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

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NCUA is proposing to streamline its rule on the purchase, sale, and pledge of eligible obligations (12 CFR 701.23).

What NCUA is proposing:

• Remove the prescriptive lists of items that FCUs must address in their written purchase, sale, and pledge policies
• Remove the detailed code of conduct in paragraph (g) governing conflicts of interest and compensation tied to these transactions
• Make a conforming redesignation (current 701.23(h) becomes 701.23(g)) and update the cross-reference in the appeals rule at 12 CFR 746.201(c)
• Comments are due April 27, 2026

Why NCUA is making the change:

• The current one-size-fits-all framework is viewed as unduly burdensome, especially for smaller FCUs
• The FCU Act requires NCUA to issue rules in this area but does not require a detailed framework for internal credit union policies
• An FCU's board is in the best position to scale policies to its own activities and risk profile
• The existing compensation prohibition, with a narrow list of exceptions, is seen as inflexible and may hinder legitimate incentive structures
• FCUs are already governed by broader conflict of interest provisions in their bylaws and by the fiduciary duties of their officials
• The change aligns with a more principles-based supervisory approach

What is NOT changing:

• FCUs must still maintain written policies covering purchase, sale, and pledge of eligible obligations
• Board approval remains required, and transactions must be conducted at arm's length and in the best interest of the credit union
• The underlying statutory authority under section 107(13) of the FCU Act is unchanged
• Examiner oversight of these activities continues
• The rule applies only to FCUs — the basic framework for FISCUs is unaffected

10,000-foot takeaway: NCUA is shifting from prescriptive checklists to principles-based expectations for eligible obligation policies. FCUs get more flexibility to tailor their written policies and incentive structures, but they also keep full responsibility for safe and sound operations. Boards should start thinking now about how their existing policies would hold up under a principles-based exam — the guardrails are coming out, but the accountability is not.

If your credit union would like help preparing for an NCUA exam, visit MarkTreichel.com.

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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NCUA's 2025 Annual Report audio book style

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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NCUA request for feedback on data collections.

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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NCUA just released its 2026 Annual Performance Plan, and it offers a clear look at where the agency is focusing its resources this year. Here are the highlights:

What NCUA is announcing:

• 17 annual performance goals supported by 23 performance indicators, all aligned to the new 2026-2030 Strategic Plan
• A commitment to issue at least 30 regulatory actions or policy revisions that reduce regulatory or administrative burden on credit unions
• Plans to eliminate unnecessary or unduly burdensome examination scope steps
• Final regulations on permissible stablecoin activities for all federally insured credit unions
• Deployment of the Analytics 2.0 Phase I upgrade to the MERIT examination system by Q1 2026
• Key milestones in NCUA's AI roadmap, including a large language model pilot, an AI Steering Committee, and a refined AI strategy
• At least three joint NCUA-State Supervisory Authority engagements to strengthen the dual chartering system

Why the change is occurring:

• NCUA is reorganizing to focus on core statutory functions, eliminate duplication, and reduce non-essential activities
• The agency wants to reallocate resources toward material risks while reducing lower-priority work for both examiners and credit unions
• Rapid changes in technology, digital assets, and payment systems require updated regulations and guidance
• Stronger data, analytics, and AI capabilities are needed to keep pace with an increasingly complex credit union system

What is NOT changing:

• NCUA's core mission to safeguard federally insured credit unions and protect the Share Insurance Fund
• The statutory requirement to maintain the Share Insurance Fund equity ratio at or above 1.2 percent
• Timely follow-up examinations for troubled credit unions - target is at least 97 percent initiated within established timeframes for CAMELS 4/5 credit unions and CAMELS 3 credit unions over $250 million
• Commitment to an unmodified ("clean") opinion on financial statement audits and a FISMA maturity rating of at least Level 4
• Ongoing support for low-income credit unions through Congressionally appropriated grants

The 10,000-foot takeaway: NCUA is signaling a leaner, more risk-focused agency in 2026. Expect meaningful burden reduction, a final stablecoin rule, smarter use of data and AI in examinations, and continued organizational realignment - all while maintaining the financial resilience of the Share Insurance Fund. Credit unions should watch closely for the 30-plus regulatory and policy revisions coming this year, as many will directly affect exam scope, compliance expectations, and innovation opportunities.

If your credit union wants help preparing for an NCUA exam, visit MarkTreichel.com.

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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NCUA just released its 2026-2030 Strategic Plan, laying out the agency's priorities for the next five years. Here's what credit union leaders should know.

What NCUA is announcing:

• Three strategic goals: safeguarding federally insured credit unions, enabling access to cooperative financial services and responsible innovation, and strengthening the agency's own capabilities and performance
• A comprehensive review of the regulatory framework to remove rules that are outdated, duplicative, or unnecessarily burdensome
• Expanded use of data, analytics, and AI tools in examination and supervision
• A push to foster responsible adoption of financial technology, digital assets, and blockchain-based innovation
• Streamlined chartering, field of membership, and expansion processes
• Internal restructuring focused on core statutory functions, merit-based hiring, and reduced duplication

Why the change is occurring:

• Feedback from NCUA's first-ever Strategic Planning Town Hall in September 2025 with credit unions, leagues, trade associations, and CUSOs
• A financial services environment evolving rapidly with AI, digital assets, and shifting member expectations
• Presidential executive orders and laws like the GENIUS Act driving new regulatory responsibilities
• A recognition that disciplined, risk-focused supervision serves both safety and soundness and member access

What is NOT changing:

• NCUA's core mission: enabling access to financial services by facilitating safe, sound, and resilient credit unions
• Statutory responsibility to protect the Share Insurance Fund and credit union members
• Risk-focused examination framework (it's being refined, not replaced)
• Coordination with FFIEC, FSOC, and state regulators
• Agency values: results, integrity, teamwork, and accountability

10,000-foot takeaway: NCUA is signaling a lighter, more targeted regulatory touch paired with a modernized, tech-enabled supervisory approach. Expect continued focus on material risks, fewer administrative burdens, and more room for credit unions to innovate responsibly, while the Share Insurance Fund and safety-and-soundness remain non-negotiable.

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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NCUA Proposes to Loosen Associational Common Bond Rules

The NCUA Board has issued a proposed rule that would amend the associational common bond provisions of its Chartering and Field of Membership Manual. Comments are due by June 8, 2026.

What NCUA is proposing:

• Eliminate the automatic bar that currently disqualifies an associational group from FCU field of membership eligibility when the group requires purchasing a product or service as a condition of membership.
• Replace the bright-line rule with a totality of the circumstances review, looking at the group's structure, scope, degree of activities, and other operational factors.
• Clarify that a client-customer relationship can exist, even as a condition of membership, as long as it remains incidental to the group's overall purpose and activities.
• Use an example of a fraternal association that requires insurance purchase - under the proposal, this would no longer be automatically disqualifying.

Why the change:

• The Board believes the automatic bar goes beyond what the FCU Act actually requires.
• Neither the FCU Act nor the Credit Union Membership Access Act of 1998 (CUMAA) specifies that a client-customer relationship is automatically disqualifying.
• The change is intended to enhance consumer access to financial services and eliminate an inflexible restriction, consistent with Executive Order 13563 and deregulatory goals under Executive Order 14192.
• Moves NCUA toward a principles-based approach rather than a rigid rule.

What is NOT changing:

• Associations based primarily on a client-customer relationship still do not qualify.
• Health clubs, including YMCAs, remain examples of groups that do not meet the associational common bond requirements.
• Retail loyalty clubs still would not qualify, since their core reason for existence is the client-customer relationship.
• The rule does not affect occupational common bond charters, community charters, or federally insured state-chartered credit unions.
• The core associational common bond definition - members of a recognized association who participate in activities developing common loyalties, mutual benefits, and mutual interests - remains intact.
• Pre-approved categories of groups under the 2015 automatic qualification amendments are unaffected.

10,000-foot takeaway: NCUA is moving from a rigid "if you require a purchase, you're out" standard to a more flexible "look at the whole picture" standard. Associational groups that previously couldn't qualify because membership required buying a product or service may now have a path forward - but only if the client-customer piece is genuinely incidental to why the group exists. If selling something is the core reason the group was formed, the group still doesn't qualify. For FCUs looking to expand their field of membership through associational groups, this proposal could open doors that have been closed for decades.

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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The NCUA just released its 2026 Supervisory Priorities (Letter 26-CU-01), giving credit unions a heads-up on where examiners will be focusing this year.

Here's what you need to know:

• The NCUA is doubling down on balance sheet management, with particular attention to lending, interest rate risk, liquidity, earnings, and capital adequacy. Loan delinquency and loss rates are at their highest in over a decade, and examiners will be looking closely at underwriting, loss mitigation, ACL reserves, and charge-off practices.
• Operational risk is a major theme. Payment systems, fraud prevention, and cybersecurity will all get heightened scrutiny as the payments landscape grows more complex and fraud risks continue to rise.
• BSA/AML compliance remains a priority, with an emphasis on risk-based programs tailored to each credit union's profile. Expect regulatory changes throughout the year as FinCEN and the NCUA continue implementing provisions of the Anti-Money Laundering Act of 2020.
• The agency is also signaling a shift toward a more efficient and tailored examination program, building on its 2025 efforts to reduce burden for both credit unions and NCUA staff. Defined scope exams will continue for most federal credit unions with $50 million or less in assets.

What is NOT changing: The NCUA will continue enforcing all existing laws and regulations, including consumer financial protection and information security requirements. Risk-focused procedures remain the standard for larger credit unions.

The 10,000-foot takeaway: Asset quality and earnings pressure are the story of 2026. Credit unions that can demonstrate strong risk management practices across lending, liquidity, and capital planning will be well positioned. Now is the time to review your ACL methodologies, stress testing, contingency funding plans, and BSA programs before examiners come knocking.

One more thing worth noting: the NCUA reminds credit unions they may record their final exit meeting or joint conference for documentation and training purposes.

If your credit union could use help preparing, visit MarkTreichel.com or reach out to Mark Treichel on LinkedIn.

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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Changes for Corporate Credit Unions – 12 CFR 704.8 and 704.15

• NCUA is proposing to amend its regulations for corporate credit unions by removing the requirement that a corporate credit union’s asset and liability management committee (ALCO) must have at least one member who is also a member of the corporate credit union’s board of directors.

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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 the Board, seeks comment on a proposed rule to remove the segregated deposit and collateral requirements when a federally insured credit union, referred to as a F I C U, acts as a surety and guarantor. Removing this regulation will provide F I C U s with greater flexibility to design products that meet member needs. F I C U s would remain subject to the other requirements regarding surety and guaranty agreements. 

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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NCUA's 2026 Priority Letter to Credit Unions is out!

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.