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

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 The NCUA Board, referred to as the Board, is issuing this proposed rule to streamline its regulations governing advertising and the notice of insured status. This proposed rule would eliminate provisions concerning the official advertising statement. This action is undertaken to reduce regulatory complexity, and the intended effect is to reduce the administrative burden and costs for federally insured credit unions, referred to as FICU s, and provide them with greater flexibility in their advertising activities. The proposed rule would not amend requirements related to displaying the official sign. 

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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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 The NCUA Board seeks comment on a proposed rule to remove the regulations related to approval and policies on making loans to other credit unions. While this provision would no longer be codified in regulation, Federal Credit Unions would remain subject to statutory requirements related to making loans to credit unions. Federally insured state-chartered credit unions would remain subject to any other applicable NCUA or state law or regulation. 

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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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 The N C U A Board is publishing this proposed rule to amend the requirements for federally insured credit unions to report catastrophic acts to the agency. By providing more time for federally insured credit unions to notify the agency of the occurrence of a catastrophic act and by eliminating the specific list of items to be documented, the Board expects the proposed rule to reduce the compliance burden and allow federally insured credit unions to focus their resources on recovery and core functions without compromising safety and soundness. 

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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Episode Title

Credit Card Risk, Consumer Stress, and the 18 Percent Reality

Episode Description

In this episode, Samantha Shares reviews key findings from the Consumer Financial Protection Bureau’s latest Consumer Credit Card Market Report and explains what they mean for credit unions.

The discussion focuses on how credit card usage has evolved since the pandemic, where growth is occurring, and why consumer stress signals remain elevated even as delinquency rates normalize. Samantha also explains how credit unions manage credit card risk differently from large banks, particularly given the statutory 18 percent loan-rate cap.

This episode is designed to provide practical context for credit union leaders, board members, and exam preparation conversations.

Key Topics Covered

• How large the credit card market has become and how embedded cards are in daily life
• Why recent credit card spending growth is concentrated among higher-credit-score borrowers
• What rising balances and minimum-payment behavior signal about consumer stress
• Why normalization in delinquency rates does not necessarily mean household finances are healthy
• How credit cards are increasingly used for essential expenses rather than discretionary spending
• Why smaller issuers hold a larger share of higher-risk credit card balances
• How credit unions manage credit card risk under the 18 percent loan-rate cap
• The growing importance of underwriting discipline, credit limits, monitoring, and servicing controls
• Operational risk trends, including disputes tied to recurring transactions
• How innovation, artificial intelligence, and alternative payment methods may shape future card usage

Why This Episode Matters

Credit unions operate in a high-rate environment with uneven consumer stress while serving a membership base that often includes higher-risk borrowers. Understanding how credit card risk is distributed across the market—and how credit unions manage that risk structurally rather than through pricing—is essential for strategy, governance, and exam readiness.

Sponsor Message

This podcast is sponsored by Credit Union Exam Solutions Incorporated. Their team has over two hundred and forty years of National Credit Union Administration experience and helps credit unions prepare for and navigate NCUA examinations.

Learn more at MarkTreichel.com.

Related Content

• With Flying Colors podcast
• Credit Union Regulatory Guidance podcast
• Articles and resources at 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.

www.marktreichel.com

https://www.linkedin.com/in/mark-treichel/

Changes for Guidelines for Safeguarding Member Information – 12 CFR 748 Appendix A

• NCUA is proposing to remove Appendix A to part 748, guidelines for safeguarding member information, from the Code of Federal Regulations.

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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Show Notes
In this episode of Samantha Shares, we present an audio version of the Semiannual Risk Perspective from the National Risk Committee, Fall 2025, issued by the Office of the Comptroller of the Currency.

This report provides a comprehensive overview of conditions in the federal banking system, including balance sheet strength, capital and liquidity levels, earnings performance, and emerging risks. The document discusses trends in credit quality across major loan categories, underwriting standards, commercial real estate conditions, and market and liquidity risk. It also highlights key operational and compliance considerations, including cybersecurity threats, fraud risk, and the evolving regulatory environment.

The report examines the role of financial innovation, including artificial intelligence and payment system developments, and outlines how banks are balancing innovation opportunities with governance and risk management expectations. It concludes with an assessment of the economic environment and bank performance, including interest rate trends, profitability, and resilience under potential stress.

This episode is a near-verbatim spoken reading of the source document. It is provided for educational purposes only and is not legal advice.

Sponsor
This episode is sponsored by Credit Union Exam Solutions Incorporated. Our team has over two hundred and forty years of National Credit Union Administration experience and assists credit unions with NCUA examinations so they can save time and money. Learn more at Mark Treichel dot com.

Related Podcast
Be sure to also check out our companion podcast, With Flying Colors, where we share practical insights and strategies to help credit unions achieve success with NCUA.

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.

www.marktreichel.com

https://www.linkedin.com/in/mark-treichel/

Changes for Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice – 12 CFR 748 Appendix B

• NCUA is proposing to remove Appendix B to part 748, guidance on response programs for unauthorized access to member information and member notice, from the Code of Federal Regulations.

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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https://www.linkedin.com/in/mark-treichel/

"Most banks maintained relatively consistent reliance on Federal Home Loan Bank advances — including during periods of financial stress."
— Government Accountability Office

The GAO just dropped a detailed report examining the Federal Home Loan Bank system during COVID-19 and the March 2023 banking stress.

Here's what they actually found (without the noise):

What the data shows:
• FHLBank advances functioned as a stabilizing liquidity tool — not a risk amplifier
• Especially true for institutions under $10 billion in assets
• Consistent usage patterns even during stress periods
• No evidence of panic borrowing or destabilizing effects

Why it matters: While everyone was wringing their hands about liquidity risk, most community institutions used FHLBanks exactly as designed — as a reliable backstop when deposits got shaky.

The real takeaway: For smaller institutions, FHLBank membership provided stability when they needed it most. Not a crutch. Not a risk factor. Just a tool that worked.

I've posted a ~9-minute audio summary walking through what the GAO actually found.

🎧 Listen at MarkTreichel.com or on your favorite podcast app (Samantha Shares).

Translation: FHLBanks did their job. The system worked as intended.

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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https://www.linkedin.com/in/mark-treichel/

Changes for Supervisory Committee Audits and Verifications – 12 CFR 715

• NCUA is proposing to amend its regulations governing supervisory committee audits to eliminate unnecessary, redundant, and overly prescriptive provisions.

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 Announces Deregulation Project and First Round of Proposed Regulatory Changes

Stakeholders Are Encouraged to Review Notice of Proposed Rulemaking and Submit Comments

ALEXANDRIA, VA (December 10, 2025) – The National Credit Union Administration today announced the first round of proposed regulatory changes associated with a new initiative to review and potentially revise the agency’s regulations. This initiative, NCUA’s Deregulation Project, follows
This is an external link to a website belonging to another federal agency, private organization, or commercial entity.Executive Order 14192, Unleashing Prosperity Through Deregulation
(Opens new window).

NCUA’s Deregulation Project will involve a comprehensive review of regulations documented in Title 12, Chapter VII of the Code of Federal Regulations. This review will ensure the regulations are focused on the safety, soundness, or resilience of credit unions. Further, NCUA will propose changing or removing regulations that are:

• Obsolete;
• Duplicative of statutory requirements;
• Intended to serve as guidance, not requirements; or
• Overly burdensome.

In addition to announcing the project, NCUA is requesting comments on four proposals that would clarify agency guidance or eliminate unduly burdensome or obsolete requirements in
This is an external link to a website belonging to another federal agency, private organization, or commercial entity.the Federal Register
(Opens new window).

The four proposals include:

• 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.
  • For more information on this proposal, please see:
    This is an external link to a website belonging to another federal agency, private organization, or commercial entity.https://www.federalregister.gov/public-inspection/2025-22487/corporate-credit-unions
    (Opens new window)
• Changes for Supervisory Committee Audits and Verifications – 12 CFR 715
  • NCUA is proposing to amend its regulations governing supervisory committee audits to eliminate unnecessary, redundant, and overly prescriptive provisions.
  • For more information on this proposal, please see:
    This is an external link to a website belonging to another federal agency, private organization, or commercial entity.https://www.federalregister.gov/public-inspection/2025-22488/supervisory-committee-audits-and-verifications
    (Opens new window)
• Changes for Guidelines for Safeguarding Member Information – 12 CFR 748 Appendix A
  • NCUA is proposing to remove Appendix A to part 748, guidelines for safeguarding member information, from the Code of Federal Regulations.
  • For more information on this proposal, please see:
    This is an external link to a website belonging to another federal agency, private organization, or commercial entity.https://www.federalregister.gov/public-inspection/2025-22489/guidelines-for-safeguarding-member-information
    (Opens new window)
• Changes for Guidance on Response Programs for Unauthorized Access to Member Information and Member Notice – 12 CFR 748 Appendix B
  • NCUA is proposing to remove Appendix B to part 748, guidance on response programs for unauthorized access to member information and member notice, from the Code of Federal Regulations.
  • For more information on this proposal, please see:
    This is an external link to a website belonging to another federal agency, private organization, or commercial entity.https://www.federalregister.gov/public-inspection/2025-22490/guidance-response-programs-for-unauthorized-access-to-member-information-and-member-notice
    (Opens new window)

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.