Episodios

  • NCUA Reopens Public Comment on Succession Planning

    NCUA Reopens Public Comment on Succession Planning
    Apr 23 2025
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers NCUA’s reopening the public comment period on two recently finalized rules that haven’t fully taken effect yet. 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.Today, we’re diving into an important update from the National Credit Union Administration. This update comes straight from the April twenty-third Federal Register. If you’re a board member, executive, or compliance officer, you’ll want to pay close attention.On April twenty-third, the NCUA announced something a little unusual—they are reopening the public comment period on two recently finalized rules that haven’t fully taken effect yet. Here’s why this matters.Earlier this year, the White House issued what’s called a “Regulatory Freeze Pending Review.” In plain English, that means federal agencies were asked to hit pause and review any major new rules that hadn’t already kicked in. NCUA, just like other agencies, is now inviting the public—yes, that means you—to weigh in again on two big rules.The first is called Simplification of Share Insurance. This rule was finalized back in September twenty twenty-four and is scheduled to fully take effect December first, twenty twenty-six. The goal is to make NCUA’s share insurance rules simpler and clearer for both credit unions and your members. With this new comment window, you have another chance to raise questions, flag concerns, or support the parts of the rule you think are working.The second rule is about Succession Planning. This one was finalized in December twenty twenty-four and is set to take effect January first, twenty twenty-six. It’s designed to make sure credit unions have solid plans in place for leadership succession—a big deal, especially for smaller credit unions and those with retiring executives. This new comment period is your opportunity to share whether you think the rule strikes the right balance, or if it creates any challenges for your operations.So how can you submit your comments? You have until June twenty-third, twenty twenty-five. You can go online to regulations dot gov and look up the docket numbers for each rule, or send your comments to the NCUA Secretary in Alexandria, Virginia. If you’re old school, you can even hand deliver them.You might be thinking, didn’t we already comment on these rules? Yes, many did—but this is a second bite at the apple, thanks to the new administration’s regulatory review. If your credit union has operational concerns, needs more clarity, or has suggestions for how the rules are implemented, now is your chance to be heard.Here are your quick takeaways. NCUA is actively seeking comments on the share insurance simplification and succession planning rules, both of which are set to take effect in twenty twenty-six. The deadline for comments is June twenty-third, twenty twenty-five. Your feedback could help shape how these rules roll out, or even whether they proceed as planned.That’s it for today’s update. We’ll keep you posted on any new developments and what they mean for your credit union. If you have questions or want to share how your credit union is preparing for these changes, send us a note—we might feature your insights in a future episode.Thanks for tuning in Stay informed, stay compliant, and stay ahead.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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    4 m
  • NCUA Releases Staff Message on the Current NCUA Board

    NCUA Releases Staff Message on the Current NCUA Board
    Apr 19 2025

    www.marktreichel.com

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


     NCUA Releases Staff Message on the Current NCUA Board


    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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    2 m
  • Understanding Conflicts of Interest in Asset Management (OCC)

    Understanding Conflicts of Interest in Asset Management (OCC)
    Apr 16 2025

    www.marktreichel.com

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


    Understanding Conflicts of Interest in Asset Management: Show Notes

    In this episode, Samantha Shares explores the critical topic of conflicts of interest in asset management based on the OCC Comptroller's Handbook. While originally created for banks, these principle-based guidelines provide an excellent framework for credit unions managing conflicts in their asset management activities. The episode covers what constitutes a conflict of interest, common scenarios where conflicts arise, the four main risk categories (compliance, operational, reputation, and strategic), and key components of effective risk management. Samantha details specific conflict situations including self-deposits, proprietary investment products, brokerage allocation, and soft dollar arrangements, while outlining four essential principles for handling conflicts: proper authorization, full disclosure, fairness and reasonableness, and maintaining the client's best interest. The episode emphasizes that managing conflicts effectively isn't just about regulatory compliance—it's fundamental to maintaining client trust and protecting your institution's reputation.



    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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    13 m
  • OCC's Comptroller's Handbook booklet "Model Risk Management"

    OCC's Comptroller's Handbook booklet "Model Risk Management"
    Apr 9 2025

    www.marktreichel.com

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


    Show Notes: Model Risk Management (OCC Comptroller's Handbook)

    In this episode, Samantha Shares discusses the OCC's "Model Risk Management" handbook (Version 1.0, August 2021). This comprehensive handbook provides guidance on how financial institutions should manage risks associated with their use of models.

    Key topics covered:

    • Definition of models and model risk
    • Types of risk associated with model use
    • Governance framework requirements
    • Three lines of defense in model risk management
    • Model development, testing and implementation
    • Validation process and requirements
    • Third-party model risk management
    • Documentation and inventory requirements


    This handbook is essential knowledge for anyone dealing with model risk management in financial institutions, particularly those subject to OCC supervision.


    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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    35 m
  • Understanding the Capitalization of Unpaid Interest Into the Loan Balance

    Understanding the Capitalization of Unpaid Interest Into the Loan Balance
    Apr 2 2025

    www.marktreichel.com

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


    Reach out to learn how we assist our clients.


    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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    16 m
  • Building Resilience: Contingency Funding Plans for Credit Unions

    Building Resilience: Contingency Funding Plans for Credit Unions
    Mar 26 2025

    www.marktreichel.com

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


    NCUA wants you to build a good contingency funding plan. We discuss their guidance on this important topic.


    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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    9 m
  • NCUA Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data

    NCUA Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data
    Mar 19 2025
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers NCUA Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data The following is an audio version of that STATEMENT. 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 STATEMENT N C U A Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data N C U A Board Member Tanya F. Otsuka issued the following statement about the agency’s decision to remove total overdraft and non-sufficient fund (NSF) fee data for federally insured credit unions with more than $1 billion in assets from Call Reports beginning with the first quarter of 2025.Member empowerment is a cornerstone of the cooperative credit movement. For credit unions, which are built on the philosophy of “people helping people,” increasing transparency is a simple way to demonstrate the credit union difference, enable consumers to make informed financial decisions, and help maintain trust and confidence in our cooperative system of credit. In that spirit, the N C U A began collecting and publishing quarterly Call Report data on revenues credit unions with over $1 billion in assets made from overdraft and non-sufficient funds (NSF) fees last year.Unfortunately, the fourth quarter 2024 data published today will be the last to include information on overdraft and NSF fee income. On March 3, 2025, Chairman Hauptman unilaterally announced changes to the way the N C U A collects overdraft and NSF fee information.1 Specifically, starting on March 31, 2025, the agency would “no longer publish overdraft and non-sufficient fund fee income for individual credit unions” and this information would ostensibly be collected during supervisory examinations.This is a step in the wrong direction. There is no data to suggest credit unions limited the services they provide low-income or underserved consumers last year simply to avoid having to report fee income on the N C U A’s Call Reports. Credit unions with higher overdraft and NSF fees also do not appear to offer lower fees to members for other services, nor better interest rates.2 Overdraft and NSF fees put a strain on members who are likely already struggling and may further trap them in a cycle of financial hardship that can be difficult to escape. That is why providing the public information about fees through the N C U A’s Call Reports enabled consumers across the country to more readily compare between credit unions and choose the institution that best fit their needs.3Credit unions are already required to disclose to their members the fees that they charge. Instead of providing overdraft and fee income in a transparent, consistent, and standardized way, collecting overdraft and NSF fee data through the exam process will erode the quality of the data and hamstring our ability to monitor trends. The decision to collect this data through the supervisory process rather than through the quarterly Call Report must not be used as an excuse to withhold it from credit union members or the broader public.Transparency is vital for promoting fair competition within the financial system. Limiting access to individual credit union data does not help consumers, encourage the chartering of de novo institutions, or reduce regulatory burden on small cooperatives, which were exempt from the requirement to report these data. It just enables larger institutions that rely heavily on fee income to operate in the shadows, resulting in less competition and less choice for consumers, and places institutions that stay true to the principles of the credit union movement at a disadvantage.At the end of the day, members, as owners of their credit union, have a right to know how their institution operates, just like any investor would if they purchased stock in a publicly traded company. We shouldn’t keep credit union members in the dark.I urge the N C U A Chair to prioritize transparency and to continue the practice of quarterly reporting and public disclosure of overdraft and NSF fee income for individual credit unions. I look forward to continuing to work with the entire N C U A Board to protect consumers and the credit union system.This concludes the STATEMENT If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. ...
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    6 m
  • NCUA Board Member Todd Harper Statement on the Decision to Curtail the Collection of Overdraft and Non-sufficient Fund Fees

    NCUA Board Member Todd Harper Statement on the Decision to Curtail the Collection of Overdraft and Non-sufficient Fund Fees
    Mar 15 2025
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers NCUA Board Member Todd Harper Statement on the Decision to Curtail the Collection of Overdraft and Non-sufficient Fund Fees The following is an audio version of that Statement 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 Statement. NCUA Board Member Todd Harper issued the following statement about the agency’s decision to curtail the collection of total overdraft and non-sufficient fund (NSF) fees for federally insured credit unions with more than $1 billion in assets beginning with Call Reports for the first quarter of 2025.For markets to work efficiently, transparency is needed. That’s a bedrock principle of economics. And, it’s one of the many reasons why credit union member-owners and the public should have clear visibility into the income a credit union generates from overdraft and NSF fees charged to its member-owners.To advance credit union efforts to benchmark fees against other financial institutions, improve marketplace competition, and increase consumer understanding of the fees they’re charged within the credit union system, the NCUA required federally insured credit unions with more than $1 billion in assets to disclose, separately, income from overdraft and NSF fees beginning with the 2024 first quarter Call Report. With today’s release of the 2024 fourth quarter Call Report results, however, that desirable transparency experiment will regrettably end.During the last year, we’ve found that reporting institutions have collected $3.8 billion in such fees. Some charged no fees at all. For most reporting credit unions, overdraft and NSF fees accounted for between 2 and 5 percent of revenue. Some outliers charged fees amounting to as much as 18 percent of income. For those billion-dollar-plus credit unions with higher overdraft and NSF fees, we also found that they did not use those fees to subsidize better interest rates or lower other fees.Federally insured banks with more than $1 billion in assets began reporting these numbers in 2015. Since then, consumers have benefitted as banks have lowered their reliance on such fees. In fact, the Consumer Financial Protection Bureau found that roughly two out of three banks with $10 billion or more in assets have eliminated NSF fees, saving consumers $2 billion annually. Yet, among credit unions with greater than $10 billion in assets, four out of five continue to charge NSF fees. That overreliance on such fees is one of the many reasons why the NCUA began collecting and publicly reporting this data on Call Reports.But, by unilateral action by the Chairman, credit union member-owners and the public will now no longer have access to this important information. If credit unions are to live up to their statutory purpose of supporting the financial needs of ‘people of modest means and the credit union movement’s oft-touted ‘people-helping-people’ philosophy, then credit union member-owners should have access to this basic market information, so they can make better decisions about how and where to deposit and access their hard-earned money.While the NCUA will no longer publish overdraft and NSF fee income for individual credit unions on a real-time quarterly basis, the agency will instead collect the data during supervisory examinations. This approach, however, will likely shield credit union members from accessing the information through the Freedom of Information Act. Ultimately, this non-disclosure will result in financial exclusion, especially when one considers that NSF is a fee for not paying for an item.In my view, the NCUA should restore fee transparency for overdraft and NSF fees on Call Reports. If the Chairman is unwilling to reverse course, then the overdraft and NSF fee data collected in the exam process at individual credit unions shouldn’t be shielded from public release through the Freedom of Information Act. If such data was once already public information, why now sweep it under the rug?The Chairman also noted that the appropriateness of overdrafts and NSF fees charged is a matter between a credit union and its member-owners. If those member-owners ultimately determine how their credit union is run, then credit union management should make their overdraft and NSF income upon member-owner request.As a steward of the credit union system and someone whose father and grandfather ...
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    6 m
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