Episodes

  • How NCUA Evaluates Your Credit Union Earnings

    How NCUA Evaluates Your Credit Union Earnings
    Feb 19 2025

    www.marktreichel.com

    https://www.linkedin.com/in/mark-treichel/


    This episode covers NCUA's Guidance to Examiners on how they should evaluate credit union earnings.


    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 achieves 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.
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    15 mins
  • Enterprise Risk Management: NCUA's Supervisory Letter

    Enterprise Risk Management: NCUA's Supervisory Letter
    Feb 12 2025

    www.marktreichel.com

    https://www.linkedin.com/in/mark-treichel/


    NCUA's Supervisory Letter on Enterprise Risk Management. Audiobook style.


    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 achieves 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.
    Show more Show less
    14 mins
  • Operational Risks: Cyber, Fraud Risk Innovation & More

    Operational Risks: Cyber, Fraud Risk Innovation & More
    Feb 5 2025

    www.marktreichel.com

    https://www.linkedin.com/in/mark-treichel/



    ## Episode Overview
    This episode covers the OCC's Fall 2024 Operational Risk report, examining key areas of focus for financial institutions including cybersecurity, operational resilience, innovation, and fraud risk management.

    ## Key Topics Covered

    ### Cybersecurity
    - Elevated operational risks due to evolving cyber threats and AI technology
    - Importance of third-party risk management in the expanding cyber threat landscape
    - Critical security measures including MFA, system hardening, and patch management
    - New post-quantum computing encryption standards from NIST

    ### Operational Resilience
    - Focus on mitigating disruption events and cyber incidents
    - Case study from mid-2024 involving global disruptions from flawed software updates
    - Importance of testing and validating resilience plans

    ### Innovation and New Services
    - Banks' adoption of new technologies and fintech partnerships
    - Cautious approach to AI and machine learning implementation
    - Considerations for digital asset custody and cryptocurrency services
    - Challenges of maintaining legacy systems while pursuing digitization

    ### Fraud Risk Management
    - Evolution of fraud prevention strategies
    - Importance of customer identification and verification
    - Implementation of transaction verification and authentication controls
    - Role of technology in flagging suspicious activity

    ### Third-Party Risk Management
    - Continuous lifecycle approach to third-party relationships
    - Risk management processes scaled to bank size and complexity
    - Importance of ongoing monitoring as relationships evolve

    ## Resources Mentioned
    - Credit Union Exam Solutions Incorporated
    - Mark Treichel's Website: marktreichel.com
    - "With Flying Colors" Podcast

    ## Contact Information
    - LinkedIn: Mark Treichel
    - Website: marktreichel.com

    ## Disclaimer
    This podcast is educational and does not constitute legal advice. All opinions expressed are for informational purposes only.


    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 achieves 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.
    Show more Show less
    11 mins
  • Credit Risk Today: an OCC Perspective

    Credit Risk Today: an OCC Perspective
    Jan 29 2025

    www.marktreichel.com

    https://www.linkedin.com/in/mark-treichel/


    The full OCC report can be found HERE


    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 achieves 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.
    Show more Show less
    6 mins
  • NCUA THIRD PARTY RELATIONSHIP GUIDANCE

    NCUA THIRD PARTY RELATIONSHIP GUIDANCE
    Jan 22 2025

    www.marktreichel.com

    https://www.linkedin.com/in/mark-treichel/


    https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/evaluating-third-party-relationships-0


    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 achieves 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.
    Show more Show less
    28 mins
  • Cease & Desist Orders - NCUA's Enforcement Manual

    Cease & Desist Orders - NCUA's Enforcement Manual
    Jan 15 2025
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers N C U A’s Authority to issue cease and desist orders as outlined in its enforcement manual. The following is an audio version of that portion of the manual. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now cease and desist orders.Cease and Desist Order 1. What is a Cease and Desist Order?A Cease and Desist (C AND D) Order normally requires the credit union to stop illegal or unsafe or unsound activities which caused or is likely to cause more than a minimal financial loss to, or have a significant adverse effect on, the insured credit union. A document called Notice of Charges and Hearing sets out the specific charges and statement of facts supporting the charges. The Notice also arranges for an administrative hearing. The C AND D contains the required corrective actions. The C AND D action is designed to address only actions necessary to correct the most significant items. A C AND D Order can be issued against an insured credit union or an institution-affiliated party. The term institution-affiliated party means any of the following: ► Any committee member, director, officer, or employee of, or agent for, an insured credit union.► Any consultant, joint venture partner, and any other person as determined by the N C U A Board who participates in the conduct of the affairs of an insured credit union.► Any independent contractor who knowingly or recklessly participates in any violation of any law or regulation, any breach of fiduciary duty, or any unsafe or unsound practice.The types of violations most likely to be remedied by a C AND D Order include: ► Failure to maintain adequate books and records.► Deficient appraisal reports.► Transactions involving conflicts of interest.► Inadequate due diligence.► Inadequate control and oversight of operations. There is a great deal of flexibility in what actions N C U A may require. In addition to ordering a cessation of certain activities, a C AND D Order may require affirmative corrective action, including: ► Making restitution or provide reimbursement, indemnification, or guarantee against loss under specific conditions.► Restricting growth.► Rescinding an agreement or contract.► Disposing of any loan or asset.► Employing qualified officers or employees.► Taking such other action N C U A determines to be appropriate. Orders to Cease and Desist are issued pursuant to the FCU Act section206(e), 12 U.S.C.section1786(e). The provisions for the C AND D Order are set out in article-by-article form and prescribe those restrictions and corrective and remedial measures necessary to correct deficiencies or violations in the credit union and return it to a safe and sound condition. Violations of a C AND D Order can provide the legal basis for assessing civil money penalties (CMPs) against directors, officers, and other institution-affiliated parties. A C AND D Order may also be enforced through application to a U.S. district court. Moreover, a willful violation of a Final C AND D Order is itself grounds for conservatorship under the FCU Act section206(h)(1)(D), 12 U.S.C. section1786(h)(1)(D). There are three types of cease and desist orders available to N C U A: a. Consent Order A Consent Order is an Order to Cease and Desist that is entered into and becomes final through the board of directors' execution of a Stipulation and Consent document on behalf of the credit union. This type of order also requires the issuance of a Notice of Charges. The N C U A Board issues the Consent Order without the need for an administrative hearing. The Consent Order becomes effective at the time specified in the Order. b. Final (Permanent) Cease and Desist OrderAside from its title, a Final C AND D Order is identical in form and legal effect to a Consent Order. However, a Final C AND D Order is imposed on an involuntary basis after issuance of a Notice of Charges, a hearing before an administrative law judge,and a final decision and order issued by the N C U A Board. A Final C AND D Order is effective 30 days after service upon the credit union. Any Final C AND D Order is subject to review by a U.S. Court of Appeals. c. Temporary Cease and Desist Order A Temporary C AND D Order is an interim order issued ...
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    13 mins
  • NCUA's Supervisory Priority Letter to Credit Unions

    NCUA's Supervisory Priority Letter to Credit Unions
    Jan 13 2025
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This episode covers N C U A's 2025 Supervisory Priorities. The following is an audio version of Letter to Credit Unions 25-CU-01. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the Supervisory Priority Letter. Dear Boards of Directors and Chief Executive Officers: This letter outlines the N C U A's supervisory priorities and other updates to the agency's 2025 examination program. Our priorities focus on the areas posing the highest risk to credit union members, the credit union industry, and the National Credit Union Share Insurance Fund (Share Insurance Fund). There continued to be signs of financial stress on credit union balance sheets during 2024. Aggregate loan performance began to deteriorate in 2022, and the trend has continued through 2024. The overall loan delinquency rate is currently at its highest point since year-end 2013, while the rolling 12-month net charge-off rate is at its highest point since the second quarter of 2012. Additionally, the return on average assets continues to experience pressure from the interest rate environment and provision for loan and lease loss expense. Even considering these trends, the credit union system remains stable and relatively resilient against economic disruptions. With that economic landscape in mind, below are the N C U A's primary areas of supervisory focus for 2025. Supervisory Priorities for 2025 Credit Risk Credit risk will remain a supervisory priority for 2025. Loan growth moderated during 2024 while overall delinquencies and charge-offs increased. Most notably, the performance within credit card portfolios has deteriorated much more rapidly than other aspects of federally insured credit union loan portfolios. The current delinquency rate and rolling 12-month net charge-off rate for credit card loans both exceed the peak that was reached during the global financial crisis fifteen years ago. Used vehicle loan performance has also materially deteriorated. The delinquency rate and rolling 12-month net charge-off rates for used vehicle loans are currently at the highest levels on record. To address these matters, N C U A examiners will continue to review your credit union's lending and related risk-management practices. This priority will include reviewing the sufficiency of your loan underwriting standards, collection programs, Allowance for Credit Losses reserves, charge-off practices, management and board reporting, and management of any concentrations of credit risk. To the extent possible, examiners will also review your credit union's third-party risk-management practices when lending, servicing, or collection functions are outsourced. Moreover, it is important for your credit union to work with borrowers encountering financial difficulties. These efforts are consistent with the credit union system's statutory mission of meeting the credit and savings needs of members, especially those of modest means. Accordingly, examiners will assess your credit union's modification and workout strategies for borrowers experiencing financial difficulty, including assessing whether your credit union's efforts were reasonable and conducted with proper controls and management oversight. For more resources, refer to the Examiner's Guide and the following Letters to Credit Unions: 23-CU-05, Commercial Real Estate Loan Accommodations and Workouts23-CU-04, Update to Interagency Policy Statement on Allowances for Credit Losses14-CU-08, Home Equity Lines of Credit Nearing Their End-of-Draw Period10-CU-03, Concentration Risk09-CU-19, Evaluating Residential Real Estate Loan Modification Programs07-CU-13, Evaluating Third Party Relationships03-CU-01, Loan Charge-off Guidance91-CU-120, Interest Rate Adjustment Errors for A R M Loans Balance Sheet Management and Risk to Earnings and Net Worth Credit unions are exposed to various risks affecting their earnings and net worth. Among the most significant are credit, liquidity, and market risk. These risks are tied to the institution's ability to manage its financial assets and liabilities and have a direct effect on earnings and net worth. For credit unions, the primary market risk element is interest rate risk. Interest rate changes can affect the income credit unions generate from their lending and funding activities, which can affect the credit union's ability to build net worth. Loan losses can also diminish a ...
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    15 mins
  • Increased External Fraud Activity Targeting the Federal Banking System: OCC

    Increased External Fraud Activity Targeting the Federal Banking System: OCC
    Jan 8 2025
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This episode covers A portion of The O C C's Semiannual risk perspective Special topic Increase fraud targeting the federal banking system. The following is an audio version of that topic. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the letter. The special topic focuses on the increasing trend in external fraud activity targeting consumers and the federal banking system. The frequency of both traditional and novel, more sophisticated fraud activities targeting customers and banks continues to increase. Banks should maintain sound fraud risk management practices through prudent controls and appropriate fraud monitoring capabilities to identify, investigate, mitigate, and report fraudulent activity. Banks can also support their customers by providing educational information about trending fraud activities and ways to protect themselves. Criminals continue to exploit traditional payment methods through check and wire transfer schemes. The Financial Crimes Enforcement Network (F I N C E N) September 2024 "Financial Trend Analysis" analyzed threat patterns and trend information on mail theft-related check fraud incidents over a six-month period in mid-2023. The report noted that financial institutions filed 15,417 B S A reports on mail theft-related check fraud, 13,618 (88 percent) of which were filed by banks. It described several types of check fraud such as bad actors altering stolen check payees and amounts, using the stolen check to create counterfeit checks, fraudulently signing the check, and selling the check or its identifying information on dark web marketplaces or encrypted social media platforms. Furthermore, the O C C's Customer Assistance Group observed an increase in the number of check fraud-related complaints submitted by consumers over the past year. Federal banking system-related wire transfer complaints that consumers submitted to the Customer Assistance Group reflect an increasing trend. For wire transfer schemes, the fraudster often poses as a trusted business, government agency, or even a bank employee, fabricating scenarios that require immediate action and convincing, with urgency, victims to wire money to a fraudster's account. In most cases, once the wire transfer is complete, the funds cannot be retrieved. While artificial intelligence (A I) can enhance fraud risk management capabilities, reduce costs, and improve efficiency, this and other new technologies are also being used to enable increasingly more sophisticated and frequent fraud tactics. Fraudsters could use A I to implement sophisticated frauds by digitally altering voices, biometric systems, or images (also known as "deepfakes"), or to facilitate social engineering schemes, identity theft, and impersonation of a trusted business or government agency. For example, deepfakes through voice replication have been used to perpetrate fraud by tricking voice biometric systems or by convincing a victim they are dealing with someone they know and trust, such as a family member. Increasing product and service digitization can also heighten fraud risk, including fraud targeting peer-to-peer (P2P) and other fast payment platforms. P2P payment platforms can provide enhanced capabilities and convenience to consumers and other users for managing payments. However, criminals also have exploited the faster, more streamlined payment capabilities and the irreversible and irrevocable nature of these payments. Effective fraud risk management includes appropriate internal controls, such as authentication, customer identification and verification processes, fraud monitoring, and open lines of communication between bank departments responsible for researching unusual activities. It is critical for banks to promptly identify, investigate, and resolve suspicious activities and potential fraudulent concerns. Banks should also continue to promptly identify, investigate, report, and resolve fraud concerns in accordance with applicable laws and regulations, including the B S A, Expedited Funds Availability Act (Regulation C C) and Electronic Fund Transfer Act (Regulation E). Recent increases in the volume of fraud cases have led to heightened unfair or deceptive acts or practices (U D A P) risk as some banks may take prolonged timeframes to complete investigations or implement broad account access limitations, preventing ...
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    7 mins