CUSO EXAMS What You Need to Know

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## Episode Summary
Mark 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 Points
1. 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 Action
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