Federal and state regulators such as the NCUA and ODFI examine credit unions on a roughly annual basis. Examinations focus on assessing risks like credit, interest rate, liquidity, compliance and reputation risks. Credit unions have the right to respectful treatment by examiners and to discuss and appeal examination findings and directives. Examiners are expected to identify problems but also work cooperatively with credit unions to find solutions.
Credit Rating Process with Respect to Corporate DebtSumit Kumar Singh
Volatility in the financial market is becoming common day by day as we are becoming more and more intensive towards global market. The importance of Credit Rating Agencies has gone up because an investor can't always keep track on key 'Financial Metrics' of companies. So investors try to fix this with the help of ratings assigned by Recognized Rating Agencies
Credit Rating Process with Respect to Corporate DebtSumit Kumar Singh
Volatility in the financial market is becoming common day by day as we are becoming more and more intensive towards global market. The importance of Credit Rating Agencies has gone up because an investor can't always keep track on key 'Financial Metrics' of companies. So investors try to fix this with the help of ratings assigned by Recognized Rating Agencies
What is the role of credit rating agencies in our global financial system? Learn how credit ratings on securities are created and used. Part of a continuing series of introductory seminars for the financial services industry. We develop custom training, contact us for a quote or discussion of your needs.
Numerous financial instruments and products are used in financial planning. Life insurance is an example of both because it assists individuals accomplish financial goals via a financial mechanism that is legally structured differently from other financial planning products such as 401(k)s and individual retirement accounts.
Comprehensive Reporting
The Comprehensive Securitization Audit Report was created in order to serve the various purposes of securitization audit – from seeking the most favorable terms in a loan modification to supporting legal action to delay or defend against foreclosure or to seek relief from unfair or unlawful practices by lenders, servicers, and related institutions.
This report is different because it includes a section that discusses the contemplated profit that was to be made by the participants from securitizing a loan. The figures used in the computations are gathered from actual documents. It also states how soon the lender recovered the full amount it originally lent to the borrower instead of the 30 years it usually takes for the loan to be fully paid from the agreed monthly amortizations.
The Comprehensive Audit Report was conceptualized to be what a real audit should be – independent and unbiased, with the auditor or examiner free of any interest in its outcome. It neither attempts to sensationalize its findings nor ignore the present economic ramifications of the crash of the housing market that securitization helped to unfold.
CUSO vs. In-House: Growing Your Member Business Lending PortfolioLibby Bierman
In recent years, an increasing number of credit unions are starting, or expanding, their Member Business Lending (MBL) portfolios. This presents a number of challenges, including having the proper systems in place. And a decision must be made to outsource the function to a Credit Union Service Organization (CUSO), build it internally, or some combination of the two. In this webinar, Ancin Cooley, principal of Synergy Credit Union Consulting, and Mike Ford, director at Sageworks, discussed the growth in MBL, benefits and challenges of both CUSOs and internal departments, and provide recommendations for continued growth.
Discover the new world of credit. In this PowerPoint developed for high school students, be introduced to the vocabulary of credit, what it is, and why it is important to maintain a good credit score.
A slide deck from GBRW covering the key principles of problem loan management, based on GBRW's extensive experience with Non-Performing Loan (NPL) management, restructuring and work-out assignments.
Ratio Analysis and Business Performance – Why Should I Care – Part 2?McKonly & Asbury, LLP
The webinar is hosted by David Blain, Partner and Director of McKonly & Asbury’s Entrepreneurial Services Group, and Eric Fischer, Benefits Advisor at American Family Life Assurance Company of Columbus (Aflac).
This webinar is a continuation of the first webinar hosted on May 30, 2019. This webinar focuses on debt covenant and leverage ratios most used and reviewed by banks and other lending institutions. The webinar also focuses on how banks and lending institutions view these ratios and how to best prepare and present your business for compliance with these ratios.
The new Bank Secrecy Act (BSA) rule codifies existing regulatory expectations regarding customer due diligence and imposes a new requirement on covered financial institutions. Learn about the new requirement to identify and verify the natural persons behind institutions’ legal entity customers.
What is the role of credit rating agencies in our global financial system? Learn how credit ratings on securities are created and used. Part of a continuing series of introductory seminars for the financial services industry. We develop custom training, contact us for a quote or discussion of your needs.
Numerous financial instruments and products are used in financial planning. Life insurance is an example of both because it assists individuals accomplish financial goals via a financial mechanism that is legally structured differently from other financial planning products such as 401(k)s and individual retirement accounts.
Comprehensive Reporting
The Comprehensive Securitization Audit Report was created in order to serve the various purposes of securitization audit – from seeking the most favorable terms in a loan modification to supporting legal action to delay or defend against foreclosure or to seek relief from unfair or unlawful practices by lenders, servicers, and related institutions.
This report is different because it includes a section that discusses the contemplated profit that was to be made by the participants from securitizing a loan. The figures used in the computations are gathered from actual documents. It also states how soon the lender recovered the full amount it originally lent to the borrower instead of the 30 years it usually takes for the loan to be fully paid from the agreed monthly amortizations.
The Comprehensive Audit Report was conceptualized to be what a real audit should be – independent and unbiased, with the auditor or examiner free of any interest in its outcome. It neither attempts to sensationalize its findings nor ignore the present economic ramifications of the crash of the housing market that securitization helped to unfold.
CUSO vs. In-House: Growing Your Member Business Lending PortfolioLibby Bierman
In recent years, an increasing number of credit unions are starting, or expanding, their Member Business Lending (MBL) portfolios. This presents a number of challenges, including having the proper systems in place. And a decision must be made to outsource the function to a Credit Union Service Organization (CUSO), build it internally, or some combination of the two. In this webinar, Ancin Cooley, principal of Synergy Credit Union Consulting, and Mike Ford, director at Sageworks, discussed the growth in MBL, benefits and challenges of both CUSOs and internal departments, and provide recommendations for continued growth.
Discover the new world of credit. In this PowerPoint developed for high school students, be introduced to the vocabulary of credit, what it is, and why it is important to maintain a good credit score.
A slide deck from GBRW covering the key principles of problem loan management, based on GBRW's extensive experience with Non-Performing Loan (NPL) management, restructuring and work-out assignments.
Ratio Analysis and Business Performance – Why Should I Care – Part 2?McKonly & Asbury, LLP
The webinar is hosted by David Blain, Partner and Director of McKonly & Asbury’s Entrepreneurial Services Group, and Eric Fischer, Benefits Advisor at American Family Life Assurance Company of Columbus (Aflac).
This webinar is a continuation of the first webinar hosted on May 30, 2019. This webinar focuses on debt covenant and leverage ratios most used and reviewed by banks and other lending institutions. The webinar also focuses on how banks and lending institutions view these ratios and how to best prepare and present your business for compliance with these ratios.
The new Bank Secrecy Act (BSA) rule codifies existing regulatory expectations regarding customer due diligence and imposes a new requirement on covered financial institutions. Learn about the new requirement to identify and verify the natural persons behind institutions’ legal entity customers.
MODULE 3:
Credit Risks Credit Risk Management models - Introduction, Motivation, Funtionality of good credit. Risk Management models- Review of Markowitz’s Portfolio selection theory –Credit Risk Pricing Model – Capital and Rgulation. Risk management of Credit Derivatives.
When you are dealing with a problem loan, this process will help you gather and understand the facts, analyze the problem, and enable you to make a recommendation to correct the problem.
Many community banks have concerns over the implementation of the CECL standard. Learn about the concerns bankers have and the five actions you should take today.
Appraisals continue to be a very important and required valuation tool for both owner-occupied and investor real estate transactions. This excerpt from the RMA Credit Risk Council’s “2017 Industry Insights: Perspectives from the Front Line,” talks about three appraisal issues that could make or break a loan.
"ALLL" About Disclosure Reports: Key Issues to KnowLibby Bierman
This session reviews the financial reporting disclosures that were added to bank and credit union's responsibility in 2011. The slides show example reports for requirements including Credit Quality Indicators
Aging of Past Due Receivables
Nature and extent of Troubled Debt Restructures and their effect on the ALLL
Listing of significant loan purchases and sales of loans
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
BYD SWOT Analysis and In-Depth Insights 2024.pptxmikemetalprod
Indepth analysis of the BYD 2024
BYD (Build Your Dreams) is a Chinese automaker and battery manufacturer that has snowballed over the past two decades to become a significant player in electric vehicles and global clean energy technology.
This SWOT analysis examines BYD's strengths, weaknesses, opportunities, and threats as it competes in the fast-changing automotive and energy storage industries.
Founded in 1995 and headquartered in Shenzhen, BYD started as a battery company before expanding into automobiles in the early 2000s.
Initially manufacturing gasoline-powered vehicles, BYD focused on plug-in hybrid and fully electric vehicles, leveraging its expertise in battery technology.
Today, BYD is the world’s largest electric vehicle manufacturer, delivering over 1.2 million electric cars globally. The company also produces electric buses, trucks, forklifts, and rail transit.
On the energy side, BYD is a major supplier of rechargeable batteries for cell phones, laptops, electric vehicles, and energy storage systems.
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
Financial Assets: Debit vs Equity Securities.pptxWrito-Finance
financial assets represent claim for future benefit or cash. Financial assets are formed by establishing contracts between participants. These financial assets are used for collection of huge amounts of money for business purposes.
Two major Types: Debt Securities and Equity Securities.
Debt Securities are Also known as fixed-income securities or instruments. The type of assets is formed by establishing contracts between investor and issuer of the asset.
• The first type of Debit securities is BONDS. Bonds are issued by corporations and government (both local and national government).
• The second important type of Debit security is NOTES. Apart from similarities associated with notes and bonds, notes have shorter term maturity.
• The 3rd important type of Debit security is TRESURY BILLS. These securities have short-term ranging from three months, six months, and one year. Issuer of such securities are governments.
• Above discussed debit securities are mostly issued by governments and corporations. CERTIFICATE OF DEPOSITS CDs are issued by Banks and Financial Institutions. Risk factor associated with CDs gets reduced when issued by reputable institutions or Banks.
Following are the risk attached with debt securities: Credit risk, interest rate risk and currency risk
There are no fixed maturity dates in such securities, and asset’s value is determined by company’s performance. There are two major types of equity securities: common stock and preferred stock.
Common Stock: These are simple equity securities and bear no complexities which the preferred stock bears. Holders of such securities or instrument have the voting rights when it comes to select the company’s board of director or the business decisions to be made.
Preferred Stock: Preferred stocks are sometime referred to as hybrid securities, because it contains elements of both debit security and equity security. Preferred stock confers ownership rights to security holder that is why it is equity instrument
<a href="https://www.writofinance.com/equity-securities-features-types-risk/" >Equity securities </a> as a whole is used for capital funding for companies. Companies have multiple expenses to cover. Potential growth of company is required in competitive market. So, these securities are used for capital generation, and then uses it for company’s growth.
Concluding remarks
Both are employed in business. Businesses are often established through debit securities, then what is the need for equity securities. Companies have to cover multiple expenses and expansion of business. They can also use equity instruments for repayment of debits. So, there are multiple uses for securities. As an investor, you need tools for analysis. Investment decisions are made by carefully analyzing the market. For better analysis of the stock market, investors often employ financial analysis of companies.
The European Unemployment Puzzle: implications from population agingGRAPE
We study the link between the evolving age structure of the working population and unemployment. We build a large new Keynesian OLG model with a realistic age structure, labor market frictions, sticky prices, and aggregate shocks. Once calibrated to the European economy, we quantify the extent to which demographic changes over the last three decades have contributed to the decline of the unemployment rate. Our findings yield important implications for the future evolution of unemployment given the anticipated further aging of the working population in Europe. We also quantify the implications for optimal monetary policy: lowering inflation volatility becomes less costly in terms of GDP and unemployment volatility, which hints that optimal monetary policy may be more hawkish in an aging society. Finally, our results also propose a partial reversal of the European-US unemployment puzzle due to the fact that the share of young workers is expected to remain robust in the US.
US Economic Outlook - Being Decided - M Capital Group August 2021.pdfpchutichetpong
The U.S. economy is continuing its impressive recovery from the COVID-19 pandemic and not slowing down despite re-occurring bumps. The U.S. savings rate reached its highest ever recorded level at 34% in April 2020 and Americans seem ready to spend. The sectors that had been hurt the most by the pandemic specifically reduced consumer spending, like retail, leisure, hospitality, and travel, are now experiencing massive growth in revenue and job openings.
Could this growth lead to a “Roaring Twenties”? As quickly as the U.S. economy contracted, experiencing a 9.1% drop in economic output relative to the business cycle in Q2 2020, the largest in recorded history, it has rebounded beyond expectations. This surprising growth seems to be fueled by the U.S. government’s aggressive fiscal and monetary policies, and an increase in consumer spending as mobility restrictions are lifted. Unemployment rates between June 2020 and June 2021 decreased by 5.2%, while the demand for labor is increasing, coupled with increasing wages to incentivize Americans to rejoin the labor force. Schools and businesses are expected to fully reopen soon. In parallel, vaccination rates across the country and the world continue to rise, with full vaccination rates of 50% and 14.8% respectively.
However, it is not completely smooth sailing from here. According to M Capital Group, the main risks that threaten the continued growth of the U.S. economy are inflation, unsettled trade relations, and another wave of Covid-19 mutations that could shut down the world again. Have we learned from the past year of COVID-19 and adapted our economy accordingly?
“In order for the U.S. economy to continue growing, whether there is another wave or not, the U.S. needs to focus on diversifying supply chains, supporting business investment, and maintaining consumer spending,” says Grace Feeley, a research analyst at M Capital Group.
While the economic indicators are positive, the risks are coming closer to manifesting and threatening such growth. The new variants spreading throughout the world, Delta, Lambda, and Gamma, are vaccine-resistant and muddy the predictions made about the economy and health of the country. These variants bring back the feeling of uncertainty that has wreaked havoc not only on the stock market but the mindset of people around the world. MCG provides unique insight on how to mitigate these risks to possibly ensure a bright economic future.
how can i use my minded pi coins I need some funds.DOT TECH
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. 👇 I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
How to get verified on Coinbase Account?_.docxBuy bitget
t's important to note that buying verified Coinbase accounts is not recommended and may violate Coinbase's terms of service. Instead of searching to "buy verified Coinbase accounts," follow the proper steps to verify your own account to ensure compliance and security.
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
Introduction to Indian Financial System ()Avanish Goel
The financial system of a country is an important tool for economic development of the country, as it helps in creation of wealth by linking savings with investments.
It facilitates the flow of funds form the households (savers) to business firms (investors) to aid in wealth creation and development of both the parties
Best frenemies how to manage your relationship with regulatory examiners
1. How to Manage
Your
Relationship
with Regulatory
Examiners
Valerie Edgington www.linkedin.com/in/valerie1120/
2. Who and How Often?
Federal Credit Unions:
National Credit Union Administration (NCUA).
State Credit Unions:
Ohio Division of Financial Institutions (ODFI).
12 month exam schedule.
Occur more or less frequently depending on risk profile and
other issues.
Page 2
3. Who’s In Charge?
Sometimes “joint” exam with federal and state regulators.
State‐chartered federally‐insured credit unions (FISCUs) are
subject to NCUA’s examination.
“Document of Cooperation” between NCUA and State Credit
Union Supervisors (NASCUS) coordinates NCUA’s and state
examiners’ oversight of FISCUs.
“It is recognized and agreed that the regulation and
examination of state‐chartered credit unions properly
belongs to and is the primary responsibility of the state.”
NCUA will independently perform “insurance review” of
FISCUs.
Page 3
4. Who’s In Charge?
NCUA will immediately inform state regulators of NCUA’s
findings and recommendations as a result of independent
insurance review.
NCUA’s policy to hold conference with credit union officials
within 30 days of completing insurance review.
NCUA does not discuss with, or disclose to, FISCU officials the
CAMEL ratings it examiner assigned to the credit union, which
may differ from those assigned by the state examiner.
If state law or regulation does not prohibit a credit union policy
or action that NCUA considers unsafe, the NCUA examiner will
cite it as a problem in the report to officials and will expect to
see corrective action taken.
Page 4
6. NCUA’s Response to GAO 12‐247
“NCUA is committed to proactively addressing
safety and soundness problems at credit
unions.”
“NCUA will continue to build on its current
enforcement efforts in requiring credit unions
to promptly correct problems at the earliest
possible time.”
“Consistent with GAO’s findings, NCUA will
also continue to take steps to strengthen the
effectiveness of our enforcement program,
striving to develop new predictive PCA
measures that identify emerging problems
earlier and better protect the Share Insurance
Fund from losses.”
Page 6
9. Required Questionnaires
Minimum Required Exam Questionnaires
BSA – Bank Secrecy Act Interest Rate Risk ‐ A Ln – Participation Loans
5300 Review Interest Rate Risk – B Ln – Controls
SC Audit & Verification Interest Rate Risk – C Ln – Real Estate – IC
SAFE Act Interest Rate Risk – D Ln – Indirect Lending – IC
Red Flag Questionnaire Liquidity ‐ A Ln – Sub‐Prime Lending – IC
Credit CARD Act Liquidity – B Ln – Home Equity – IC
Foreclosure Procedures Liquidity – C Ln ‐ Business Loans – IC
Unlawful Internet Gambling Sh – Controls Ln – SBA – Parts I and II
FFIEC Authentication Sh – Internal Controls IC – Lines of Credit
Third‐Party Relationships IC – Financial Triggers IC – Cash
Page 9
10. Examination vs. Audit
Examinations: Audits:
Performed by regulator. Outside company
retained by credit union.
Safety & soundness.
Accuracy of accounting
Overall controls. records or procedures &
Regulation Compliance. records related to a
particular regulation (i.e.
Recordkeeping. BSA).
Internal controls.
Page 10
14. Credit Union Examination Rights
Credit unions have the right to:
1. Manage risk without being directed by examiners to eliminate it.
NEG Pg. 1‐3: Examiners should not “insist that a credit union eliminate risk but,
instead, should ensure that credit unions identify and manage their risks. The desired
reward for taking risk is stable profitability and increased net worth. Credit unions
must balance risk and reward responsibly.”
2. Respectful conduct from their examiners.
NEG Pgs. 21‐3; 21‐4: Credit unions, as well as regulators, expect examiners to act
professionally – which they do most of the time, according to credit unions. However,
if a credit union feels that an examiner has stepped over the line in terms of conduct
involving the credit union, the credit union should report the incident to the
supervisor examiner or regional office, without fear of retaliation.
3. Be examined by well‐trained, competent examiners who understand the unique
characteristics of credit unions. Page 14
15. Credit Union Examination Rights
Credit unions have the right to:
4. Meet and discuss examiner findings, conclusions, directives and administrative
actions with the examiner, or privately among themselves without the examiner
present. Credit union officials should be able to have management staff present at
the officials’ discretion.
NEG Pgs. 1‐11; 1‐15, 21‐2 & 21‐3: According to NCUA’s Examiner’s Guide, examiners
are instructed to provide time throughout the examination process for discussion
with management and officials regarding developments and findings in the
examination. Examiners are encouraged to provide credit union officials with a draft
copy of the examination report and give officials sufficient time to review it before
the joint conference or exit interview. As the Examiner’s Guide notes, ―Nothing
presented at the joint conference, exit interview, or in the examination report should
surprise the [credit union’s] officials.‖ It is equally important that credit union
officials not surprise examiners and that they take advantage of opportunities to
meet with examiners and discuss issues throughout the examination process.
Page 15
16. Credit Union Examination Rights
Credit unions have the right to:
5. Question, and seek corrections to, examiner findings, conclusions and directives.
NEG Pg. 1‐15: Accuracy is an essential component of strong safety and soundness
regulation. Examiners are human and all humans make mistakes. It is not only
appropriate but very important that credit unions work with their examiner to
ensure all reports are as accurate and timely as possible and that all directives are
based on accurate information.
6. Provide alternative and/or additional data, conclusions and solutions to address
problems indentified by the examiner.
NEG Pgs. 1‐11; 2‐3; 3‐10 & 21‐6: According to the Examiner’s Guide, examiners are
not expected to dictate credit union policies but rather should work with credit union
officials to reach a favorable outcome. The Examiner’s Guide emphasizes cooperation
and coordination between examiners and credit union officials, which should include
flexibility for credit union management to provide alternative perspectives and data
as well as alternative solutions to problems—as long as such alternatives are
factually based and appropriate for the situation.
Page 16
17. Credit Union Examination Rights
Credit unions have the right to:
7. Know the specific authority or legal basis for an examiner’s directive.
NEG Pg. 20‐7: The Examiner’s Guide makes it clear that examiners must be willing and
able to provide to credit union officials the legal authority for the action they are
suggesting or directing the credit union to take. In addition, examiners do not have
flexibility to insist on actions or policies that are counter to or inconsistent with
statutes, agency policy, or GAAP.
8. Receive clearly written examination reports, notices, etc. on a timely basis.
NEG Pg. 20‐1: Credit unions should not be expected to comply with directives that
are not in writing. In order for the credit union’s record of performance, including
efforts to address problem areas, to be as accurate as possible, directives should be
provided in writing to the credit union and included in the credit union’s examination
history.
Page 17
18. Credit Union Examination Rights
Credit unions have the right to:
9. Receive exam reports, findings, directives, and administrative actions that are
based on all relevant facts.
10. Be evaluated on their own strengths and weaknesses and not solely on the basis of
regulator concerns about trends.
NEG Pg. 3‐5: While examiners must be mindful of problems and conditions in their
regions and even across the country, it is essential for the accuracy of each credit
union’s examination report that the examiner’s assessment of a credit union reflects
an accurate depiction of the performance and operations of the credit union under
review.
11. Be evaluated for progress toward objectives that are realistic and achievable,
proportionate to the risk presented.
12. Examination findings and directives that are risk prioritized.
Page 18
19. Credit Union Examination Rights
Credit unions have the right to:
13. Appeal examiner findings, conclusions, or directives without retaliation from their
regulator.
It is clear that under the FCU Act, agency policy and practice, credit unions have the
right to appeal ―material supervisory determina ons, including decisions to require
prompt corrective action‖ to the NCUA Board. As discussed in this Section, matters
that may be appealed include, for example, cease and desist orders, removal of
officials, and conservatorships. Credit unions also have the right to appeal material
examination report findings, conclusions, and directives from the examiner.
Documents of Resolu on and LUAs are not generally ―appealable‖ because they are
technically voluntary agreements, but the credit union should be able to appeal to
the regional director as part of the DOR or LUA negotiation process.
Page 19
20. Credit Union Examination Rights
Credit unions have the right to:
14. Have instructions on how to appeal, detailed on every exam report form provided
to credit unions.
NEG Pg. 17‐1: NCUA’s process for allowing an appeal is far from clear. NCUA and
state regulators should ensure that all examination report forms which examiners
provide to credit unions include sufficiently detailed information as to which issues
may be appealed or challenged and the process for making such an appeal. CUNA
and the Leagues are pursuing greater transparency in the appeals process.
15. Record meetings with examiners and other agency personnel.
NEG Pg. 21‐2: The Examiner’s Guide states that credit unions often use tape
recorders to record their meetings at the joint conference, and that the NCUA
examiners usually agree to the request, and may request a copy of the tape or
transcript. A recorded meeting provides an objective transcript of the discussion
between the examiner and the credit union officials.
Page 20
21. Credit Union Examination Rights
Credit unions have the right to:
16. Have a representative, such as attorney, present during meetings with the examiner
and other regulatory personnel.
NEG Pg. 21‐6: The Examiner’s Guide states that credit union officials have the right to
invite other persons to the joint conference, and that an examiner will rarely object
to the attendance of any outside individual. Proper communication about the
attendees in advance will facilitate the meeting.
17. Have any published orders – such as consent orders – address only facts and not
conjecture or speculation by the examiner.
18. Have confidential, non‐discoverable communications with their legal counsel
regarding examination issues.
19. Develop and use “high‐level” policies, which should be separate and distinct from
detailed procedures.
Page 21
22. Credit Union Examination Rights
Credit unions have the right to:
20. Have a lead examiner that is state or federal, consistent with the credit union’s
charter type (except with respect to some insurance reviews performed solely by
NCUA staff).
NEG Pg. 22‐B3: NCUA appears to be compelled to accompany state regulators during
the examination of state‐chartered credit unions, par cularly on federal ―hot
button‖ issues such as MBL and indirect lending. Thus, it is important that the lead
examiner be comparable to the credit union’s charter type. It is also important that
the state regulator—not NCUA—be responsible for assigning the credit union’s
CAMEL rating during an examination.
21. Know the timing of when NCUA will publish a Letter of Understanding and
Agreement.
Page 22
23. Credit Union Examination Rights
Credit unions have the right to:
22. Defer to their CPA if there is a disagreement between the officials and their
regulator regarding issues related to U.S. generally accepted accounting principles.
NEG Pgs. 5A‐4 & 7‐28: Credit unions over $10 million in assets are required to follow
GAAP and a credit union’s CPA is responsible for ensuring that the credit union’s
activities and financial statements are in compliance with GAAP. Therefore, rather
than the regulator becoming involved in the specific accounting issues of numerous
credit unions, the examiner should not seek to override the credit union’s CPA when
disagreement on accounting issues arise, absent clearly erroneous guidance from the
CPA. Such practice will benefit not only the credit union but also the regulator by
freeing up its resources.
Page 23
24. Credit Union Examination Rights
Credit unions have the right to:
23. Have communication (i.e., discussion of draft findings) with their examiner prior to
final issuance of the examination report.
NEG Pg. 21‐1: The NCUA Examiner’s Guide states that examiners should set aside
time periodically to discuss with management and officials developments in the
examination.‖ NEG page 21‐1. In addition, an examiner should provide credit union
officials and management sufficient time to review it before the joint conference or
exit interview.‖ NEG page 20‐1.
24. Have directives from examiners (including verbal and written comments) be
consistent with regulatory requirements, policies and Letters to Credit Unions.
NEG pages 3‐1; 6‐15; 6‐16; 6‐20; 7‐35; 9A‐18; & 10‐1 – 10‐14: While this seems like
an obvious right, this is frequently raised by credit unions across the country. NCUA
examiners must follow the guidelines in the Letters to Credit Unions. For example,
the Examiner’s Guide states that credit unions must follow Letters to Credit Unions in
areas such as CAMEL ratings, risk‐based lending, and risk management.
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25. Enforcement Actions
Prompt Corrective Action.
Document of Resolution (DOR).
Letters of Understanding and Agreement (LUAs).
Cease and Desist Orders.
Civil Monetary Penalties.
Removal of Officials/Prohibition Orders.
Termination of Insurance.
Conservatorship.
Revocation of Charter.
Liquidation.
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31. Letters of Understanding
and Agreement
Letter of Understanding and Agreement (LUA) is a more formal
supervisory tool.
Negotiated when credit unions have not adequately responded
to less severe measures, such as Documents of Resolution.
“Voluntary” contract between NCUA and a credit union and/or
its officials, in which the credit union or officials agree to take, or
not take, certain specified actions.
Severe consequences for failing to follow and fulfill terms LUA.
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40. Other Administrative Appeals
Credit unions may also appeal other decisions:
For MBL decisions and waivers and foreign branching, may
appeal to NCUA Board.
Freedom of Information Act requests can be appealed to
Office of General Counsel.
Appeals of creditor claims in liquidation should following
the administrative review process.
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41. NCUA Ombudsman
NCUA Ombudsman office set up to investigate complaints and
recommend solutions.
Ombudsman does not make decisions regarding complaints but
will help identify options and make recommendations to
involved parties.
Issues or complaints must relate to regulatory issues that were
first appeals, and were not resolved at the operational and
regional levels.
Credit union must submit an Ombudsman Complaint Form.
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42. NCUA Ombudsman
Ombudsman can help explain NCUA’s regulations or help raise
systemic or recurring issues.
Ombudsman does not handle matters that are:
Subject to formal review as set forth in NCUA regulations or
policies.
Involving an enforcement action where a Notice of Charges
has been filed, such as an LUA.
In litigation.
Involving a conservatorship or liquidation.
Within the Inspector General’s jurisdiction.
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44. Credit Union Examination
Best Practices
1. Understand the scope of the examination. Activities posing the
highest risk will receive the highest amount of scrutiny.
2. Use past exams to prepare for future exams. Ensure there has
been a resolution of prior exam and audit issues.
3. Ensure credit union officials are fully informed regarding any
areas of material weakness at the credit union and the credit
union’s risk management program.
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45. Credit Union Examination
Best Practices
4. Ensure the credit union’s policies and practices are appropriate
for the credit union’s risk profile, up‐to‐date, and consistent
with legal requirements.
5. Work with the examiner to provide necessary financial data and
access to personnel on a timely basis.
6. Seek to work with the examiner on a professional basis and be
willing to meet and listen to his/her concerns,
recommendations and directives.
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46. Credit Union Examination
Best Practices
7. Do not hesitate to provide reasonable supplementary
information to the examiner or to seek corrections in examiner
reports, findings, or directives that the credit union feels are
incorrect.
8. Do not hesitate to point out discrepancies between the
examiner’s directives and the regulator’s Examiner’s Guide or
legal requirements.
9. Do not hesitate to appeal examiner or regional office decisions
on material, supervisory issues that the credit union feels are in
error, unrealistic, inappropriate or inconsistent with its
regulator’s policies or procedures.
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47. Credit Union Examination
Best Practices
10. Be specific. When an examiner indicates that you must/must
not do a specific thing, ask for the specific legal or regulatory
citation that is the basis for the recommendation.
11. Use CUNA’s Examination and Supervision Issues Reporting Form
after each exam to report on your latest examination
experiences.
12. Seek the advice of legal counsel prior to entering into any type
of legally binding agreement (LUA, etc.).
13. Maintain open communications with examiner before, during
and after the exam.
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49. Resources
CUNA Supervisory Issues and Examinations: Guidance For Credit Unions During the
Current Economic Times and Beyond
http://www.cuna.org/reg_advocacy/member/download/examsuper_issuesguide_20
11‐01.pdf
CUNA’s Examination Experience Reporting Form. Click to report on your credit
union’s examination experiences
http://www.cuna.org/initiatives/member/exam_supervisory.html
CUNA’s Examination & Supervisory Resources for Credit unions
http://cuna.org/reg_advocacy/member/hot_topic/exam_supervisory_resc.html
CUNA’s Due Diligence Resources for Credit Unions
http://www.cuna.org/initiatives/due_diligence.html
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50. Resources
“Everything You Ever Wanted to Know about Exam Appeals” NCUA’s Newsletter
http://www.ncua.gov/NewsPublications/News/Newsletters/NCUA_Newsltr_
March10_5P.pdf
Guidelines for NCUA’s Supervisory Review Committee (RegFlex), IRPS 02‐1
http://www.ncua.gov/Legal/Documents/IRPS/IRPS2002‐1.pdf
Guidelines for NCUA’s Supervisory Review Committee, IRPS 95‐1
http://www.ncua.gov/Legal/Documents/IRPS/IRPS1995‐1.pdf
NCUA Examiner’s Guide
http://www.ncua.gov/Legal/GuidesEtc/Pages/Examiners‐Guide.aspx
Administrative Actions – Chapter 30 of NCUA Examiner’s Guide
http://www.ncua.gov/Legal/GuidesEtc/ExaminerGuide/chapter30.pdf
NCUA Aires Exam Questionnaires
http://www.ncua.gov/Resources/CUs/Pages/AIRES.aspx
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