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

Credit Union Exam Solutions Inc.

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.

  1. ٢٣ يوليو

    Office of the Comptroller of the Currency's Semiannual Risk Perspective Spring 2025.

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Show Notes: OCC Semiannual Risk Perspective Spring 2025 Episode Overview This episode covers the Office of the Comptroller of the Currency's Semiannual Risk Perspective for Spring 2025, providing valuable insights for credit unions on key banking risks and industry trends. Key Topics Covered Federal Banking System Key Themes Overall system strength remains sound despite economic uncertaintyCommercial credit risk increasing due to geopolitical risks and sustained higher interest ratesRetail credit risk stable but consumer sentiment decliningMarket and liquidity risk stable with improved net interest marginsOperational risk elevated due to cyber threats and digitalization challengesCompliance risk remains elevatedEconomic Operating Environment Global: Slow growth forecast for 2025, trade policy uncertainty, geopolitical tensionsDomestic: GDP 12% above pre-pandemic peak, unemployment at 4.2%, but economic uncertainty growingProjections: 1.2% growth in 2025, 1.3% in 2026; PCE inflation expected to reach 3.6% by Q3 2025Credit Risk Insights Commercial Credit CRE market conditions vary by property typeOffice vacancies projected to continue rising into 2026Multifamily market expected to stabilize later in 2025Refinance risk high for loans underwritten during low-rate periodsTrade disruptions may compress industry marginsRetail Credit Delinquency rates manageable but trending upwardConsumer payment prioritization favoring low-rate mortgagesTighter lending standards across consumer categoriesNatural disaster impacts on insurance and collateral administrationMarket Risk Net interest margins improved in second half of 2024Unrealized investment losses remain a concern10-year Treasury yield volatility affecting portfolio valuesInterest rate risk scenario testing critical given uncertaintyOperational Risk Cybersecurity Continued targeting by threat actors with ransomwareIncrease in "double extortion" attacksATM jackpotting attempts risingThird-party dependencies creating single points of failureInnovation & Technology Cautious AI adoption with focus on fraud detection and credit underwritingLegacy system challenges amid digitalization demandsNew OCC guidance on crypto-asset activities (IL 1183 and IL 1184)Board oversight responsibilities for new technologiesFraud Risk Management Traditional payment methods still targetedSocial engineering and phishing schemes prevalentFirst-party fraud and insider abuse concernsImportance of customer education and staff trainingCompliance Risk BSA/AML and OFAC Elevated fraud levels increasing SAR filing obligationsFintech partnerships may lack adequate compliance resourcesCorporate Transparency Act requirements removed for US companiesNeed for continued CDD rule complianceConsumer Compliance Investigation and resolution timeframes criticalNew deposit products requiring clear communicationsRising insurance premiums affecting flood insurance complianceBank Performance Return on equity stable at 11.7% for federal banking systemNet interest income growth slowed due to funding costsLoan growth weak at 1.6%, driven by C&I loan declinesBalance sheet positioning may benefit from future rate cutsNet charge-off rates historically strong despite slight increasesKey Statistics Federal banking system liquid assets: 31% of total assets (vs. 16% in 2008)Employment: 5.5 million above pre-pandemic peakUnemployment rate: 4.2%Q1 2025 job creation: 177,000Federal banking system loan growth: 1.6%Deposit growth: 1.6%Important Dates & Regulatory Updates March 7, 2025: OCC issued IL 1183 on crypto-asset activitiesMay 7, 2025: OCC issued IL 1184 on crypto-asset custody servicesMarch 2025: Treasury removed beneficial ownership reporting requirementsSeptember 2024: Federal Reserve began rate cuts (100 basis points total)Credit Union Applications While this report focuses on OCC-supervised institutions, the principle-based guidance provides excellent insights for credit unions to: Assess similar risk exposuresBenchmark risk management practicesPrepare for evolving regulatory expectationsUnderstand industry-wide trends affecting the financial sectorSponsor Information Credit Union Exam Solutions LLC Over 240 years of combined NCUA experienceAssists credit unions with NCUA examinationsContact: Mark Treichel at MarkTreichel.comLinkedIn: Mark TreichelRelated Resources OCC Bulletin 2017-43: "New, Modified, or Expanded Bank Products and Services"OCC Bulletin 2023-17: "Third-Party Relationships: Interagency Guidance"OCC Bulletin 2019-37: "Operational Risk: Fraud Risk Management Principles"With Flying Colors Podcast: NCUA examination tips and strategies This podcast is educational and is not legal advice. Content reflects conditions as of December 31, 2024, unless otherwise noted. 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. ١٦ يوليو

    FDIC's Consumer Compliance Supervisory Highlights for July 2025

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Show Notes: FDIC Consumer Compliance Supervisory Highlights - July 2025 Episode Summary In this episode, we break down the FDIC's latest Consumer Compliance Supervisory Highlights report, covering 2024 examination results and compliance trends. While focused on FDIC-supervised institutions, this principle-based guidance serves as an excellent roadmap for credit unions and all financial institutions. Key Takeaways Overall Performance 97% of FDIC-supervised institutions rated satisfactory or better for consumer compliance800 consumer compliance examinations conducted in 2024Risk-focused examination approach targets areas with greatest potential for consumer harmTop 5 Most Cited Violations (73% of all violations) Truth in Lending Act (TILA) - 470 violations (37%)Periodic statement disclosure failuresGood faith estimate timing issuesLoan cost breakdown requirementsFlood Disaster Protection Act (FDPA) - 143 violations (11%)Failure to provide required flood insurance45% of FDPA violations related to this single issueTruth in Savings Act (TISA) - 129 violations (10%)Inadequate deposit account disclosuresPre-opening disclosure failuresElectronic Fund Transfer Act (EFTA) - 122 violations (10%)Error investigation procedure failuresTiming and reporting requirement violationsHome Mortgage Disclosure Act (HMDA) - 65 violations (5%)Incomplete data collection and reportingMissing required borrower and loan informationEnforcement Actions & Restitution 31 formal and 23 informal enforcement actions$5.6 million in civil money penalties$33.3 million in voluntary restitution to ~400,000 consumers3 referrals to Department of Justice for discrimination violationsConsumer Complaint Trends 26,451 complaints closed (14% increase from 2023)100% acknowledgment within 14 days98.6% response rate within performance goalsTop Complaint Categories: Credit cards: 4,733 complaints (29%)Checking accounts: 3,152 complaints (19%)Installment loans/CLOC: 2,708 complaints (12%)Residential real estate: 844 complaints (5%)Most Common Issues: Credit reporting disputes (18%)Transaction errors (9%)Accounts opened without knowledge (6%)Disclosure problems (6%)Service availability issues (5%)Emerging Trends 13% increase in third-party provider-related complaints (4,282 cases)Growing vendor oversight challengesPersistent credit reporting and account opening issuesFair lending complaints decreased 9% (68 to 62 cases)Key Compliance Areas for Focus High-Risk Areas Disclosure Management: TILA, TISA, and HMDA reporting accuracyOperational Procedures: Flood insurance, error resolution processesVendor Oversight: Third-party provider compliance monitoringData Collection: HMDA and other regulatory reporting requirementsProactive Strategies Implement robust disclosure review processesEnhance staff training on operational complianceStrengthen vendor management programsMonitor complaint trends as early warning indicatorsWhy This Matters for Credit Unions While this report focuses on FDIC-supervised banks, the consumer protection laws and compliance principles apply broadly across financial services. Credit unions can use these insights to: Benchmark their compliance performanceIdentify potential risk areas before they become problemsEnhance training and procedures in high-violation areasImprove vendor management practicesResources Mentioned FDIC Consumer Compliance Examination ManualFederal Financial Institutions Examination Council (FFIEC) Rating SystemFDIC National Center for Consumer and Depositor Assistance Host Notes This episode provides actionable insights for compliance professionals, with extensive use of direct quotes from the FDIC report to ensure accuracy. The data shows that while most institutions are performing well, concentrated issues in specific areas offer clear opportunities for improvement across the industry. 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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  3. ٩ يوليو

    NCUA Exam Alert: Risk Management Framework Essentials That Pass Exams

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This podcast is educational and is not legal advice. Banking agencies have curtailed issuance of new guidance and regulations under the current administration. As a result, and to continue providing our listeners with valuable new episodes, we're excited to share our new initiative and cohost. We'll be providing AI-powered summaries of evergreen episodes from our sister podcast With Flying Colors. These episodes will highlight the key points in an easy-to-digest eight to twelve minute format. We continue to embrace Artificial Intelligence, and like my voice, these new episodes will be introduced by me and then narrated by our guest AI voice. Today, Daniel will discuss 'NCUA Exam Alert: Risk Management Framework Essentials That Pass Exams.' This episode is also available on YouTube in AI video format, so be sure to check that out as well! Now, here's Daniel with your summary.   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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  4. ٢٥ يونيو

    Fighting Payments Fraud: A Deep Look into Federal Banking Agencies' New Initiative

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Episode: Fighting Payments Fraud - Federal Banking Agencies Launch Major Initiative Episode Summary Three major federal banking agencies have joined forces to combat the explosive growth in payments fraud across America. In this episode, we break down the comprehensive Request for Information issued by the OCC, Federal Reserve, and FDIC on June 20, 2025, seeking public input on how to better protect consumers, businesses, and financial institutions from fraud schemes. Key Takeaways 🚨 Alarming Statistics: Non-card payments fraud losses increased 271% between 2020-2024Suspicious Activity Reports for check, ACH, and wire fraud up 489% since 2014Check fraud alone has risen 385% since COVID-19Check fraud accounts for 30% of all fraud-related SARs filed in 2023💰 Financial Impact: Fraud reports for payments apps, bank transfers, wire transfers, and checks resulted in $2.99 billion in losses in 2024, up from $806 million in 2020Five Key Areas Federal Agencies Are Targeting External Collaboration - How can stakeholders work together more effectively?Education - Better fraud prevention education for consumers, businesses, and industryRegulation & Supervision - Potential regulatory changes and clearer guidanceData Collection - Standardizing and centralizing fraud data sharingReserve Bank Tools - Enhanced fraud detection and prevention servicesNotable Quotes "Payments fraud has the potential to erode public trust in—and undermine the safety, accessibility, and efficiency of—the nation's payments system, upon which the U.S. financial system depends.""No agency or private-sector entity can address payments fraud on its own."Payments fraud data is currently "collected in an incomplete, non-standardized, ad hoc, and fragmented way."What's at Stake Check Vulnerability: Paper checks contain sensitive information including account numbers, routing numbers, addresses, and signatures that criminals can exploitMulti-Institution Schemes: Fraud often involves multiple banks and payment methods across different regulatory jurisdictionsTrust in the System: Continued fraud growth threatens confidence in the entire U.S. payments infrastructureRegulatory Focus Areas Regulation CC Changes The Federal Reserve is considering amendments to funds availability rules, asking whether: Technological advances allow for shorter hold periodsCurrent fraud detection capabilities justify faster fund accessBetter dispute resolution mechanisms are neededIndustry Pain Points Banks struggle with interbank disputes over fraudulent check liabilitySmall community banks need additional fraud prevention resourcesCurrent data sharing restrictions limit collaborative fraud fightingWhat Happens Next Comment Deadline: September 18, 2025 Who Can Participate: Banks and credit unionsFintech companiesConsumer advocacy groupsTechnology providersPayment processorsAnyone affected by payments fraudQuestions Agencies Want Answered What technological solutions work best for fraud prevention?How can fraud education be more effective?Should Reserve Banks require fraud reporting across all payment rails?What barriers prevent better data sharing between institutions?How can confirmation of payee services reduce fraud?Why This Matters to You Whether you're a banking professional, fintech entrepreneur, or consumer who's experienced fraud, this initiative could reshape how America fights payments fraud. The agencies are serious about getting input from all stakeholders to build a more secure payments ecosystem. Resources Federal Register Document: Vol. 90, No. 117, June 20, 2025, pages 26293-26298Comment Submission: Multiple agencies accept comments through regulations.gov and agency websitesAgency Contacts: Specialized fraud and payments policy teams at OCC, Federal Reserve, and FDICEpisode Length Approximately 10 minutes Tags #PaymentsFraud #BankingRegulation #FederalReserve #OCC #FDIC #CheckFraud #Fintech #PaymentSecurity #RegulatoryPolicy #FinancialCrimes This episode is based on official federal regulatory documents. For the most current information, consult the Federal Register and agency websites. 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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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.

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