Episodes

  • NCUA Chairman Harper's Written Testimony Before the House Financial Services Committee

    NCUA Chairman Harper's Written Testimony Before the House Financial Services Committee
    Nov 21 2024

    www.marktreichel.com

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


    # NCUA Chairman's Congressional Testimony: State of Credit Unions in 2024

    ## Episode Overview
    A deep dive into NCUA Chairman Todd M. Harper's testimony before the House Financial Services Committee, covering the current state of the credit union system, key challenges, and regulatory initiatives.

    ## Key Points

    ### Credit Union System Performance
    - Total assets nearly $2.3 trillion
    - Total outstanding loans exceed $1.6 trillion
    - Net worth ratio: 10.84%
    - Return on average assets: 0.69%
    - Warning signs: rising delinquency rates, declining capital levels

    ### Major Concerns
    - One in five credit unions rated as troubled (CAMELS 3, 4, or 5)
    - Number of troubled complex credit unions tripled in Q2 2024
    - Commercial real estate showing stress due to hybrid work environments
    - Rising consumer financial stress affecting loan performance

    ### Cybersecurity Initiatives
    - Deployed updated Information Security Examination procedures
    - Received 1,000+ reportable cyber incidents since September 2023
    - 70% of cyber incidents related to credit union vendors
    - Expanded partnerships with CISA and FBI

    ### Consumer Protection Efforts
    - Focus areas: overdraft programs, fair lending, auto lending
    - Eight credit unions referred to DOJ for discrimination in 2024
    - First-ever race-based redlining settlement against a credit union
    - New requirements for large credit unions to disclose overdraft fees

    ### Minority Depository Institutions (MDIs)
    - 490 MDI credit unions serving 6.6+ million members
    - Combined assets over $90 billion
    - 39 MDIs received nearly $1.4 million in technical assistance grants
    - Average asset size: $183 million

    ### Legislative Requests
    1. Restore third-party vendor oversight authority
    2. Reform Central Liquidity Facility
    3. Provide more flexibility in Share Insurance Fund management
    4. Increase Community Development Revolving Loan Fund to $10 million

    ## Hurricane Response
    - Detailed response to Hurricanes Helene and Milton (Sept/Oct 2024)
    - Provided emergency grants and loans to affected credit unions
    - Extended regulatory filing deadlines
    - Supported cash needs during telecommunications outages

    ## Notable Statistics
    - Share Insurance Fund equity ratio: 1.28%
    - Share Insurance Fund net income: $154.3 million
    - Insured shares and deposits: $1.76 trillion
    - Uninsured shares and deposits: $169.4 billion

    ## Contact Information
    For more information: [ncua.gov](https://ncua.gov)

    ## Additional Resources
    - NCUA's Financial Technology and Digital Asset webpage
    - Credit Union Diversity Self-Assessment tool
    - Automated Cybersecurity Evaluation Toolbox (ACET)

    *Show notes based on testimony delivered November 20, 2024*


    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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    36 mins
  • Civil Money Penalties and NCUA

    Civil Money Penalties and NCUA
    Nov 19 2024
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers N C U A’s Authority to Assess Civil Money Penalties as outlined in its Enforcement Manual. The following is an audio version of 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 civil money penalties. 1. What are civil money penalties?The FCU Act section206(k), 12 U.S.C. section1786(k), contains N.C.U.A.'s authority to issue civil money penalties; N.C.U.A. Rules and Regulations. Section 747, Subpart A, contains the rules and regulations governing civil money penalty administrative hearings. The N.C.U.A.Board may assess civil money penalties against either a credit union or an institution­ affiliated party (see definition of institution-affiliated party above). The FCU Act specifies three tiers of civil money penalties, as follows: ► First tier. Any credit union or institution-affiliated party that violates a law or regulation, a final order of the N.C.U.A. Board, a published agreement with the Board (such as a published Letter of Understanding and Agreement), or a condition imposed in a published writing by the Board in connection with the granting of any application (such as the Insurance Agreement), may receive a penalty of not more than 5,000 dollars for each day of the violation. First tier penalties may apply to credit unions that, even after warnings, repeatedly submit late or substantially inaccurate call reports. ► Second tier. If the credit union or institution-affiliated party commits a first tier violation, and exhibits reckless conduct or a breach of fiduciary duty, and the violation, practice or breach is part of a pattern of misconduct, or causes more than a minimal loss to the credit union, or results in a monetary gain or other benefit to the institution-affiliated party, then the N.C.U.A. Board may assess a civil money penalty of not more than 25,000 dollars per day for each day of the violation. ► Third tier. Any credit union or institution-affiliated party that knowingly commits the first tier violations, knowingly engages in unsafe or unsound practices, knowingly breaches any fiduciary duty, or knowingly or recklessly causes a substantial loss to the credit union or a substantial monetary gain or other benefit to a party because of the violation, breach, or practice, may receive assessment of a civil money penalty of not more than $1,000,000 perday for each day of the violation, or in the case of a credit union, 1 percent of assets, whichever is less. 2. How are civil money penalties assessed?The normal administrative procedure for a civil money penalty action is as follows: 1. The regional director notifies the party of his or her intent to recommend to the N.C.U.A. Board the issuance of a civil money penalty, requesting a written response from the party.2. The N.C.U.A. Board issues a Notice of Assessment, setting forth a statement of the law and facts on which it bases the assessment.3. The assessed party has 90 days to make payment, but may request a hearing within 20 days.4. An administrative law judge will hold a formal hearing if requested.5. After the administrative hearing, the administrative law judge submits a recommended decision to the N.C.U.A. Board.6. The N.C.U.A. Board issues its final order.7. An institution-affiliated party or credit union may appeal to the U.S. Court of Appeals within 20 days of receipt of the final order. This concludes the N.C.U.A. civil money penalty authorities and policies. If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening. 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 expertiseWith 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 ...
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    5 mins
  • NCUA Guidance on Preliminary Warning Letters

    NCUA Guidance on Preliminary Warning Letters
    Nov 12 2024

    www.marktreichel.com

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


    Episode Summary
    This episode covers the National Credit Union Administration's (NCUA) examiner guidance on Preliminary Warning Letters (PWLs) to credit unions, as outlined in the National Supervision Policy Manual.

    ## Key Points

    1. Purpose of Preliminary Warning Letters (PWLs):
    - Issued when a credit union's problems are serious or persistent
    - Used when a credit union's board is unwilling to sign a Letter of Understanding and Agreement (LUA)
    - Supports potential formal administrative action

    2. Content of a PWL:
    - Written from the Regional Director's perspective
    - Lists serious areas of concern and cites relevant regulations
    - Includes required actions and timeframes for resolving issues

    3. Process for Issuing a PWL:
    - Examiners draft PWLs after examinations or supervision contacts
    - Division of Supervision (DOS) reviews and processes for Regional Director approval
    - Can be hand-delivered or mailed, depending on severity of issues

    4. Supervision of Credit Unions with PWLs:
    - Follow-up examinations typically every 120 or 180 days
    - Examiners document compliance with PWL in Status Updates
    - PWLs usually not outstanding for longer than 12 months

    5. Terminating a PWL:
    - Recommended when credit union meets specific performance standards
    - Examiners prepare draft removal letter for Regional Director's signature

    ## Sponsor
    Credit Union Exam Solutions Inc. - Offering assistance with NCUA examinations

    ## Additional Resources
    - Sample PWLs and BSA-specific PWL templates mentioned
    - Reference to NCUA Instruction 4820, Enforcement Manual

    ## Call to Action
    For credit unions needing assistance with exams, contact Mark Treichel on LinkedIn or at marktreichel.com.


    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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    9 mins
  • Involuntary Liquidations - NCUA's Enforcement Manual

    Involuntary Liquidations - NCUA's Enforcement Manual
    Nov 5 2024
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Hello, this is Samantha Shares. This episode covers N C U A’s authority to Involuntarily Liquidate a Credit Union. The following is an audio version of N.C.U.A.’s Liquidation authorities. 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 liquidations. INVOLUNTARY LIQUIDATIONS1. What is the purpose of this chapter?This chapter provides guidance in processing involuntary liquidations. 2. What are the types of involuntary liquidations?a. Title I involuntary Undersection120 of the FCU Act, 12 U.S.C. section1766, the NCUA Board can place a solvent federal credit union into involuntary liquidation for violations of its charter, its bylaws, the FCU Act, or the NCUA Rules and Regulations. Also, under section120, 12 U.S.C. section1766, the NCUA Board can place a federal credit union into involuntary liquidation upon finding that the board or liquidating agent did not conduct a voluntary liquidation in an orderly or efficient manner or in the best interests of the members. The rules and regulations relating to these administrative proceedings are contained in NCUA Rules and Regulations section747, Subpart E. The effect of this action is the elimination of a federal credit union as a legal entity after due process provided for by section120(b) of the FCU Act, 12 U.S.C. section1766, and Part 747, Subpart E, of the NCUA Rules and Regulations. It is the most drastic enforcement action that can be taken against a solvent federal credit union. Since Title I liquidation is not a commonly used administrative action, examiner involvement will differ from case-to-case.b. Title II involuntary Section 207 of the FCU Act, 12 U.S.C. section1787, requires the NCUA Board to close for liquidation any federal credit union it deems bankrupt or insolvent. In these cases, the NCUA Board must also appoint itself as liquidating agent. In addition, the NCUABoard can accept appointment as liquidating agent of a bankrupt or insolvent federally-insured, state-chartered credit union.c. Purchase and assumption A purchase and assumption (P&A) is an action similar to a merger, but unlike a merger the NCUA Board places the credit union into involuntary liquidation first. In a P&A, another credit union or another financial institution assumes all or part of the assets, liabilities, and shares. 3. What are the goals for an involuntary liquidation?The primary goals of an involuntary liquidation are: ► Prompt return of members' shares.► Payment to the creditors.► Disposition of the remaining assets to the NCUSIF. 4. What are the grounds for an involuntary liquidation of an insolvent credit union pursuant to section207 of FCU Act?The grounds for this most severe action is insolvency or bankruptcy as defined insection700.2(e) of NCUA Rules and Regulations. For a liquidation pursuant to section207, 12 U.S.C. 1787, of the FCU Act, the credit union has no right to a pre-closure administrative hearing. The federal credit union's charter is immediately revoked and the credit union is placed into involuntary liquidation. The credit union may, however, challenge the action in U.S. District Court within 10 days. It is critical, therefore, that the finding of insolvency be based upon tangible evidence and indisputable circumstances using the most current information available. The examiner prepares a supplemental memorandum for the liquidation package that contains all significant data to support the recommended action, including an analysis of the various exceptions to insolvency set forth in section700.2(e) of the regulations. It is imperative that the administrative record adequately supports insolvency. The examiner must be prepared to testify in court to establish the reasonableness of the insolvency calculation. For this reason, involuntary liquidations require the concurrence of the Office of General Counsel to ensure that the liquidation package is legally sufficient.A Notice of Revocation of Charter and Involuntary Liquidation and Appointment of a Liquidating Agent will be served on the federal credit union. The order is effective immediately upon service, and all assets, books and records of the credit union immediately become the property of the NCUA. Agents for the Liquidating Agent will be appointed as provided in section207(a) of the FCU Act, 12 U.S.C. section1787. 5. What are the ...
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    10 mins
  • Cyber Security Briefing of the NCUA Board - October 2024

    Cyber Security Briefing of the NCUA Board - October 2024
    Nov 2 2024

    www.marktreichel.com

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


    Show Notes: NCUA Board Cybersecurity Briefing - October 2024

    🎙️ With Flying Colors - A Credit Union Examination Podcast

    Hosted by Samantha Shares

    Sponsored by Credit Union Exam Solutions Inc.

    Episode Overview:

    Join us for a comprehensive breakdown of the NCUA's October 2024 cybersecurity briefing, where key officials provided critical insights into the current threat landscape facing credit unions.

    📊 Key Statistics:

    - 1,072 cyber incidents reported (Sept 2023 - Aug 2024)

    - 742 incidents (70%) involved third-party vendors

    - 13 major service provider events affected multiple credit unions

    - Financial services is 5th most targeted critical infrastructure sector

    - Ransomware demands typically range from $1M-$10M

    🔑 Main Discussion Points:

    1. Current Cyber Threat Landscape:

    - Ransomware attacks

    - Business email compromises

    - ATM security issues

    - Third-party provider outages

    2. Emerging Threats:

    - Malvertising attacks

    - Social engineering tactics

    - Web application vulnerabilities

    3. NCUA Recommendations:

    - Maintain offline encrypted backups

    - Implement zero trust architecture

    - Create incident response plans

    - Strengthen vendor risk management

    🚨 Incident Reporting Requirements:

    - 72-hour reporting window

    - Contact methods:

    - Phone: 1-833-CYBERCU (1-833-292-3728)

    - Email: cybercu@ncua.gov

    - New web form coming December 2024

    📱 Pro Tip: Save the NCUA cyber incident reporting number in your contacts for quick access during emergencies.

    🔗 Resources Mentioned:

    - NCUA Cybersecurity Resources Page

    - Letter to Credit Unions 24-CU-02 (October 21, 2024)

    - NCUA's Automated Cybersecurity Examination Tool (ACET)

    - CISA Cybersecurity Resources

    💡 Key Takeaway:

    Cybersecurity threats to credit unions continue to evolve and increase, with third-party vendors representing a significant vulnerability in the system. Credit unions must remain vigilant and maintain strong cyber hygiene practices.

    📞 Contact Information:

    - For exam assistance: Visit marktreichel.com

    - Connect with Mark Treichel on LinkedIn

    🎧 Next Episode:

    Stay tuned for more insights on credit union examination success strategies.

    #CreditUnions #Cybersecurity #NCUA #FinancialServices #RiskManagement

    Sponsored by Credit Union Exam Solutions Inc. - Over 240 years of combined NCUA experience helping credit unions save time and money on examinations.

    Note: This podcast is educational and does not constitute legal advice.


    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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    1 hr and 4 mins
  • Field of Membership NCUA Board Briefing Audio from October 2024 Meeting

    Field of Membership NCUA Board Briefing Audio from October 2024 Meeting
    Oct 29 2024

    www.marktreichel.com

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


    🎙️ Episode Summary
    Join us for an inside look at the NCUA's October 2024 board meeting, where we explore groundbreaking developments in new credit union charters and field of membership expansions. From innovative pilot programs to surging underserved area applications, discover how the credit union movement is evolving to serve more communities.

    ⏰ Timeline
    00:00 - Introduction
    02:15 - Overview of 2024 New Charters
    05:30 - Provisional Charter Pilot Program
    10:45 - Field of Membership Updates
    15:20 - Underserved Area Applications Surge
    20:10 - Process Improvements
    25:30 - Future Outlook

    🔑 Key Points
    • NCUA has chartered 3 new credit unions in 2024
    • Provisional Charter Pilot helping address startup capital challenges
    • 87 underserved area applications YTD (up from 32 in 2020)
    • New credit unions serving 15,000+ members with $51.9M in assets

    💡 Featured Credit Unions
    - Tribe Federal Credit Union (Minneapolis, MN)
    - MDI & low-income designation
    - Serving Minneapolis community

    - Fairbreak Federal Credit Union (Memphis, TN)
    - MDI & low-income designation
    - Serving Memphis area

    📊 Notable Statistics
    - New CU Performance:
    • $51.9M total assets
    • $34.8M share deposits
    • $15.4M loans
    • ~15,000 members served

    - Processing Times:
    • 152 days avg. review time (2023)
    • 215 days avg. review time (2024)

    🎯 NCUA Initiatives
    • Provisional Charter Program
    • Enhanced CAPRI online system
    • Streamlined application tracking
    • Improved transparency in charter process

    💭 Memorable Quote
    "The test of our progress is not whether we add to the abundance of those who have so much, it is whether we provide enough for those who have so little." - FDR

    🔗 Resources Mentioned
    • NCUA New Charter Website
    • CAPRI System
    • Charter Application Guidelines
    • Field of Membership Manual

    📝 Action Items for Credit Unions
    1. Check NCUA website for charter templates
    2. Review underserved area requirements
    3. Explore CAPRI system updates
    4. Connect with CURE office for guidance

    👥 Featured Speakers
    • Todd Harper - NCUA Chairman
    • Kyle Hauptman - Vice Chairman
    • Tonya Otsuka - Board Member
    • Martha Ninichuk - Director, Office of Credit Union Resources and Expansion
    • Leilani Stamper - Consumer Access Division Director

    📅 Next Steps
    • Provisional Charter Program review (End of 2024)
    • CAPRI system enhancement for community/underserved applications (Q1 2025)
    • Recommendations for program future (2025)

    #CreditUnions #FinancialInclusion #NCUA #Banking #Cooperation


    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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    57 mins
  • 2024 September NCUA Board Meeting Simplifying Share Insurance

    2024 September NCUA Board Meeting Simplifying Share Insurance
    Oct 23 2024

    www.marktreichel.com

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


    https://www.marktreichel.com/podcast

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


    2024 September NCUA Board Meeting: Simplified Share Insurance Rules

    This episode covers the NCUA's final rule on simplifying share insurance coverage, focusing on trust accounts and mortgage servicing accounts. The discussions include details on the changes, their implications, and responses to questions and comments from the NCUA board members.

    Introduction
    Final Rule on Part 745
    Presentation of the Final Rule
    Simplification of Trust Accounts
    Comments and Further Discussion
    Mortgage Servicing Accounts
    Record Keeping Regulations
    Board Members' Questions
    Conclusion


    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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    30 mins
  • Defense Credit Union Council Letter on Harper's CRA Efforts

    Defense Credit Union Council Letter on Harper's CRA Efforts
    Oct 22 2024
    www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This episode covers The Defense Credit Union Council’s letter to N C U A’s Chairman Todd Harper regarding his support for imposing Community Reinvestment Act on credit unions. The following is an audio version of that advisory and the press release. 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. October 15, 2024 Chairman Todd M. HarperNational Credit Union Administration Dear Chairman Harper,Our members noted your recent social media posts and comments indicating support for imposing Community Reinvestment Act (C R A) provisions on credit unions and soliciting input on the issue. On behalf of the Defense Credit Union Council (D C U C) and our nearly 200 members and 40 million members of defense credit unions, as well as the entire credit union movement, we are writing to express our deep concerns regarding the potential application of C R A to credit unions. This decision should not be made in haste or in response to news stories about the actions of one or two credit unions. It would be a public policy failure to universalize the recent “redlining” violation of one particular credit union and apply remedies for that misdeed into a regulatory burden that is wholly inappropriate for the member-owned cooperative credit union industry. Additionally, the fact that the “redlining” finding by the Department of Justice was uncovered without C R A being applicable to credit unions strongly suggests that this remedy would not address whatever problem you assert should lead to C R A for part or all of the credit union movement. Our members take their mission seriously as not-for-profit, member-owned cooperatives with a distinct mission to serve their members, especially those of modest means. This cooperative structure has always served to ensure that credit unions are inherently focused on meeting the financial needs of their members, unlike for-profit banks, which have external shareholders to satisfy. Credit unions already serve low- and moderate-income individuals and communities without the need for additional regulatory mandates. Imposing expensive C R A requirements on credit unions is redundant and unnecessary and eliminate the number of credit unions currently serving their members’ best interests along with those who are economically disadvantaged.Data consistently shows that credit unions, including Defense Credit Unions, have an exemplary record of providing affordable financial services to underserved populations. Many credit unions, particularly those serving military bases and defense personnel, operate in areas where banking options are limited, and the financial needs of service members are distinct. By offering low-cost loans, financial literacy programs, and savings products, credit unions fulfill their mission of promoting financial inclusion and security.Since the C R A was enacted to address the issue of discriminatory lending practices (i.e., “redlining”) by for-profit, shareholder-driven banks, why punish all credit unions? Credit unions, by definition, do not engage in the practices that C R A was designed to combat. The fundamental difference in structure and purpose between banks and credit unions makes C R A an ill-fitting regulatory framework on the latter. Plus, credit unions are already held accountable to their members, ensuring that their activities benefit the communities they serve. Finally, the N C U A, as the independent regulator of federally insured credit unions, has a critical role in protecting and promoting the unique cooperative model of credit unions. We commend the N C U A for consistently opposing the application of C R A to credit unions and urge the agency to continue to advocate against any such proposals. Particularly since credit unions are already subject to extensive regulatory oversight and examination by the N C U A. We strongly urge the National Credit Union Administration (N C U A) to continue its long- standing opposition to such requirements and request a meeting with your office and our member CEOs to discuss this issue in greater detail.Chairman Harper, we have a shared interest in protecting and empowering consumers, and we look forward to working constructively with you and your team to arrive at workable solutions that improve member access and service. Thank you for your attention to this matter and for ...
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    6 mins