Credit Union Exam Solutions Presents With Flying Colors

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. 5D AGO

    2025 CAMEL Trends: What the Full-Year Data Actually Tells You

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ In this episode, Mark Treichel walks through the full-year 2025 CAMEL code data across all four quarters, providing a comprehensive analysis of where the industry stands and what the numbers mean for credit unions at every asset tier. The episode opens with context: in September 2024, then-National Credit Union Administration Chairman Todd Harper sounded a public alarm after the number of complex credit unions — those over $500 million in assets — coded at CAMEL four or five tripled in a single quarter. That alarm set the benchmark for evaluating 2025's results. Mark frames the analysis around three perspectives: the glass half full (optimistic), the glass half empty (skeptical), and the base case (pragmatic). He works through the data at an industry level before breaking it down by asset tier, where a more complicated picture emerges. Key findings include: the overall improvement in code four and five counts; a significant reduction in dollar exposure in troubled institutions; the resolution of Harper's specific alarm as the complex credit union count returned to seven at year-end; and the Q2 2025 anomaly, where the code three count fell but assets in that bucket jumped by $25 billion — illustrating how quickly the composition of a tier can shift even when the headline count moves in the right direction. A critical section covers the mid-size tier — $100 million to $500 million in assets — where 2025 produced almost no improvement. Code fours and fives in that range actually ticked upward. Mark explains the particular pressures mid-size institutions face and why the headline numbers can obscure their reality. The episode also addresses the National Credit Union Administration's staffing situation in depth: a 27% reduction in force, a shift in exam cycle requirements from mandates to goals, and the quiet update to the National Supervision Policy Manual extending exam cycles for larger institutions. Mark raises a pointed question: do the CAMEL code improvements reflect genuine rehabilitation, or do they partly reflect an agency adjusting to resource constraints? The episode closes with practical guidance for what to do based on your CAMEL code, and a look ahead to 2026 — including the hiring freeze, rising delinquency trends, and potential leadership changes at the agency.   Topics Covered: •        The Harper Alarm: context from September 2024 and how 2025 resolved it •        Full-year CAMEL code trends across all five quarter-ends •        Asset tier breakdown: $500M+, $100M–$500M, and under $100M •        The Q2 2025 anomaly: count down, dollar exposure up •        National Credit Union Administration staffing: 27% reduction, exam cycle changes, and the truth-in-coding question •        Glass half full: genuine improvements and the resolution of the Harper alarm •        Glass half empty: uneven distribution, merger effects, and delinquency trends •        The base case: what every credit union should do based on its CAMEL code •        What to watch in 2026

    24 min
  2. MAR 24

    Merger Mania: What Thirty Quarters of NCUA Data Reveal About Credit Union Consolidation

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ In this solo episode of With Flying Colors, host Mark Treichel presents a comprehensive data analysis of credit union mergers using thirty quarters of NCUA quarterly merger reports, covering activity from the third quarter of 2018 through 2025. The dataset includes 1,901 credit unions involved in merger activity, 1,298 completed mergers, and over $111 billion in merged assets. Mark walks through the consolidation math: credit union mergers typically run between 130 and 180 per year, representing three to four percent of all charters annually. The most notable trend in the data is the dramatic increase in the average size of merging credit unions—from $36 million in average assets in 2018 to $285 million in 2025, roughly an eight-fold increase. Total merged assets in 2025 reached $45 billion, the highest annual figure in the dataset. The episode examines the 80/20 split between voluntary and involuntary mergers, clarifying what the "involuntary" designation actually means in NCUA's reporting—and why it is frequently misunderstood. Mark also profiles the characteristics of serial acquirers, including one credit union that completed 24 mergers in four years, and discusses the different strategic approaches active acquirers take. The pre-merger financial profile section compares median data from merging credit unions against the broader population, with return on assets, membership growth, loan-to-share ratios, net worth, and delinquency all examined. Mark identifies the two metrics he considers most predictive: earnings and membership growth. The episode closes with a look at charter conversion trends—specifically the significant swing back toward federal charters since 2021—and a projection of where the industry is headed over the next 25 years under different consolidation rate scenarios. Topics covered include: •        Annual merger volumes and the peak year of 2019 (254 mergers) •        The dramatic rise in average merger size: $36M (2018) to $285M (2025) •        What "voluntary" and "involuntary" really mean in NCUA merger data •        The 265 involuntary mergers: financial condition, official challenges, management, and sponsor loss •        Serial acquirers and scale players: different strategies, same data source •        Pre-merger profile: median $11M in assets, negative ROA, membership declining at -91bps •        Acquirer profile: median $2.5B in assets, 82bps ROA, 139,000 members •        Charter conversion trends: $41B moved back to the federal charter since 2021 •        Industry projections: 1,555 to 2,015 charters by 2050 under current consolidation rates •        Strategic implications: board governance, membership growth, earnings discipline

    27 min
  3. The Two Documents That Shape Your NCUA Examination

    MAR 19

    The Two Documents That Shape Your NCUA Examination

    Two documents shape how NCUA conducts credit union examinations: the Examiner's Guide and the National Supervision Policy Manual (NSPM). In this episode, Mark Treichel sits down with former NCUA veterans Todd Miller and Steve Farrar to break down what credit unions need to know about both.  The discussion covers the history behind these documents—including why NCUA's six regions once operated so differently that the Board mandated standardization—and provides practical guidance on which sections credit unions should prioritize.  Topics discussed in this episode:  • Why the NSPM was created and how it standardized examination procedures across NCUA's regions  • What happened to the Examiner's Guide and why it's been de-emphasized  • The reference sections in the Examiner's Guide that remain valuable for credit unions  • Key NSPM chapters every credit union should review: District Management, Federal/FSCU Programs, and Regulatory Waivers  • Response timeframes for administrative actions and appeals  • Transparency gaps: missing chapters, dead links, and redacted sections  • How to use both documents strategically when preparing for examinations  Whether you're preparing for an upcoming exam, navigating an enforcement action, or simply want to understand how your regulator operates, this episode provides the insider perspective.  Resources mentioned:  • NCUA's publicly available redacted NSPM  • NCUA Examiner's Guide (web-based version)  • Related episodes on CAMEL Code 3 and 4 ratings, appeals process, and Documents of Resolution

    54 min
  4. MAR 17

    Margin, Membership, and Mounting Risk: Unpacking Q4 2025 with Farrar, Miller and Bauer

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ In this episode, Mark Treichel is joined by Steve Farrar, Todd Miller, and Dennis Bauer for their quarterly review of the National Credit Union Administration call report data. The group walks through the Q4 2025 numbers across each component of the CAMEL framework, discussing what the data is showing, where the risks are building, and what credit union leaders should be paying attention to heading into 2026.   TOPICS COVERED   Capital The industry net worth ratio stands at approximately 11.28%, down slightly from 11.35% at the end of Q3 2025 but up from 11.2% at year-end 2024. Only 59 credit unions are below the 7% well-capitalized threshold. GAAP net worth has improved nearly 200 basis points over the past two years as unrealized investment losses continue to recover. Community bank core capital ratios are comparable at approximately 11.05%.   Asset Quality – Investments Credit unions have been extending investment maturities in a flat yield curve environment, with dollars growing in the three-year, five-year, and ten-year buckets. The spread between a three-year and ten-year investment is only about 14 basis points. Combined with growth in mortgage and commercial loans, balance sheet duration is extending on multiple fronts simultaneously.   Asset Quality – Loans Industry delinquency crossed 1% for the first time in a decade. Non-owner occupied residential real estate delinquency jumped from approximately 62 basis points to 141 basis points. Commercial real estate, construction and development, and student loan categories also showed meaningful increases. Auto loan balances actually declined in 2025 — a rare occurrence. Allowance coverage of delinquency declined from 140% at Q3 to 131% at year-end. Community bank charge-off rates were 0.21%, compared to 0.78% for credit unions. The group discusses the regional nature of credit stress and how national averages can mask concentrated problems in specific geographies.   Earnings Return on assets improved approximately 16 basis points year-over-year, driven by a 27-basis-point improvement in net interest margin. Net interest margin appears to have peaked — up only one basis point from Q3 to Q4. The efficiency ratio improved to approximately 69-70%. Operating expenses have grown at 7% or more for at least three consecutive years, with salary and benefits (nearly half of all operating expenses) up roughly 8% annually in 2024 and 2025. About 11.7% of credit unions were unprofitable in 2025, compared to approximately 5% of community banks. Seventeen credit unions over $1 billion reported losses.   Liquidity and Membership Deposit growth ran at approximately 5%, while membership growth fell to just 2% — the lowest level in roughly a decade. Certificate of deposit growth is decelerating as rates fall, with money market and share draft accounts growing faster. Approximately 80% of CDs are expected to reprice in 2026. Wholesale funding was repaid, improving borrowing capacity.   NCUA and the Broader Environment The group discusses National Credit Union Administration staffing reductions and what that means for examination priorities. With limited resources, the focus will necessarily concentrate on asset quality and concentration risk. Mark raises the pending change to the CAMEL 1 designation and calls for the agency to communicate that change publicly to stakeholders. CAMEL rating distribution improved modestly, with a $155 billion reduction in assets held in CAMEL 3-rated institutions.   GUESTS Steve Farrar – Former National Credit Union Administration examiner, problem case officer, and VP of the Central Liquidity Facility; now with Credit Union Exam Solutions Todd Miller – Former Director of Special Actions, National Credit Union Administration Western Region; now with Credit Union Exam Solutions Dennis Bauer – Former CFO and EVP of Ideal Credit Union (St. Paul, MN); former National Credit Union Administration examiner; now with Credit Union Exam Solutions

    48 min
  5. From Guidelines to Guardrails: Getting Credit Union Policies Right

    MAR 12

    From Guidelines to Guardrails: Getting Credit Union Policies Right

    In this episode of With Flying Colors, Mark Treichel sits down with Todd Miller to explore what makes credit union policies effective — and what separates the policy frameworks at high-performing credit unions from those that consistently generate examination findings.   Todd, who spent over 33 years at NCUA including a decade as Director of Special Actions, draws on his experience examining credit unions across the full performance spectrum. He shares what he consistently saw in top-performing organizations: strong written policies that created transparency at every level, from the boardroom to the branch.   The conversation covers why policies matter beyond regulatory compliance, including their role as training tools, culture builders, and accountability mechanisms. Todd outlines the general principles that underpin effective policy management — from top-down implementation and accessibility to the importance of consequences for non-compliance and the disciplined handling of policy exceptions.   The heart of the episode is Todd's breakdown of common elements that should appear in every credit union policy, regardless of subject matter: purpose and objectives, accountability structures, risk appetite statements with real limits, systems of trend-based reporting, and scheduled review processes. He explains why policy limits should be unique to each credit union, why guidelines are no substitute for hard limits, and why trend reporting matters more to board members than point-in-time snapshots.   Mark and Todd also discuss the connection between policy compliance and organizational culture, including how violations of individual authority limits can erode morale, create bond claim exposure, and — in the most serious cases — lead to insurance fund losses.

    32 min
  6. MAR 10

    Rate Caps, Interchange, and the Banking Lobby: What Credit Unions Are Up Against with Jason Stverak

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Episode Summary Mark Treichel sits down with Jason Stverak, Chief Advocacy Officer at the Defense Credit Union Council (DCUC), for a wide-ranging conversation on the policy threats credit unions are currently facing. From the government shutdown's impact on Coast Guard members to the proposed 10% interest rate cap, interchange regulation spreading into the states, and the banking lobby's opposition to credit union bank acquisitions — Stverak covers the full landscape of what's moving in Washington and why credit union leaders need to be paying attention. What We Cover The partial government shutdown and its direct impact on Coast Guard members working without pay — and how credit unions are stepping in with forbearances and emergency lending. The ICBA's renewed push against credit union bank acquisitions, and why Stverak argues the real driver is dues protection rather than principled policy. The proposed 10% interest rate cap: why credit unions and banks have issued joint opposition, and what a cap at that level means for members with lower credit scores. How interchange regulation is moving from Congress into state legislatures — and why Illinois is just the beginning. DCUC's growth (30% membership increase in the past year), its due structure, and what it means for non-defense credit unions to engage with a defense-focused trade organization. The concept of operating "over the event horizon" — anticipating threats before they become crises. Upcoming DCUC events including Defense Matters at GAC, CU Unplugged in San Francisco, regional sub-council meetings, the annual meeting in Miami, and an overseas meeting in Bangkok. Connect with Jason Stverak and DCUC Website: dcuc.org Email: jstverak@dcuc.org

    32 min
  7. Don’t Create a Vacuum: Crisis Communication for Credit Unions with John McKechnie

    MAR 5

    Don’t Create a Vacuum: Crisis Communication for Credit Unions with John McKechnie

    When a crisis hits your credit union—whether it’s a cyber breach, ransomware attack, or liquidity event—how you communicate in those first hours and days can define the outcome. In this episode, Mark Treichel sits down with John McKechnie to discuss crisis communication lessons learned from decades in the credit union industry.  John served at CUNA for over 18 years before joining NCUA, where he led the Office of Public and Congressional Affairs under three chairmen during some of the most turbulent years in the agency’s history, including the 2008 financial crisis. Since 2011, he’s been advising credit unions on communications strategy, public affairs, and crisis management. In this episode, Mark and John discuss: •        Why silence during a crisis creates a dangerous vacuum—and how to avoid it •        The principle of being “first with the truth” and why speed matters •        How to identify and prioritize your key stakeholders during an incident •        The value of tabletop exercises and crisis communication plans •        Real examples from the 2008 financial crisis and recent cyber incidents •        Why your members need to hear that their insured funds are safe—early and often •        Setting up a landing page as a single source of truth during a crisis •        The importance of conducting a postmortem after any incident •        How a crisis can actually strengthen the bond between a credit union and its members Whether your credit union has a crisis communication plan on the shelf or is starting from scratch, this episode offers practical guidance on how to prepare—and how to perform when it matters most. Connect with John McKechnie: Email: john@mckechniellc.com Phone: 202-997-5816

    27 min
  8. MAR 3

    My Takeaways from Monday at GAC: Structure, Supervision, and Stablecoins

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Episode Title: My Takeaways from Monday at GAC: Structure, Supervision, and Stablecoins In this episode, I share my takeaways from Monday at GAC in Washington, D.C. This was my first GAC in 2000 as Deputy Executive Director at NCUA. I’ve attended more than 20 since. It was good to be back in D.C., reconnect with colleagues, clients, and former NCUA staff — and to see how the tone of the conference felt this year. Three sessions stood out: 1️⃣ Scott Simpson – Stewardship & Advocacy Scott Simpson’s first GAC as head of America’s Credit Unions set a different tone. He emphasized: Credit unions as a social movementThe importance of advocacyThe reality that tax status and field of membership are not automaticUnity between large and small institutionsIn a chaotic political and regulatory environment, the reminder that credit unions exist because Congress allows them to exist matters. 2️⃣ Brené Brown – Strengthening the Foundation Brené Brown’s keynote focused on “strong ground.” Her theme: leaders often compensate around weaknesses instead of strengthening the foundation. Key ideas: Vulnerability = uncertainty, risk, and exposureNo risk, no courageArmor (resistance, avoidance, overconfidence) blocks real leadershipIn times of uncertainty, strengthen the coreIn an environment shaped by technology shifts, mergers, geopolitical tension, and regulatory changes, that message resonated. 3️⃣ Chairman Hauptman – Supervision & Stablecoins Chairman Hauptman’s fireside chat focused on rethinking supervision and discussing stablecoins. Supervision With NCUA staffing down significantly (I reference roughly 27%), he raised the question: Is the juice worth the squeeze? Topics discussed: Consistency and transparency in examsFewer document requestsRethinking supervisory touchpointsReorganization within NCUAExtending exam cycles for well-run institutionsI also discuss how regulatory inconsistency — when priorities swing dramatically — can create real operational risk for credit unions. Sometimes NCUA can be a credit union’s biggest risk — not due to bad intent, but because uncertainty affects strategic decisions. Consolidation Consolidation is happening. That’s math. But it’s not inevitable individually. Every mature industry consolidates over time. The key is leadership, strategy, and execution. Stablecoins Chairman Hauptman framed stablecoins as infrastructure and global dollar dominance. The key question I raise (credit to Kiah Haslett’s framing): What problem does stablecoin actually solve that existing rails don’t? We already have: FedwireACHRTPFedNowIs the value international? Domestic? Structural? Or hype? Time will tell. Final Thought Across all three speakers, one theme connected the day: Are we strengthening the foundation — or compensating around it? It was a fun and informative day at GAC, and I’ll continue sharing observations as the week unfolds. If you were there and saw something differently, let me know.

    23 min

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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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