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Mark Treichel's Credit Union Exam Solutions

Tips for Credit Unions Success on the NCUA Examination. Brought to you by Mark Treichel's Credit Union Exam Solutions.

  1. 3d ago

    Trust Is Not an Internal Control: David Reed on Fraud and the Supervisory Committee

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ In this episode of With Flying Colors, host Mark Treichel welcomes back David Reed of Reed & Jolly, PLLC — a longtime credit union attorney, former general counsel, and self-described “recovering supervisory committee member” who served a decade on a supervisory committee, including six or seven years as chair. David reached out after listening to Mark’s earlier coverage of the Jackson Area Federal Credit Union case, just as he was kicking off a two-day national supervisory committee school, and the timing made for a rich conversation. The heart of the discussion is fraud prevention through the lens of the supervisory committee. Using the Jackson Area allegations as a teaching tool — and stressing repeatedly that everything is alleged, drawn from NCUA’s amended lawsuit — David walks through why trust is not an internal control, why insider accounts are the single greatest fraud risk at smaller credit unions, and why occasional reviews of senior executives’ own accounts (even just by volume) should be routine and done independently. He and Mark unpack the “clipboard audit” problem, the limits of pop teller audits, and the difference between a full CPA opinion audit, agreed-upon procedures, and a supervisory committee doing the work itself. David makes a direct case that the $500 million CPA opinion-audit threshold is outdated — arguing it should drop to $250 million — because technology has erased the product-and-service gap between small and large credit unions while leaving the same fraud exposure. He notes that many of his sub-$500 million clients already choose to get CPA audits because they add accountability and assurance, and that scope can be added to any audit like a cafeteria plan, including a targeted review of senior-executive and insider accounts. The conversation then broadens. On the NCUA board, David explores the implications of changes to Humphrey’s Executor — the prospect of removable board members, a possible “clean sweep” every administration, the chilling effect on recruiting qualified people to serve partial terms, and the resulting shift of power toward the permanent bureaucracy. On succession planning, he champions a “junior varsity governance” model with associate board and committee members, and reframes every incumbent nomination as a re-selection that deserves real evaluation. On collections, he urges credit unions to turn the same predictive analytics they use to find lending opportunities inward — reaching members before they fall two or three payments behind and stop answering the phone. Throughout, David returns to one theme: most credit unions already have the tools, processes, and even the results they need — the question is whether anyone is actually activating and reviewing them. Reach David Reed at david@reedandjolly.com.

  2. Jul 9

    WFC Classic: Liquidity — An NCUA Perspective

    "Liquidity Management: Reading Between the Lines of NCUA's Latest Guidance" In this insightful episode, Mark Treichel and former NCUA Capital Markets Specialist Todd Miller analyze NCUA's April 2023 liquidity webinar and provide their expert take on the agency's current perspective on liquidity management. Episode Highlights: Todd Miller shares his 34-year experience at NCUA, including his roles as a regional capital market specialist and director of special actionsKey liquidity guidance documents discussed: 2010 Interagency Policy Statement on Funding and Liquidity Risk Management, 2013 CU 10 guidance on Regulation 741.12, and the 2023 addendum on contingency funding plansAnalysis of credit union deposit composition changes: from 55% in money markets, CDs, and wholesale funding in 2009 to 52% currentlyDiscussion of "reversion to the mean" in deposit mix and how credit unions have adapted to the rate environmentExamination inconsistencies: varying liquidity ratios and expectations from examiner to examinerThe importance of forward-looking liquidity management versus "rear-view mirror" approachesDisconnect between NCUA's public statements (e.g., "supervisory test is not how credit unions should manage interest rate risk") and examiner actionsHow improved analytics allow credit unions to operate with lower cash holdings while still managing risk effectivelyThe appropriate use of wholesale funding, borrowings, and non-member deposits in liquidity managementWhy well-capitalized credit unions with good asset quality will generally maintain access to liquidityResources Mentioned: 2010 Interagency Policy Statement on Funding and Liquidity Risk Management2013 CU 10 guidance on NCUA Regulation 741.122023 addendum to the 2010 interagency statement on funding and liquidity risk

  3. Jul 6

    CAMELS Gets an Overhaul: Inside the NCUA’s Proposed Changes

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ For the first time in 30 years, the CAMELS rating system is being rewritten. In this episode, Mark Treichel is joined by Todd Miller and Steve Farrar — all former NCUA — to break down the proposal moving through the Federal Financial Institutions Examination Council (FFIEC) and what it means for credit unions. The headline change: Management (the “M”) loses the special status that let it override the other five components. The agency’s own data showed Management was the most influential factor in composite ratings; under the proposal, it’s weighed alongside Capital, Asset quality, Earnings, Liquidity, and Sensitivity — not above them. Mark, Todd, and Steve dig into the new “material financial risk” threshold that must now be met to downgrade Management to a 3 or worse; the removal of judgment-heavy language like “resiliency” and “size and complexity”; the push toward fewer, sharper Documents of Resolution; and the compliance carve-outs that keep the system from being toothless. They also weigh the trade-off at the heart of the proposal — more objective, consistent ratings versus the loss of a forward-looking early warning system — with Signature Bank and Silicon Valley Bank as cautionary examples. The practical bottom line: most credit unions won’t see their composite change, but those sitting right at a rating boundary should pay close attention. Comments are open, and the notice doubles as a useful primer for boards and senior staff.

  4. Jun 25

    WFC Classic: NCUA's Net Economic Value (NEV) Framework

    Episode Summary:In this episode of With Flying Colors, host Mark Treichel is joined by former NCUA capital markets expert Todd Miller to discuss the latest updates to NCUA’s Interest Rate Risk (IRR) Supervisory Framework. Following NCUA’s recent stakeholder webinar, we break down key takeaways, including changes to risk categorization, the elimination of the extreme risk rating, and how these updates impact credit unions navigating today’s economic landscape. What You’ll Learn in This Episode:✅ The history and evolution of NCUA’s NEV framework✅ Why NCUA eliminated the “extreme risk” category and what it means for credit unions✅ The role of examiner judgment in assessing interest rate risk under the new guidance✅ How credit unions can mitigate risk and avoid a Document of Resolution (DOR)✅ The growing importance of liquidity management and how credit unions should prepare✅ Why examiner scrutiny of IRR is increasing, despite the removal of automatic DORs Key Takeaways from the NCUA Webinar:🔹 NCUA clarified that interest rate risk remains a top supervisory priority for 2023 and beyond.🔹 Credit unions must demonstrate strong risk management practices to avoid regulatory action.🔹 Liquidity risks are increasing due to rising rates and market shifts—credit unions should reassess their funding strategies.🔹 Open communication with examiners is essential—proactive discussions can help avoid surprises. Resources Mentioned in This Episode:📄 NCUA’s Letter to Credit Unions (22-CU-09): [Insert link if available]🎥 NCUA’s Stakeholder Webinar on Interest Rate Risk: [Insert link if available]🔍 Learn more about Credit Union Exam Solutions: marktretchel.com Subscribe & Stay Connected

    WFC Classic: NCUA's Net Economic Value (NEV) Framework
  5. Jun 22

    Washington Roundtable: The NCUA Board in Flux With McKechnie, Bacino and Swann

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Mark Treichel hosts a Washington roundtable with John McKechnie, Geeff Bacino, and Alonzo Swann — each with deep NCUA and credit union experience — to break down the forces reshaping the agency this summer. The conversation opens with the NCUA board itself: nominee John Crews and his likely path through a Senate Banking confirmation hearing, and a pending Supreme Court removal-power case that could reinstate two dismissed members or clear the way for new appointments. The group weighs what a full versus divided board would mean for examination priorities, enforcement, and the pace of rulemaking. From there, the discussion turns to a Mississippi conservatorship that became a fraud. Mark explains the single balance-sheet signal — an unusually high cash position paired with heavy borrowing and low loans-to-assets — that pointed to trouble before the word “fraud” was ever used, and the panel discusses what it reveals about supervisory committees, external audits, and internal controls. All wrongdoing is alleged, and a material loss review by the Inspector General follows. The panel then makes the case for examiner presence — the “empty cop car” effect — and why on-site observation catches what data alone cannot, especially as staffing tightens. The episode closes with a look at the Credit Union Board Modernization provision moving through Congress, which would give qualifying, healthy credit unions relief from monthly board-meeting requirements, and a candid take on why credit unions still trail banks on legislative relief. Topics: NCUA board composition and the confirmation timeline; the pending removal-power case; the Jackson, Mississippi conservatorship and alleged fraud; internal controls and supervisory committee oversight; examiner presence and staffing; the material loss review process; and the Credit Union Board Modernization provision.

  6. Jun 18

    WFC Classic: Avoiding Document of Resolutions: 10 Essential Strategies

    Episode Description:In this special archive episode of With Flying Colors, Mark shares valuable insights from his years of experience in credit union examination and consulting. Broadcasting straight from the beach, he breaks down the top 10 ways credit unions can avoid receiving a Document of Resolution (DOR) from the NCUA. Whether you're preparing for an exam or just looking to fine-tune your operations, these practical tips will help ensure compliance and maintain a smooth examination process. What You'll Learn in This Episode: Understanding Document Resolutions (DOR): What they are, why they occur, and how to avoid them.Key Triggers for DORs: Common issues such as violations of regulations, policies, or strategic plans.Proven Strategies: How to communicate, negotiate, and train effectively to avoid potential pitfalls.Best Practices: Mark’s insights on proactive planning, staying informed, and maintaining good examiner relationships.Top 10 Tips Highlighted in This Episode: Comply with the Federal Credit Union Act and NCUA regulations.Follow your organization's policies diligently.Stick to your approved strategic plan or adjust it responsibly.Communicate effectively with NCUA examiners.Negotiate issues identified during the examination process.Invest in training for staff, boards, and committees.Stay updated with regulatory changes by subscribing to NCUA Express.Listen to informative podcasts like With Flying Colors and Credit Union Regulatory Guidance.Avoid accounting problems by ensuring reconciliations and timely audits.Make senior leadership accessible to examiners during the examination process.Resources Mentioned: NCUA ExpressCredit Union Regulatory Guidance podcastMark’s consulting services for NCUA examination supportCall to Action:If you enjoyed this episode, don’t forget to subscribe to With Flying Colors for more actionable tips and insights into navigating NCUA exams and credit union compliance. Ratings and reviews on Apple Podcasts and Spotify are always appreciated!

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Tips for Credit Unions Success on the NCUA Examination. Brought to you by Mark Treichel's Credit Union Exam Solutions.

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