Credit Union Exam Solutions Presents With Flying Colors

Mark Treichel's Credit Union Exam Solutions
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Credit Union Exam Solutions Presents With Flying Colors

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

  1. Just When You Thought It Was Safe - ECOA Part 2

    قبل ٢٢ ساعة

    Just When You Thought It Was Safe - ECOA Part 2

    Set up a call: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 Check out our website: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 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 passers its exam with 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. # With Flying Colors Podcast: Equal Credit Opportunity Act (ECOA) Part Two ## Episode SummaryIn this episode, Mark Treichel continues his discussion with Joe Goldberg, diving deeper into the Equal Credit Opportunity Act (ECOA) and Regulation B. They focus on the second primary purpose of ECOA: encouraging the informed use of credit through adverse action notices. ## Key Points1. Adverse Action Notices   - Purpose: Inform applicants of reasons for credit denial or less favorable terms   - Must provide specific reasons in detail   - Optimal to provide 3-4 main reasons for adverse action 2. Special Purpose Credit Programs   - Allow creditors to meet credit needs of specified classes of persons   - Different rules for for-profit and non-profit organizations 3. Department of Justice Referrals   - Required when there's reason to believe an institution has engaged in a pattern of illegal discrimination   - DOJ guidance available for identifying practices that may lead to referrals 4. New ECOA Section (Effective August 29, 2023)   - Requires collection and reporting of small business lending data to CFPB   - Applies to creditors with at least 100 originations to small businesses for each of the prior 2 years 5. Enforcement and Legal Actions   - NCUA enforces for federal credit unions   - Private actions allowed, including class actions 6. Compliance Best Practices   - Familiarize with ECOA and Regulation B   - Implement sufficient compliance management system   - Provide regular training for staff involved in lending   - Oversee third-party vendors   - Conduct self-testing and audits ## Resources Mentioned- NCUA Fair Lending Guide- NCUA Regulatory Alerts and Letters to Credit Unions- Federal Consumer Financial Protection Guide on NCUA website- CFPB website (consumerfinance.gov) - Fair Lending section ## Guest InformationJoe Goldberg: Attorney with 40 years of experience, former NCUA staff member, and consumer compliance expert. ## Hosted ByMark Treichel

    ٣١ من الدقائق
  2. What NCUA Really Wants to See in Your Board Reports with Todd Miller

    قبل ٣ أيام

    What NCUA Really Wants to See in Your Board Reports with Todd Miller

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ ## Episode OverviewA detailed discussion on what makes an effective board package for credit unions, drawing from Todd Miller's 34 years of experience at NCUA. Learn how to create board reports that help directors make informed decisions while satisfying regulatory requirements. ## Key Points on Board Packages ### Foundation and Purpose- Board packages should reflect management's responsibility to demonstrate compliance with:  - Business plan  - Board policy  - Risk appetite standards- Purpose is to help board members make good decisions regarding their responsibilities- Must balance what boards need to know vs. want to know ### Components of Effective Board Packages #### Quantitative Reports- Key Performance Indicators (KPIs)- Key Risk Indicators (KRIs)- Financial reports- Budget updates- Strategic plan progress- Peer comparisons- Dashboard-style summaries preferred over excessive detail #### Qualitative Reports- Clear, concise explanations providing context- Explanations for deviations from plans- Discussion of emerging risks and opportunities- Summaries of committee activities- Analysis of significant trends or changes ### Best Practices1. Maintain consistent formatting across all reports2. Use standardized indicators (e.g., red/yellow/green) throughout3. Present data in consistent order (e.g., oldest to newest)4. Include peer comparisons5. Make detailed data available but focus on summaries6. Regular review and updating of package contents7. Address material risks clearly and directly ### Common Pitfalls to Avoid- Information overload/data dumping- Inconsistent formatting- Burying significant risks in details- Failing to provide context for decisions- Including outdated or unnecessary reports- Not disclosing material information ## Regulatory ConsiderationsNCUA guidance states that "reports to directors should support complete, understandable, and accurate information appropriate to the size and complexity of the credit union." ## Key Takeaways1. Focus on helping board members make good decisions2. Provide clear understanding of current situation3. Keep focus on future actions and strategic direction4. Balance detail with clarity5. Maintain consistency in reporting structure

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  3. Equal Credit Opportunity Act Part 1

    ١٢ جمادى الأولى

    Equal Credit Opportunity Act Part 1

    Set up a call: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 Check out our website: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 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 passers its exam with 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. ## Episode SummaryIn this episode of With Flying Colors, host Mark Treichel welcomes back Joe Goldberg, a veteran attorney with 40 years of experience and former NCUA official. They dive deep into the Equal Credit Opportunity Act (ECOA) and its significance in fair lending practices for credit unions. ## Key Points Discussed- The purpose and significance of ECOA and Regulation B- NCUA's increased focus on fair lending examinations- Coverage of ECOA across various forms of credit- The nine prohibited bases for discrimination in lending- Specific examples of potential ECOA violations in credit union practices ## Highlighted Quotes- "ECOA requires creditors to make decisions related to providing credit and the terms of credit based solely on credit related factors." - Joe Goldberg- "NCUA has increased its focus on fair lending in the last several years. They even started when I was there. I left there at the end of 2021, but that's still true. And, in fact, the agency is expanding its fair lending examination program." - Joe Goldberg ## Important Takeaways for Credit Unions1. Review policies and procedures for potential age or marital status discrimination2. Be aware of the expanding fair lending examination program at NCUA3. Understand the nuances of the nine prohibited bases for discrimination4. Consider the risks associated with Department of Justice referrals for ECOA violations ## Next EpisodeTune in for Part 2 of this discussion, where Mark and Joe will continue their exploration of ECOA, including special purpose credit programs and the referral process to the Department of Justice. ## About the GuestJoe Goldberg is a former NCUA official who led the division responsible for HMDA, fair lending, and consumer compliance. With 40 years of experience as an attorney, he now works as a consultant in the credit union industry. ## Resources Mentioned- NCUA Letter to Credit Unions: 22-CU-04 (February 2022)- Equal Credit Opportunity Act (ECOA)- Regulation B ## Get in TouchFor more information on achieving success with NCUA, visit [marktreichel.com](https://marktreichel.com).

    ٣٥ من الدقائق
  4. Trump Election: What It Means for Your Credit Union

    ٩ جمادى الأولى

    Trump Election: What It Means for Your Credit Union

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Host: Mark TreichelGuests: John McKechnie and Jeff Pacino Key Topics Discussed: 1. Leadership Changes:- Discussion of Trump's election victory and its potential impacts- Changes in Senate Banking Committee leadership with Sherrod Brown's defeat- Tim Scott expected to chair Senate Banking Committee- Elizabeth Warren potentially becoming ranking Democrat on Banking Committee 2. NCUA Board Implications:- Anticipated leadership transition from Chairman Todd Harper to Kyle Hauptman- Analysis of NCUA Board dynamics and chairmanship powers- Discussion of Hauptman's term expiring in August 2025- Need for credit union industry experience on the NCUA Board 3. Critical Industry Issues:- Potential tax reform efforts in 2025- Importance of credit union advocacy and GAC attendance- Changes in regulatory approach under new leadership- Consumer compliance and budget considerations 4. Political Dynamics:- Discussion of Republican control of Congress- Two-year window for administration priorities- Importance of maintaining relationships across party lines- Changes in House Financial Services Committee leadership with McHenry's retirement Expert Analysis: The episode features experienced regulatory and industry veterans providing insights on navigating the changing political landscape and its implications for credit unions.

    ٣٤ من الدقائق
  5. Commercial Credit Culture: What Is It and Why It Is So Important

    ٥ جمادى الأولى

    Commercial Credit Culture: What Is It and Why It Is So Important

    Set up a call: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 Check out our website: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 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 passers its exam with 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. With Flying Colors Podcast: Understanding Credit Culture with Vin Vieten ## Episode SummaryIn this episode, host Mark Treichel interviews Vin Vieten, a retired senior credit specialist from NCUA, about credit culture in credit unions. Vin shares insights from his extensive experience in commercial banking, industry, and regulation, offering valuable perspectives on developing and maintaining a strong credit culture. ## Key Topics Discussed- Definition of credit culture and its importance in credit unions- Who is responsible for establishing credit culture- How to implement and reflect credit culture in policies and practices- The role of credit culture in credit proposals and actions- Balancing member service with safety and soundness in lending ## Notable Quotes- "What credit culture is, is your approach to providing credit to your customers, your members... It's how you're going to, why you're providing commercial financing and, and then really how you're going to do it."- "We're not here just to say yes or no to loans. We're here to provide the right financing for that borrower."- "Appropriate financing for the borrower. That's really what your job is. And that means financing that is paid back within the ability that's structured." ## Guest BioVin Vieten is a retired senior credit specialist from the NCUA with 11 years of experience at the agency. Prior to his role at NCUA, Vin worked as a commercial banker, senior loan officer, and controller for a large ready-mixed concrete company, giving him a unique perspective on all sides of the commercial lending process. ## Resources Mentioned- NCUA regulation 723 on Member Business Loans and Commercial Loans- Preambles to the proposed and final rules on commercial lending (July 2015 and February 2016) ## Upcoming TopicsMark teases future episodes covering:- Credit proposals- Underwriting- Regulatory resources- Credit risk rating systems- Global cash flow analysis ## Get in TouchFor follow-up questions or to discuss how Mark and Vin can assist your credit union:- Email: CUExamSolutions@marktreichel.com- Website: www.marktreichel.com

    ٣٤ من الدقائق
  6. Risk Appetite and Risk Management Framework

    ٢ جمادى الأولى

    Risk Appetite and Risk Management Framework

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ 1. Risk Management Framework Components:- Risk Culture - Established by board and management, sets tone from top- Risk Appetite - Formal statements and limits that define acceptable risk levels- Risk Management System - Including the three lines of defense 2. Risk Appetite:- Should be commensurate with institution's size and complexity- Must be supported by capital levels- Requires clear metrics and reporting systems- Needs documented processes for when limits are approached or breached- Should be consistently communicated throughout organization 3. Three Lines of Defense:- First Line: Front-line business units conducting transactions and operations- Second Line: Risk management department (in larger institutions) led by Chief Risk Officer- Third Line: Internal audit function testing controls and verification 4. Key Risk Management Principles:- Risk management culture is foundational to effectiveness- Smaller institutions can accomplish goals without full three lines structure- Need to avoid managing risks in silos- Importance of aggregating risks across organization- Chief Risk Officer role should support but not have veto power 5. Best Practices:- Document and communicate risk appetite clearly- Establish appropriate metrics and reporting- Have action plans for when limits are approached- Ensure staff feels comfortable raising risk concerns- Maintain independence of risk oversight functions 6. Resources Available:- OCC Director's Reference Guide contains useful guidance on risk governance- Includes questions to consider and potential red flags- Contains comprehensive references on risk and corporate governance The episode emphasized that while sophistication levels vary by institution size, core risk management concepts remain consistent and should be applied appropriately based on each credit union's specific circumstances.

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  7. CUSO EXAMS What You Need to Know

    ٢٨ ربيع الآخر

    CUSO EXAMS What You Need to Know

    Set up a call: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 Check out our website: https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10 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 passers its exam with 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. ## Episode SummaryMark Treichel discusses Credit Union Service Organizations (CUSOs) and CUSO examinations, drawing from his experience as a former NCUA Regional Director. He compares CUSO exams to credit union exams and provides insights into what credit unions and CUSOs can expect during these reviews. ## Key Points1. CUSO exam frequency and types:   - Less frequent than credit union exams   - Three types: integrated exams, standalone exams, and independent reviews 2. NCUA's authority to examine CUSOs:   - Based on agreements between credit unions and CUSOs   - Allows NCUA complete access to CUSO books and records 3. Types of CUSOs likely to be examined:   - Those offering new or growing services (e.g., commercial loans, student lending, FinTech) 4. NCUA's focus during CUSO exams:   - Systemic risks   - Individual credit union risks   - New or growing services 5. Documents NCUA may request:   - Strategic plans   - Disaster recovery plans   - Organizational charts   - Board minutes   - Customer lists   - Policies and procedures 6. Corporate veil considerations:   - Ensuring independence between CUSO and credit union operations 7. "Primarily serves" requirement:   - Case-by-case determination   - Based on totality of circumstances ## Notable Quotes"Getting a CUSO review, if your books and records are clean and your services are well documented and you can do a good job of controlling the narrative when NCUA comes in, when that happens, it's actually, can be a plus." ## Upcoming NCUA Developments- Proposed rule on eligible obligations and loan participations expected between July and September ## Resources Mentioned- Credit Union Exam Solutions: marktrico.com- CUSO Law: cusolaw.com- Previous podcast episode with Brian Lauer on CUSO regulation changes (episode number to be added in show notes) ## Call to ActionSubscribe to "With Flying Colors" on your favorite podcast app for more expert insights on achieving success with NCUA.

    ١٨ من الدقائق
  8. NCUA's Focus On Corporate Governance

    ٢٥ ربيع الآخر

    NCUA's Focus On Corporate Governance

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Guest Speakers:- Todd Miller - Steve Farrar  Key Topics Covered: 1. Definition of Corporate Governance- Set of processes, customs, policies, and laws affecting how a corporation is directed and controlled- Structure of rules, practices, and processes that determine corporate culture- Board responsibility for setting corporate culture 2. Resources for Directors- NCUA has limited specific resources on corporate governance- FDIC resources recommended:  * Pocket Guide for Directors  * 2016 Supervisory Insights  * Proposed guidance for larger institutions  * YouTube video on corporate governance 3. Key Board Responsibilities:- Setting appropriate tone and corporate culture- Approving and overseeing strategic planning (3-5 year outlook recommended)- Establishing and approving policies- Creating code of ethics- Providing active oversight of management- Selecting qualified executive officers- Ensuring ongoing director training- Conducting board self-assessments- Overseeing compensation and performance management 4. Important Considerations:- Board composition and diversity of skills/backgrounds- Documentation of strategic plan changes- Importance of independent but cooperative relationship with management- Training and self-assessment requirements- Three lines of defense in risk management:  * Frontline units  * Independent risk management  * Internal audit Notable Quotes:"By and large, directors are very dedicated and do a very good job of keeping our system safe and sound." - Todd Miller Resources Mentioned:- FDIC Director's Resource Center- NCUA Required Policies List- Quantum Governance (board training resource)

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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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