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

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Changes for Corporate Credit Unions – 12 CFR 704.8 and 704.15NCUA 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/ 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/ 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.  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 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.comhttps://www.linkedin.com/in/mark-treichel/ 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.  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 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.comhttps://www.linkedin.com/in/mark-treichel/ 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/Episode TitleCredit Card Risk, Consumer Stress, and the 18 Percent RealityEpisode DescriptionIn 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 CoveredHow large the credit card market has become and how embedded cards are in daily lifeWhy recent credit card spending growth is concentrated among higher-credit-score borrowersWhat rising balances and minimum-payment behavior signal about consumer stressWhy normalization in delinquency rates does not necessarily mean household finances are healthyHow credit cards are increasingly used for essential expenses rather than discretionary spendingWhy smaller issuers hold a larger share of higher-risk credit card balancesHow credit unions manage credit card risk under the 18 percent loan-rate capThe growing importance of underwriting discipline, credit limits, monitoring, and servicing controlsOperational risk trends, including disputes tied to recurring transactionsHow innovation, artificial intelligence, and alternative payment methods may shape future card usageWhy This Episode MattersCredit 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 MessageThis 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 ContentWith Flying Colors podcastCredit Union Regulatory Guidance podcastArticles 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/Changes for Guidelines for Safeguarding Member Information – 12 CFR 748 Appendix ANCUA 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/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 expertiseWith 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.comhttps://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 BNCUA 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 expertiseWith 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.comhttps://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 OfficeThe 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 effectsWhy 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/Changes for Supervisory Committee Audits and Verifications – 12 CFR 715NCUA 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/NCUA Announces Deregulation Project and First Round of Proposed Regulatory ChangesStakeholders Are Encouraged to Review Notice of Proposed Rulemaking and Submit CommentsALEXANDRIA, 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; orOverly 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 704.15NCUA 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 715NCUA 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 ANCUA 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 BNCUA 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/n this episode of Samantha Shares, we present the verbatim text of the N C U A’s proposed rule on  Elimination of Reputation Risk.The document covers:A Summary of the proposed rule to eliminate reputation risk from N C U A’s supervisory framework.Background and Policy Objectives — why reputation risk is subjective, inconsistent, and prone to examiner bias.Legal Authority — the Federal Credit Union Act provisions that give N C U A power to regulate.Description of the Proposed Rule and Changes — prohibiting examiners from citing, criticizing, or taking action against credit unions for reputation risk, including political, cultural, or religious reasons.Expected Effects — how this will affect all 4,370 federally insured credit unions, their members, and business partners.Regulatory Procedures — transparency, cost analysis, and references to Executive Orders and statutory requirements.The proposal directly addresses concerns that reputation risk was being misused in examinations, particularly around politically sensitive or lawful but disfavored activities.This audiobook-style episode presents the full Federal Register text as released, unedited and verbatim, for educational purposes. 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 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.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers the Fair Credit Reporting Act; Preemption of State Laws. The following is an audio version of that document. 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 Fair Credit Reporting Act; Preemption of State Laws.The Consumer Financial Protection Bureau is issuing this interpretive rule to clarify that the Fair Credit Reporting Act broadly preempts state laws that attempt to regulate credit reporting. This action reflects Congress’s original intent to create national standards for the credit reporting system. This interpretive rule replaces an earlier Bureau rule from July twenty twenty-two, which had taken a narrower view of preemption. That rule was withdrawn in May twenty twenty-five.The Fair Credit Reporting Act, or F C R A, was enacted in nineteen seventy and has been amended several times since. It established a national system for credit reporting and set rules for consumer reports and the use of consumer information. From the beginning, the law preempted state laws that were inconsistent with its provisions. In nineteen ninety-six, Congress strengthened this preemption by adding a new clause that barred states from regulating in certain specifically identified areas. This was meant to avoid a patchwork of conflicting rules. Originally, this stronger preemption was set to expire in two thousand four, but in two thousand three, Congress made it permanent. The intent was clear: to preserve uniform national standards and support the growth of the national credit reporting system.In July twenty twenty-two, the Bureau published an interpretive rule suggesting that section sixteen eighty-one tee, subsection b, paragraph one, had only a narrow sweep. It concluded that many state laws affecting consumer reports could stand alongside federal law. For example, it suggested that state laws regulating medical debt, rental history, or arrest records could coexist with the F C R A. That interpretation was controversial. In May twenty twenty-five, the Bureau withdrew that interpretive rule, stating that it was unnecessary and that agencies lack special authority to interpret preemption unless Congress specifically delegates it. The Bureau also found that the twenty twenty-two rule created confusion and risked imposing higher compliance burdens. The Bureau now clarifies that the prior interpretation was flawed. The F C R A’s preemption clause was written in broad terms and must be applied broadly.The text of section sixteen eighty-one tee, subsection b, paragraph one, uses sweeping language: “No requirement or prohibition may be imposed under the laws of any State with respect to any subject matter regulated under” certain provisions of the Act. Congress deliberately used expansive phrases like “no requirement or prohibition,” “with respect to,” and “relating to.” Read together, these show that Congress meant to occupy the field of consumer reporting.The legislative history supports this interpretation. In the nineteen ninety-six amendments, lawmakers stressed the need for a uniform national credit system. In two thousand three, Congress decided to make preemption permanent, concluding that the national credit reporting system had expanded access to credit, lowered costs, and accelerated decisions. Allowing states to impose their own requirements would fracture the system, increase compliance costs, and undermine the usefulness of credit reports. Consumers would no longer be able to take their credit history with them as they moved, and lenders would struggle to compare creditworthiness across state lines.The Bureau emphasizes that state laws attempting to regulate core areas of credit reporting—such as prescreening, dispute procedures, adverse action notices, or the content of consumer reports—are preempted. State efforts to ban certain categories of information, such as medical debt or rental arrears, are also preempted. The Bureau explains that rules about how long information may remain on a report and whether it may appear in the first place are points on the same continuum. Allowing states to prohibit categories outright would contradict Congress’s intent.For the financial services industry, the rule restores clarity. Credit bureaus, lenders, and providers of consumer information can look to federal law as the governing standard without having to reconcile fifty different state regimes. For consumers, the effects are mixed. A national standard supports broader access to credit and ensures consistency. But some advocates will argue that state-level protections, particularly around medical debt, are now off the table.This interpretive rule is guidance. It does not have the force of law. Courts remain the final arbiters of preemption questions. Still, the Bureau’s position is clear: Congress intended broad federal preemption under the Fair Credit Reporting Act, and the national credit reporting system depends on it.This concludes the Fair Credit Reporting Act; Preemption of State Laws. 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 expertiseWith 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.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers Frequently Asked Questions. The following is an audio version of that document. 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 Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements. October 3, 2005. The Financial Crimes Enforcement Network, jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision, is issuing interpretive guidance in response to questions received regarding the filing of Suspicious Activity Reports. The purpose of this guidance is to clarify the regulatory expectations and requirements for financial institutions with respect to the reporting of suspicious activity. Financial institutions are reminded that Suspicious Activity Reports are one of the most important sources of information available to law enforcement and regulatory agencies for detecting financial crime, and are used in a wide range of investigations and enforcement actions. Below are answers to frequently asked questions regarding suspicious activity reporting requirements. Question 1: S A R Filings for Potential Structuring related Activity. Is a financial institution required to file a S A R for transactions or a series of transactions in which a person or persons are structuring transactions to avoid the C T R threshold, even though the total amount of currency involved does not exceed ten thousand dollars? Yes. The mere purpose of structuring is evidence of suspicious activity regardless of the amount. If one person or two or more persons act together to break up currency transactions to avoid the ten thousand dollar C T R threshold, then information sufficient to identify the activity should be reported on a S A R. For example, if an individual conducts multiple cash deposits of nine thousand five hundred dollars or less into different accounts to evade a C T R, the financial institution is required to file a S A R. A financial institution is required to file a S A R for a transaction conducted or attempted by, at, or through the institution if it involves or aggregates at least five thousand dollars in funds or other assets, and the institution knows, suspects, or has reason to suspect that the transaction: One, involves funds derived from illegal activities or is intended to hide or disguise funds from illegal activities. Two, is designed to evade Bank Secrecy Act requirements, such as structuring to avoid a C T R. Three, has no business or apparent lawful purpose. FinCEN has consistently advised that financial institutions must file S A R s for structuring even when the total amount of currency is less than ten thousand dollars. Under FinCEN guidance, structuring transactions to evade reporting requirements is suspicious in and of itself and must be reported. Financial institutions should not ignore structuring simply because the total amount falls below the C T R threshold. The fact that the amount is below ten thousand dollars does not eliminate the obligation to file a S A R. Question 2: Continuing Activity Reviews. Is a financial institution required to conduct a review of a customer or account following the filing of a S A R to determine whether suspicious activity has continued? Yes. Recognizing that suspicious conduct does not end once an initial S A R is filed, FinCEN guidance issued in October two thousand advised that institutions must review their S A R filings to determine whether additional S A R s should be filed. The continuing review should determine whether suspicious activity has persisted and whether further S A R s are warranted. Institutions are required to file continuing activity S A R s no later than ninety days after the date of the previously related S A R filing, if suspicious activity continues. Financial institutions must establish policies and procedures to identify and report ongoing suspicious activity. Institutions are expected to document reviews conducted and provide the rationale for whether a subsequent S A R is necessary. Question 3: Continuing Activity Reviews – Timeline. What is the timeline for a financial institution that elects to file S A R s in accordance with FinCEN’s continuing suspicious activity guidance? As noted in prior F A Qs, FinCEN previously recommended that financial institutions report continuing suspicious activity with a new S A R filing at least every ninety days. Subsequent S A R s must be filed no later than one hundred and twenty calendar days after the date of the initial S A R. The standard timeline is: Day one: Date of suspicious activity detection, begin review. Day thirty: File initial S A R. Day ninety: Review whether suspicious activity continues. Day one hundred and twenty: File continuing S A R if necessary. This timeline ensures that law enforcement is kept informed of continued suspicious activity. Institutions must maintain procedures that identify and escalate potential continuing suspicious conduct to compliance officers responsible for S A R decision-making. Question 4: No S A R Documentation. Is a financial institution required to document the decision not to file a S A R? Yes. There is no requirement or regulation that requires an institution to document its reasons for not filing a S A R. However, FinCEN has stated that financial institutions should maintain sufficient documentation to support the rationale for their decision not to file. This documentation should be retained in accordance with the institution’s internal policies and record retention requirements, and must be available to examiners and law enforcement upon request. Outro. This concludes the document. 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 expertiseWith our access retainer, you'll have on-demand support from former NCUA ...

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers Chairman Hauptman on Regulation by Enforcement. The following is an audio version of that document. 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 document. Chairman Hauptman On Regulation by Enforcement ALEXANDRIA, VA, October 1, 2025 – The National Credit Union Administration Chairman Kyle S. Hauptman issued the following statement about N C U A’s No Regulation-by-Enforcement Policy: Today’s policy statement fulfills a goal listed back in January upon being designated as Chairman: “Codifying our procedures to protect Americans from regulation-by-enforcement. For example, no enforcement action should ever set―or even clarify― policy. In America and other free societies, the sequence is: set speed limits, then give speeding tickets (no one has any obligation to be aware of someone else’s ticket).” To be clear, this agency has a good track record regarding regulation-by-enforcement, so this statement shouldn’t be viewed as being the result of any recent N C U A actions. After all, it’s counterproductive for a deposit insurer to engage in regulation-by-enforcement against the same institutions we insure. That said, it’s important to put in writing a policy of fairness, whereby government employees give regulated credit unions the same due-process that they, under civil servant protections, rightly expect in their own careers. Today’s statement is born partly of my frustrating interactions with regulators, both in my time on Capitol Hill and in the private sector. I know that millions of others share the frustration of being told ‘if you want to figure out the rules, look at our prior settlements.’ Americans expect better from their government, including financial regulators. No Regulation-by-Enforcement Policy Statement Regulation-by-enforcement is unethical and not permitted at N C U A. Enforcement actions shall only occur in the case of clear and significant violations of law or regulation. Therefore, no person or entity regulated by N C U A has any obligation to be aware of any prior N C U A enforcement actions because no new policy is ever set via an enforcement action. No enforcement action, nor the timing of enforcement actions, shall be motivated by trying to boost the agency’s enforcement totals or get the enforcement done in a certain fiscal or calendar year. Enforcement is a necessary tool, but is not, by itself, an accomplishment or a metric of success. Our goal is for credit unions to operate safely and soundly and in compliance with applicable laws and regulations. We will seek to remedy any such problems whenever we can without needing to use enforcement action. The goal is to resolve any problems, not to issue press releases, rack up enforcement numbers or improve the post-N C U A career options of agency staff. We don’t set “speed traps” to increase enforcement totals. A guiding principle here is avoiding double-standards. In their own careers, civil servants are protected against arbitrarily poor performance reviews, allegations of misconduct, wrongful termination and other things that could harm their career path. In turn, government employees must extend the same due process protections to those they regulate. If N C U A finds a harmful practice that threatens our mission or is otherwise injurious or abusive, and it is not currently addressed by law or regulation, then our next step is to consider rulemaking or other remedy. As is the norm in America, the sequence of events at N C U A is: one, publish rules, two, then and only then, enforce them. This concludes the document. 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 expertiseWith 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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www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ N C U A Discontinues Risk Ratings and Reputational RiskShow Notes In this episode, Samantha Shares provides an audio version of the recent N C U A communications announcing the discontinuation of risk ratings and the elimination of reputational risk in credit union examinations.In early September, N C U A emailed CEOs and Board Chairs that it would stop using individual risk ratings for categories like Credit, Liquidity, and Strategic risk. Later that month, the agency issued a press release confirming it would no longer use reputational risk or equivalent concepts, in line with White House Executive Order Fourteen Three Three One.Listeners will hear the original text of these letters and announcements, voiced audiobook-style, without added commentary. This principle-based guidance is designed to streamline examinations, reduce duplicative scoring, and focus examiner attention on material issues reflected in CAMELS ratings.Key points covered in the episode include:The removal of duplicative risk ratings for the seven traditional risk categories.Confirmation that N C U A examiners will still assess risk, but only in the context of CAMELS ratings.The elimination of reputational risk as a supervisory concept.Clarification that issues such as litigation exposure or insider abuse will still be reviewed under material financial impact.An emphasis on more streamlined examination reports and communications with credit unions.This audiobook-style presentation is intended as an educational resource for credit union leaders and boards.Disclaimer This podcast is educational and is not legal advice.Sponsor Message Credit Union Exam Solutions Incorporated provides consulting support from a team with more than two hundred and forty years of N C U A experience. If your credit union is preparing for or undergoing an N C U A exam, visit MarkTreichel.com to learn more. 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 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.comhttps://www.linkedin.com/in/mark-treichel/Tips on Starting an Exam Efficiently 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 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.