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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. 5h ago

    WFC Classic: Documents of Resolutions & Project Management

    Document of Resolutions can be complex or simple.  Regardless, they usually have many steps that NCUA doesn't realize, but you need to track.  We discuss the ins and outs of DOR project management in this archive episode.

    WFC Classic: Documents of Resolutions & Project Management

  2. 4d ago

    NCUA's New Exam Entry Letter: What Changed and What It Means for Your Exam

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ NCUA started sending a rewritten exam entry letter to credit union CEOs in late July and early August. It is not a formatting change. For the first time, the letter states what the exam is actually about. Mark Treichel is joined by Todd Miller and Steve Farrar of Credit Union Exam Solutions to go through the new template line by line and compare it against the one it replaced. The old template did not define or limit the substantive focus of the exam. Scope was whatever the exam team decided it was. The new template says the exam will focus on safety and soundness, significant compliance with applicable laws and regulations, and whether there is material financial risk. Steve traces that phrase across all three federal banking regulators and back to the Silicon Valley Bank failure. Todd points out that "material" is not defined by NCUA or anyone else, and that you can drive a truck through the barn door of what counts. Underneath all of it is staffing. Todd puts NCUA’s reduction at 27 percent and the FDIC’s at roughly a third. Examiners are playing triage, and the letter is the agency telling them what to stop looking at. The conversation covers what the letter now makes explicit that used to live as an unwritten rule in the national supervisory policy manual — including that examiners are supposed to work with management on corrective actions before the DOR is drafted, and that supplementary facts and informal discussion items are not actionable concerns. Todd’s read is that this took a tool away from examiners. Mark’s read is that the pressure does not disappear — it moves into supplementary facts, into the scope workbook, and into the close section the credit union never sees. Also covered: why compensation, vendor contracts, and pricing being off limits sits badly next to a decade of third-party due diligence pressure, and why it costs small credit unions the most; the mandatory exit meeting; the codified right to record joint conferences and exit meetings, and why recordings matter on appeal; VPN access and the two-week notice; CUSO records; direct examiner contact with external auditors; and the disappearance of unencrypted media and chain-of-custody transfers. Steve closes with a practical checklist for the day the letter lands: name the point person, resolve ambiguous requests before you upload anything, ask for extensions early and say why, and put someone on version control.

  3. Sep 11

    Commercial Loan Underwriting That Satisfies NCUA

    Guest: Vin Vieten, former NCUA Senior Credit Specialist Key Topics:- Financial analysis for commercial lending- Credit proposal best practices - Global cash flow analysis Key Takeaways: 1. Financial Analysis:   - Should be well-organized, consistent, and comprehensive   - Analyze 3+ years of financial performance to establish trends   - Examine income statement, balance sheet, and cash flow   - Provide value to borrowers through expert financial review 2. Credit Proposals:   - Use a standard, logical format    - Include key information like ownership structure, industry analysis, repayment ability   - List all direct and related debt to show total relationship exposure   - Assign and justify an appropriate risk rating   - Highlight exceptions to policy on the cover page 3. Global Cash Flow:   - Analyzes borrower, guarantor, and related entities to understand overall risk   - Depth of analysis depends on transaction complexity and risk level   - Should drive understanding of risk, not just regulatory compliance   - Default expectation is to obtain guarantees; exceptions must be well-documented Resources Mentioned:- NCUA Examiner's Guide on financial analysis and credit approval documents- Preamble to the proposed MBL rule from July 2015

    Commercial Loan Underwriting That Satisfies NCUA

  4. Sep 8

    SAR Confidentiality: The Line Between the Filing and the Facts Underneath It

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ On September 2, five agencies signed a joint statement on suspicious activity report (SAR) confidentiality: the Federal Reserve, the FDIC, the OCC, the NCUA, and the Financial Crimes Enforcement Network (FinCEN). Every prudential regulator plus the Bank Secrecy Act (BSA) rule maker on the same page. That is not one agency freelancing. The subject is narrow and the headline is simple. SAR confidentiality rules do not prevent a credit union from communicating with a member about a potentially fraudulent transaction, or about an action taken on their account — a hold, a closure. What stays confidential is the existence of the SAR itself and its contents. Two different things, and for years a lot of compliance programs have treated them as one. Mark Treichel, former NCUA Executive Director, walks through the operative sentence in the statement — a SAR, or information that would reveal a SAR exists, does not include the underlying facts, transactions, and documents that the SAR is based on — and explains why that is a legal test rather than a question of institutional risk tolerance. He then takes it where it actually lands: on the CEO's desk. Internal guidance written more restrictively than the rule requires is not a safe harbor. It is a credit union's own policy manufacturing member service and complaint handling exposure, and it gets asked about under the consumer compliance side of the exam, separate and apart from the BSA/AML module. Examiners will ask how you communicate with members during a fraud hold. "We say nothing, ever" is a harder answer to defend than it was a week ago. The episode closes with a three-step gap analysis a BSA officer can finish this week, and a broader question worth sitting with: where else in the program did the safe answer quietly become the house rule?

  5. Sep 4

    WFC Classic: Understanding Risk Management: Culture, Appetite & Action

    OverviewIn this episode, we break down the fundamentals of risk management for credit unions — what it really means, why it matters at every asset size, and how boards and executives can build a resilient framework that supports safe, sustainable growth.  blog risk appetite What We Cover The Three Pillars of Risk ManagementRisk Culture — how tone from the top determines effectiveness.Risk Appetite — defining how much risk is acceptable before strategy becomes unsafe.Risk Management System — the controls, processes, and oversight that put culture and appetite into action. blog risk appetite Why Size Matters — and Doesn’tPractical guidance for smaller credit unions: clear limits, strong oversight, and effective supervisory committees.What larger credit unions need: formal risk appetite statements, risk departments, and comprehensive reporting frameworks. blog risk appetite Common PitfallsThe “capital trap”—why even strong net worth can’t compensate for unmanaged concentration risk (e.g., taxi medallion credit unions).Siloed risk decisions.Hoping limit breaches “self-correct.” blog risk appetite Best Practices for a Strong FrameworkAlign appetite with capital and strategy.Use clear metrics to monitor risk.Establish formal limit-breach processes.Encourage staff to raise risk concerns without hesitation.Maintain strong documentation and communication. blog risk appetite Key TakeawayRisk management isn’t about eliminating risk — it’s about managing it in a way that protects members while enabling growth. A clear culture, aligned risk appetite, and well-designed system create the foundation for long-term success.

    WFC Classic: Understanding Risk Management: Culture, Appetite & Action

  6. Aug 31

    What’s Coming This Fall: Exam Letters, Bylaws, and a Rule NCUA Might Need

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Recorded August 30. A short episode looking ahead at the last four months of the year, plus one development worth flagging now. NCUA sent out a letter on how the exam process is going to work this coming cycle. It went to credit union CEOs. It was not posted on NCUA’s website. Mark has a copy and will cover it in an upcoming episode with Steve Farrar and Todd Miller of the Credit Union Exam Solutions team. An attorney pointed out that an item on bylaws went out the same way — to CEOs, not listed online. That’s two communications in short order that credit unions received directly and that the public record does not reflect. Mark has thoughts on why NCUA may be handling it that way. He does not agree with it. Also in this episode: the FDIC and OCC’s new final rule on safety and soundness and whether NCUA needs one of its own; what is likely to land on NCUA’s agenda in the remaining four months; a coming episode on ten things a new chairman should do for clarity and sunshine; the ex-regulator panel of John McKechnie, Geoff Bacino, and Alonzo Swann returning in the fourth quarter, probably after John Crews’s first board meeting; the Inspector General’s report to Congress; and new YouTube shorts that will not appear on the podcast feed.

  7. Aug 28

    WFC Classic: Capital Rules and Risk Management for Credit Unions

    www.marktreichel.com https://www.linkedin.com/in/mark-treichel/  | WFC Classic: Capital Rules and Risk Management for Credit Unions

  8. Aug 21

    WFC Classic: Did You Agree to That?

    Summary:In this special Archive episode of With Flying Colors, Mark explores the meaning and implications of "agreed upon corrective action" in credit union examinations. Drawing from his experience at NCUA, Mark explains how this term appears on examination reports and why its proper implementation is crucial for credit unions. Key Points Covered:Mark begins by breaking down the literal meaning of "agreed upon" using dictionary definitions, emphasizing that it means coming to a mutual arrangement or understanding. He shares a recent case where a small credit union reached out about their examination frustrations, highlighting how the agreed-upon process can sometimes break down. The Process:The examination report process typically includes a draft phase where credit unions can review and discuss findings with examiners. However, due to year-end pressures and internal goals, sometimes reports are finalized without proper consultation. Mark explains that the examination report's cover page explicitly states it should document "agreed upon corrective actions," making it important for credit unions to ensure they actually have input in this process. Recommendations for Credit Unions:Mark advises credit unions to push back when they don't receive proper opportunity for input. He suggests starting with the examiner, then moving up to the supervisory examiner if necessary. While NCUA has final authority on safety and soundness issues, credit unions should still receive the opportunity to influence report language to better serve their needs and their members' interests. Important Context:The podcast notes that NCUA implemented a higher level of review for examination reports, requiring supervisory review. While this creates more consistency, it can sometimes make immediate dialogue more challenging, especially when reports are delivered as final without prior discussion. Closing Thoughts:Mark emphasizes that credit unions must decide when to "go along to get along" versus when to advocate for changes. The goal should be finding language that satisfies both NCUA's safety and soundness requirements and the credit union's operational needs. Contact Information:Listeners can learn more about Mark's services at markteichel.com. The podcast releases new episodes once or twice weekly, providing expert insights on achieving success with NCUA. Listen Anywhere Listen OnApple Podcasts Listen OnSpotify Listen OnOvercast Listen OnPocket Casts Listen OnAmazon Music Listen OnYouTubeMore Options »

    WFC Classic: Did You Agree to That?
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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
    379
  • Rating
    Clean
  • Copyright
    © Credit Union Exam Solutions

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