Credit Union Exam Solutions Presents With Flying Colors

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

  1. From Guidelines to Guardrails: Getting Credit Union Policies Right

    1D AGO

    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

  2. 3D AGO

    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
  3. 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

  4. 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

  5. FEB 26

    LUAs Explained: From Informal Actions to Formal Commitments

    Mark Treichel sits down with Steve Farrar and Todd Miller to break down Letters of Understanding and Agreement—NCUA's formal enforcement tool that requires board-level commitment. With over 100 combined years of NCUA experience, including Steve's authorship of NCUA's enforcement manual, this episode delivers insider perspective on what LUAs mean for credit unions, how boards should approach them, and critical mistakes to avoid. Key Topics Covered What triggers an LUA: Understanding when NCUA escalates from informal actions to formal enforcement, and why most credit unions receiving LUAs are classified as troubled. Published vs. unpublished: The distinction that creates reputation risk, how industry publications find published LUAs, and which state regulators require publication. Board accountability: Why voting no or abstaining doesn't protect individual directors, and what fiduciary responsibility means when your credit union signs an LUA. Negotiation before signing: How to approach discussions with your examiner or problem case officer, ensuring timeframes are realistic and commitments are achievable. Root causes vs. comprehensive lists: Why LUAs should focus on fundamental problems, and what to do when you're facing a lengthy document with dozens of items. Satisfying an LUA: The two-part test NCUA applies—completing actions AND achieving intended results—and why there's no built-in expiration date. Notable Quotes "The LUAs only addressed mainly what we would refer to as the root causes of the problem." — Steve Farrar "The language in published LUAs is very draconian and very one-sided. It's intended to be serious." — Todd Miller "If you abstain or vote no, and the board agrees to sign, you're still subject to that agreement. It was a board decision." — Mark Treichel About the Guests Steve Farrar spent 30+ years at NCUA, including 15 years as a problem case officer and 15 years in the central office where he authored NCUA's enforcement manual and worked on corporate resolution and risk-based capital regulations. Todd Miller served nearly 35 years at NCUA as an examiner, problem case officer, regional capital market specialist, and Director of Special Actions supervising problem case officers and capital market specialists. Resources Credit Union Exam Solutions: marktreichel.com Related Episode: Documents of Resolution and Examiner Findings

    19 min

  6. FEB 24

    It's Never as Bad as You Think: Suicide, Fraud, and the Stories I've Never Told

    Episode Title: It's Never as Bad as You Think: Suicide, Fraud, and the Stories I've Never Told Content Warning: This episode discusses suicide. If you or someone you know is struggling, please call or text 988 (Suicide & Crisis Lifeline). Episode Description: The death of 25-year-old Vikings wide receiver Rondale Moore this weekend brought back memories Mark has never shared publicly. In 33 years at NCUA — including 8 years as Executive Director — Mark encountered two individuals who took their own lives after embezzling from their credit unions. In this solo episode with no intro music, Mark tells those stories for the first time and delivers three messages to anyone in the credit union industry who may be carrying a secret they think will destroy their life. In This Episode: How the Rondale Moore story and Hollywood Brown's tweet triggered this episodeMark's first encounter with suicide at age 19A Midwest credit union CEO whose "hunting accident" wasn't accidentalThe connection between Dead Poets Society and an examination Mark will never forgetAn East Coast treasurer who jumped from a high-rise rather than face conservatorshipThree core messages: it's never as bad as you think, there's always a way back, and you will get caughtWhat credit union leaders can do to pay attention to the people, not just the numbersResources: 988 Suicide & Crisis Lifeline — call or text 988American Foundation for Suicide Prevention — afsp.orgHat tip: Matthew Coller and The Purple Insider podcast for the Rondale Moore episode that pushed Mark to finally record this.

    26 min
  7. Your Right to Appeal: Navigating NCUA's Formal Process

    FEB 19

    Your Right to Appeal: Navigating NCUA's Formal Process

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Episode Description: When your credit union receives an examination result you believe is wrong, what are your options? In this episode, Mark Treichel walks through NCUA's formal appeal process from start to finish — the timeline, the levels of review, what you can actually appeal, and how to think about whether it makes sense for your institution. Drawing on his experience as a former NCUA regional director and his work advising credit unions through the process, Mark breaks down the practical realities most credit union leaders don't fully understand until they're in the middle of it. Key Topics Covered: Why resolving issues at the examiner level is always the best first step — and why it doesn't always workThe fear of retaliation and when it's worth pushing back anywayWhat qualifies as a "material supervisory determination" under Part 746The critical phrase most credit unions overlook: "includes, but is not limited to"Why you can't formally appeal CAMEL components — but effectively can anywayDocument resolutions are negotiable: pushing back on language, dates, and requirementsThe full appeal timeline: regional director, Supervisory Review Committee, and NCUA BoardWhen oral hearings are available and when they're guaranteedWhy "tie goes to the runner" at every level — and what that means for your burden of proofDefining victory: full reversals, partial wins, and the value of being heardBuilding your administrative record for the long termKey Takeaways: You have 30 days from the final exam to appeal to the regional director — and some argue the clock starts when you see the draft.A full appeal through the NCUA Board can take eight months to a year.The Supervisory Review Committee must grant an oral hearing if you request one — the only level where that's guaranteed.Your odds of success generally improve as you move higher in the process.Even if you don't win the appeal, you're building an administrative record NCUA must consider in any future enforcement actions.Resources: NCUA Part 746, Subpart A (Appeals Regulation)Preamble to the final rule on appeals processCredit Union Exam Solutions: marktreichel.com  Opus 4.5Extended Claude is AI and can make mistakes. Please double-check responses. Share Artifacts Download all Ncua

    28 min

  8. FEB 17

    NCUA’s Stablecoin Proposal: What Credit Unions Need to Know Now

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ The NCUA has issued a proposed rule implementing the GENIUS Act, establishing a federal licensing framework for payment stablecoin issuers. For the first time, credit union subsidiaries could apply to become Permitted Payment Stablecoin Issuers (PPSIs) — but only under strict supervisory standards. In this episode, Mark breaks down: Why credit unions cannot issue stablecoins directlyHow the subsidiary licensing model worksThe 10% “Parent Company” threshold and joint application structureThe 1% CUSO investment cap and its impact on participationThe 120-day statutory decision clockHow this compares to FDIC, OCC, and Federal Reserve proposalsWhy “rewards vs. interest” could become the next regulatory battlegroundHow the proposed CLARITY Act fits into the broader digital asset frameworkThis proposal represents one of the most significant expansions of NCUA supervisory authority in decades. While stablecoin issuance is optional, the regulatory guardrails are now taking shape. Comments on the proposed rule are due 60 days after Federal Register publication. If your credit union is considering digital asset innovation, payment modernization, or cooperative technology ventures, this episode outlines the strategic considerations. Key Topics GENIUS Act stablecoin frameworkSubsidiary-only issuance requirementPPSI licensing processCapital and liquidity expectationsCUSO structure implicationsJoint ownership modelsRegulatory cost recovery debateCLARITY Act market structure considerationsWhy This Matters Stablecoins are not insured shares. They are not backed by the full faith and credit of the United States. They cannot blur the line between payments and deposits. Understanding these distinctions will be critical as the industry evaluates next steps. If you found this episode helpful, share it with a colleague and subscribe to With Flying Colors for ongoing insights into NCUA policy, supervision trends, and regulatory strategy.

    17 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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  • Creator
    Mark Treichel's Credit Union Exam Solutions
  • Years Active
    2022 - 2026
  • Episodes
    329
  • Rating
    Clean
  • Copyright
    © Credit Union Exam Solutions

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