Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC Podcast Por Credit Union Exam Solutions Inc. arte de portada

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

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

De: Credit Union Exam Solutions Inc.
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This podcast provides you the ability to listen to new regulatory guidance issued by the National Credit Union Administration, and occasionally the F D I C, the O C C, the F F I E C, or the C F P B. We will focus on new and material agency guidance, and historically important and still active guidance from past years that NCUA cites in examinations or conversations. This podcast is educational only and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated. We also have another podcast called With Flying Colors where we provide tips for achieving success with the N C U A examination process and discuss hot topics that impact your credit union.2023 Economía
Episodios
  • NCUA's Proposed Rule to Eliminate Reputation Risk

    NCUA's Proposed Rule to Eliminate Reputation Risk
    Nov 5 2025

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    https://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.


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    22 m
  • CFPB Fair Credit Reporting Act; Preemption of State Laws

    CFPB Fair Credit Reporting Act; Preemption of State Laws
    Oct 29 2025
    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 ...
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    6 m
  • NCUA's Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements

    NCUA's Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements
    Oct 22 2025
    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, ...
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    7 m
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