting Childcare Expenses as Reimbursable 

The following is an audio version of that letter and the press release.    This podcast is educational and is not legal advice.  We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union  Administration experience.  We assist our clients with N C U A so they save time and money.  If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM.  Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

And now the letter.

RE: Permitting Childcare Expenses as Reimbursable Under 12 CFR 701 point 33

Dear Chairman Harper, Vice Chairman Hauptman, and Board Member Oatska:

On behalf of America’s Credit Unions, I am writing to request the National Credit Union Administration (the agency) explicitly permit reimbursement of childcare related costs incurred by a federal credit union (F C U) board member. While the term “childcare” is used throughout this letter, our ask is that child and other non-child dependent care expenses be reimbursable America’s Credit Unions is the voice of consumers’ best option for financial services: credit unions. We advocate for policies that allow the industry to effectively meet the needs of their nearly on hundred forty million members nationwide.

Credit unions stand out from banks in a variety of ways, including our emphasis on diversity, equity, and inclusion. This is, in part, evident in the prevalence of and increasing percentage of women, not only in senior level positions, but also at the board level. Based on data from the THE AGENCY and analyzed by America’s Credit Unions, the percentage of women board members has increased by roughly five percentage points among all asset ranges since at least twenty twelve.

This is a testament to the work of our industry to achieve greater gender equity in leadership.

Further, we are proud to have a regulator in the THE AGENCY that similarly emphasizes the importance of equality in the credit union industry. We applaud the focus of the THE AGENCY Board, as well as staff, including those in the agency’s Office of Minority and Women Inclusion. We appreciate the Board’s recent willingness to pursue actionable items to address ongoing challenges among credit unions, such as those related to the agency’s records preservation program. Our request below is another great opportunity for the Board to take action to achieve a sensical change to the agency’s regulations.

We ask the THE AGENCY to update its existing regulation pertaining to reimbursement of F C U officials. Specifically, we ask the Board to amend section 701 point 33 to allow F C U board members to be reimbursed for the cost of childcare when it is necessary in order to attend an official board meeting of the F C U. Family structures and childcare responsibilities are significantly different now than when this provision was last amended. To attract new talent, people with young children should be afforded the opportunity to more easily participate on a credit union board with appropriate reimbursement for their childcare expenses.

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The Federal Credit Union Act (F C U Act) provides sufficient latitude for the Board to pursue such an amendment. While section 1761(c) of the Act generally limits compensation to a single board member, it explicitly states that “the reimbursement of reasonable expenses incurred in the execution of the duties of the position shall not be considered compensation.”3 This provision of the Act is implemented by section 701 point 33(b) of the agency’s regulations, which, consistent with the Act, states that compensation specifically excludes:

Payment (by reimbursement to an official . . . ) for reasonable and proper costs incurred by an official in carrying out the responsibilities of the position to which that person has been elected or appointed, if the payment is determined by the board of directors to be necessary or appropriate in order to carry out the official business of the credit union, and is in accordance with written policies and procedures, including documentation requirements, established by the board of directors. Such payments may include the payment of travel costs for officials and one guest per official[.]4

In particular, we ask the Board to update the existing limitation in section 701 point 33(b)(2)(i). This could be achieved by simply inserting “childcare” into the last sentence of section 701 point 33(b)(2)(i) as follows: “Such payments may include the payment of childcare or travel costs for officials and one guest per official[.]”

The AGENCY last updated the provision regarding the definition of “compensation” over twenty-two years ago. In that update, the agency used its expansive statutory authority to add the travel expenses of a guest as reimbursable under section 701 point 33(b). Previously, reimbursement was limited to the travel expenses of the board member’s “immediate family member.” In so doing, the Board stated its belief that amending this provision would “allow F C Us greater flexibility to accommodate the needs of officials whose duties include business-related travel.” While we are fortunate to now live in a world where virtual meetings are ubiquitous, there continue to be instances where in-person meetings are necessary, including in the context of certain F C U board meetings. Such meetings cause attendees to incur not only direct travel-related expenses, such as fuel, but also indirect expenses, such as costs associated with securing childcare for a board member’s family.

Section 701 point 33(b)(2)(i) offers just a single example of what might be considered a reasonable and proper reimbursable cost. The example is clearly not intended as an exhaustive list of permissible expenses, given the regulation’s use of “may.” We believe the cost associated with childcare is more similar to travel than other expenses the agency has indicated are not reimbursable under this section. Assuming a virtual meeting is not an option, the only way for a board member to attend a meeting is to physically travel to the meeting location. The only option for a board member to attend a board meeting is to ensure his or her child or dependent has proper care, which in many situations, absent the presence of another family member or trusted

caregiver, requires utili...

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https://ncua.gov/files/press-releases-news/incentive-based-compensation-arrangements.pdf

Above is the link to the 200 page proposed rule on banker's incentive compensation.

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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.

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• 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 expertise

With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves 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.

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America's Credit Unions Appeal Against Disclosure of Fee Data

This episode of Samantha Shares presents an audio version of a letter from Carrie Hunt, Chief Advocacy Officer for America's Credit Unions, to the National Credit Union Administration (NCUA) Board of Directors, dated April 19, 2024. The letter requests the NCUA not to publicly disclose overdraft and non-sufficient funds (NSF) fee data collected in the latest Call Report. America's Credit Unions argue that disclosing this information could harm credit unions' reputations and should be considered confidential business information under FOIA exemptions. The organization had already expressed concerns about the process of including such data in the Call Report without sufficient notice to credit unions. The letter underscores the potential reputational risks and misleading interpretations if the fee data is made public. It urges the NCUA Board to either prevent the disclosure of the fee data or delay it until the legal and policy implications are fully assessed.

00:00 Introduction to the Episode
00:26 Sponsorship and Additional Resources
00:55 The Letter to the NCUA Board
01:08 Urging Nondisclosure of Fee Data
03:33 Concerns Over Public Disclosure
04:43 Conclusion of the Letter and Final Thoughts

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• Insider knowledge of NCUA procedures and expectations

• Strategies to address potential issues before they become problems

• Continuous access to our extensive subject matter expertise

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Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

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This episode of Samantha Shares focuses on the NCUA's Advanced Notice of Proposed Rulemaking regarding updates to its Records Preservation Program regulations and Catastrophic Act Preparedness Guidelines, aiming to solicit comments for improvement. It highlights the need for feedback on the outdated Part 749 regulations, detailing the current standards for records preservation among credit unions and the request for comment on vital records definitions, retention practices, and additional guidance to ensure effective recordkeeping and disaster preparedness. The NCUA seeks to modernize and clarify these regulations to aid credit unions in maintaining crucial records for business continuity and member service. The podcast is sponsored by Credit Union Exam Solutions Incorporated, offering expertise in NCUA examination preparation.

00:00 Welcome and Introduction
00:02 Overview of the ANPR and Sponsorship
00:54 Deep Dive into the ANPR
06:28 Request for Comments and Feedback
12:58 Conclusion and Contact Information

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• 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 expertise

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Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.