NCUA Exams: Insights and Trends with Todd Miller & Steve Farrar

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Key Points:

1. Recent NCUA exam focus areas:
- Interest rate risk and liquidity risk (2022-2023)
- Board governance
- Commercial lending programs
- Loan concentrations
- Consumer compliance, especially for third-party relationships

2. Board governance issues:
- Increased expectations for board oversight and accountability
- Focus on risk appetite and concentration risk limits
- Need for analytical support and modeling for risk limits

3. Communication challenges:
- Frustrations with examiner communication and expectations
- Importance of documenting discussions and agreements with examiners

4. Enterprise Risk Management:
- Growing expectations for ERM programs, even for credit unions under $10 billion
- FDIC guidance on corporate governance as a useful resource

5. Stress testing requirements:
- Increasing expectations for analytical support of policy limits
- Can be costly and resource-intensive for credit unions

6. Information security:
- Ongoing area of focus, likely to increase given recent high-profile incidents
- May lead to more formal exam findings (DORs) on cybersecurity issues

7. Third-party vendor management:
- Renewed emphasis on oversight of third-party relationships
- Recent incidents may fuel push for NCUA third-party vendor authority

8. Looking ahead:
- Potential for increased NCUA staffing and resources for consumer compliance
- Importance of credit union communication plans for crisis situations

Guests: Todd Miller and Steve Farrar, former NCUA executives and current credit union consultants

Host: Mark Treichel

The podcast provides insights into current NCUA examination trends and offers advice for credit unions on navigating regulatory expectations.