NCUA Exams: Insights and Trends with Todd Miller & Steve Farrar
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Key Points:
1. Recent NCUA exam focus areas:
- Interest rate risk and liquidity risk (2022-2023)
- Board governance
- Commercial lending programs
- Loan concentrations
- Consumer compliance, especially for third-party relationships
2. Board governance issues:
- Increased expectations for board oversight and accountability
- Focus on risk appetite and concentration risk limits
- Need for analytical support and modeling for risk limits
3. Communication challenges:
- Frustrations with examiner communication and expectations
- Importance of documenting discussions and agreements with examiners
4. Enterprise Risk Management:
- Growing expectations for ERM programs, even for credit unions under $10 billion
- FDIC guidance on corporate governance as a useful resource
5. Stress testing requirements:
- Increasing expectations for analytical support of policy limits
- Can be costly and resource-intensive for credit unions
6. Information security:
- Ongoing area of focus, likely to increase given recent high-profile incidents
- May lead to more formal exam findings (DORs) on cybersecurity issues
7. Third-party vendor management:
- Renewed emphasis on oversight of third-party relationships
- Recent incidents may fuel push for NCUA third-party vendor authority
8. Looking ahead:
- Potential for increased NCUA staffing and resources for consumer compliance
- Importance of credit union communication plans for crisis situations
Guests: Todd Miller and Steve Farrar, former NCUA executives and current credit union consultants
Host: Mark Treichel
The podcast provides insights into current NCUA examination trends and offers advice for credit unions on navigating regulatory expectations.
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