Chris Nowinski is a former football player at Harvard University and professional wrestler with WWE, World Wrestling Entertainment. After enduring a career-ending head injury, Chris has dedicated his professional life to serving patients and families affected by brain trauma, particularly Chronic traumatic encephalopathy, or CTE, a progressive neurodegenerative disease that develops after repeated head injuries. Jay and Chris discuss the state of head injuries in American athletics, the difference between advocating for head safety at youth and professional levels, Chris’ newest research, and much more. Episode Chapters (00:00) Intro (00:50) changes in the culture around concussions in the past two decades (02:39) padded helmet technology (03:55) concussion reporting in the NFL (10:35) Chris’ career path and concussion history (14:52) connecting with activists who haven’t themselves suffered a traumatic brain injury (17:42) SHAAKE - a new sign to identify concussions (20:53) Unions can help players advocate for safety policies (23:10) final thoughts and goodbye For video episodes, watch on www.youtube.com/@therudermanfamilyfoundation Stay in touch: X: @JayRuderman | @RudermanFdn LinkedIn: Jay Ruderman | Ruderman Family Foundation Instagram: All About Change Podcast | Ruderman Family Foundation To learn more about the podcast, visit https://allaboutchangepodcast.com/…
This podcast provides you the ability to listen to new regulatory guidance issued by the National Credit Union Administration, and occasionally the F D I C, the O C C, the F F I E C, or the C F P B. We will focus on new and material agency guidance, and historically important and still active guidance from past years that NCUA cites in examinations or conversations. This podcast is educational only and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated. We also have another podcast called With Flying Colors where we provide tips for achieving success with the N C U A examination process and discuss hot topics that impact your credit union.
This podcast provides you the ability to listen to new regulatory guidance issued by the National Credit Union Administration, and occasionally the F D I C, the O C C, the F F I E C, or the C F P B. We will focus on new and material agency guidance, and historically important and still active guidance from past years that NCUA cites in examinations or conversations. This podcast is educational only and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated. We also have another podcast called With Flying Colors where we provide tips for achieving success with the N C U A examination process and discuss hot topics that impact your credit union.
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ This episode covers NCUA's Guidance to Credit Unions on Concentration Risk. 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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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This episode covers NCUA Chairman Kyle S. Hauptman's opening remarks from the February 27, 2025 Board Meeting. The following is an audio version of Chairman Hauptman's first board meeting remarks as NCUA Chairman. 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 NCUA so they save time and money. If you are worried about a recent, upcoming or in process NCUA examination, reach out to learn how they can assist at MarkTreichel.com. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with NCUA. And now the Chairman's opening remarks. NCUA Chairman Kyle S. Hauptman Board Meeting Opening Remarks As Prepared for Delivery on February 27, 2025 This is my first board meeting as Chairman. It's truly an honor to serve as the thirteenth Chairman of the NCUA and advance priorities that promote growth, opportunity, and innovation within the credit union system. I want to thank the President for his trust in me, and I also want to thank Todd Harper for his service through some challenging times for NCUA and the credit union system. Over the past few weeks there has been various announcements and Executive Orders affecting the federal workforce. Some of these directives may bring significant changes to the NCUA. All of us at this table understand that change, and the uncertainty that accompanies it, can be challenging for a number of parties: the credit union system, other stakeholders, and most definitely NCUA employees. All of us at the NCUA, including the Board, are diligently assessing how these announcements may affect the NCUA, our operations, regulatory structures, and our workforce. "All of us at this table understand that change, and the uncertainty that accompanies it, can be challenging for a number of parties: the credit union system, other stakeholders, and most definitely NCUA employees." To the NCUA employees who may be watching: The work each of you does, day in and day out, keeps our credit union system thriving and credit union members safe. There's also loads of misinformation and rumor out there. I've spent some time recently reading forums on Reddit that touch on NCUA or federal employees. And there's some crazy stuff out there. People moving money out of banks and credit unions to buy Treasury bonds because they think deposit insurance is going away. And that's not one of the crazier ones. Let's continue to stay focused on our mission, and we --- the Board --- will continue to support your work as we navigate any changes together. Thank you for your patience and your dedication to the NCUA. One thing that struck me last week. Our executive director mentioned how much NCUA staff liked seeing an email about this year's fee schedule for credit unions. I was curious why a fairly routine, mundane topic would generate a positive reaction. But it was precisely because it was mundane that people reacted that way. A sign that the big picture hasn't changed, NCUA business continues. I want to ask of my 1200 colleagues at NCUA to reach out to me anytime, by phone, Teams, email. While we on the Board don't have any more info on White House directives than anyone else, I'm happy to talk about problems and possible solutions. I'll tell you what I know and don't know. And to the people who we work for, the 142 million Americans who pay into the Share Insurance Fund: Know that NCUA's mission is unchanged. There are 4500 credit unions to examine, and most importantly, a $22 billion Share Insurance Fund that is the true north for each of us on the Board. Our deposit insurance is unchanged, the exams are continuing just the rest of our work here. Be assured we haven't taken our eye off the ball. "There are 4500 credit unions to examine, and most importantly, a $22 billion Share Insurance Fund that is the true north for each of us on the Board." We're aware that uncertainty surrounding your employer and your job isn't new for credit union members. Many credit unions were founded by employee groups of companies that no longer exist. We're aware that most Americans, the people who pay my salary, live a daily reality of uncertainty to their work situation. Just four years ago, 21 million Americans lost their jobs in one month. We get how the real world works. So just maybe grant us a bit of grace as we adjust and work through changes. And again, your money is safe in the NCUA insurance fund, and it's safe at NCUA-insured credit unions. Our NCUA staff are professionals, and they, and credit union members, should know the management around here has worked around the clock to ensure we still meet the needs of America's credit union members and my outstanding NCUA coworkers. And finally, I know that as Chairman, I can steer some priorities of the agency, but any concrete actions will require Board approval and that requires some measure of compromise on the part of all parties. Discussions among my colleagues have always been in good faith and in the spirit of cooperation during my tenure on the Board. There has been plenty of give-and-take in negotiations. None of us gets everything he or she wants , but all of us get some of what we wanted. I look forward to continuing that collaboration with my Board colleagues now that I am Chairman. That concludes my opening remarks. This concludes Chairman Hauptman's opening remarks from his first board meeting as NCUA Chairman. If your credit union could use assistance with your exam during these times of change at the NCUA, or if you have concerns about how recent executive orders might impact your credit union's examination process, reach out to Mark Treichel on LinkedIn, or at MarkTreichel.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 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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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ By the authority vested in me as President by the Constitution and the laws of the United States of America, it is hereby ordered: Section 1. Policy and Purpose. The Constitution vests all executive power in the President and charges him with faithfully executing the laws. Since it would be impossible for the President to single-handedly perform all the executive business of the Federal Government, the Constitution also provides for subordinate officers to assist the President in his executive duties. In the exercise of their often-considerable authority, these executive branch officials remain subject to the President’s ongoing supervision and control. The President in turn is regularly elected by and accountable to the American people. This is one of the structural safeguards, along with the separation of powers between the executive and legislative branches, regular elections for the Congress, and an independent judiciary whose judges are appointed by the President by and with the advice and consent of the Senate, by which the Framers created a Government accountable to the American people. However, previous administrations have allowed so-called “independent regulatory agencies” to operate with minimal Presidential supervision. These regulatory agencies currently exercise substantial executive authority without sufficient accountability to the President, and through him, to the American people. Moreover, these regulatory agencies have been permitted to promulgate significant regulations without review by the President. These practices undermine such regulatory agencies’ accountability to the American people and prevent a unified and coherent execution of Federal law. For the Federal Government to be truly accountable to the American people, officials who wield vast executive power must be supervised and controlled by the people’s elected President. Therefore, in order to improve the administration of the executive branch and to increase regulatory officials’ accountability to the American people, it shall be the policy of the executive branch to ensure Presidential supervision and control of the entire executive branch. Moreover, all executive departments and agencies, including so-called independent agencies, shall submit for review all proposed and final significant regulatory actions to the Office of Information and Regulatory Affairs (OIRA) within the Executive Office of the President before publication in the Federal Register . Sec. 2. Definitions. For the purposes of this order: (a) The term “employees” shall have the meaning given that term in section 2105 of title 5, United States Code. (b) The term “independent regulatory agency” shall have the meaning given that term in section 3502(5) of title 44, United States Code. This order shall not apply to the Board of Governors of the Federal Reserve System or to the Federal Open Market Committee in its conduct of monetary policy. This order shall apply to the Board of Governors of the Federal Reserve System only in connection with its conduct and authorities directly related to its supervision and regulation of financial institutions. (c) The term “independent regulatory agency chairman” shall mean, with regard to a multi-member independent regulatory agency, the chairman of such agency, and shall mean, with regard to a single-headed independent regulatory agency, such agency’s chairman, director, or other presiding officer. (d) The term “head” of an independent regulatory agency shall mean those appointed to supervise independent regulatory agencies and in whom the agencies’ authorities are generally vested, encompassing the chairman, director, or other presiding officer, and, as applicable, other members, commissioners, or similar such officials with responsibility for supervising such agencies. Sec. 3. OIRA Review of Agency Regulations. (a) Section 3(b) of Executive Order 12866 of September 30, 1993 (“Regulatory Planning and Review”), as amended, is hereby amended to read as follows: “(b) “Agency,” unless otherwise indicated, means any authority of the United States that is an “agency” under 44 U.S.C. 3502(1), and shall also include the Federal Election Commission. This order shall not apply to the Board of Governors of the Federal Reserve System or to the Federal Open Market Committee in its conduct of monetary policy. This order shall apply to the Board of Governors of the Federal Reserve System only in connection with its conduct and authorities directly related to its supervision and regulation of financial institutions.”. (b) The Director of the Office of Management and Budget (OMB) shall provide guidance on implementation of this order to the heads of executive departments and agencies newly submitting regulatory actions under section 3(b) of Executive Order 12866. Agency submissions by independent regulatory agencies under such section shall commence within the earlier of 60 days from the date of this order, or completion of such implementation guidance. Sec. 4. Performance Standards and Management Objectives. The Director of OMB shall establish performance standards and management objectives for independent agency heads, as appropriate and consistent with applicable law, and report periodically to the President on their performance and efficiency in attaining such standards and objectives. Sec. 5. Apportionments for Independent Regulatory Agencies. The Director of OMB shall, on an ongoing basis: (a) review independent regulatory agencies’ obligations for consistency with the President’s policies and priorities; and (b) consult with independent regulatory agency chairmen and adjust such agencies’ apportionments by activity, function, project, or object, as necessary and appropriate, to advance the President’s policies and priorities. Such adjustments to apportionments may prohibit independent regulatory agencies from expending appropriations on particular activities, functions, projects, or objects, so long as such restrictions are consistent with law. Sec. 6. Additional Consultation with the Executive Office of the President. (a) Subject to subsection (b), independent regulatory agency chairmen shall regularly consult with and coordinate policies and priorities with the directors of OMB, the White House Domestic Policy Council, and the White House National Economic Council. (b) The heads of independent regulatory agencies shall establish a position of White House Liaison in their respective agencies. Such position shall be in grade 15 of the General Schedule and shall be placed in Schedule C of the excepted service. (c) Independent regulatory agency chairmen shall submit agency strategic plans developed pursuant to the Government Performance and Results Act of 1993 to the Director of OMB for clearance prior to finalization. Sec. 7. Rules of Conduct Guiding Federal Employees’ Interpretation of the Law. The President and the Atto...…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
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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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
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.…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
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.…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
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.…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
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.…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://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 Order Aside 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 by the N C U A pursuant to its authority under the FCU Act section206(f), 12 U.S.C. section1786(f), and is used to impose measures immediately pending resolution of a Final C AND D Order. Such orders are typically used only when immediately necessary to protect the credit union against ongoing or expected harm. A Temporary C AND D Order may be challenged in U.S. District Court within 10 days of issuance, but it is effective upon issuance and remains in effect unless overturned by the court or until a final order is in place. To issue a temporary order, N C U A must also issue a Notice of Charges initiating a proceeding to obtain a Final C AND D Order. In order to issue a Temporary C AND D Order, N C U A must determine that the violation or threatened violation or the unsafe or unsound practice(s) is likely to either: ► Cause insolvency or significant dissipation of assets or earnings. ► Weaken the condition of the credit union or otherwise prejudice the interest of the credit union's members. The FCU Act section206(f)(3), 12 U.S.C. section1786(f)(3), provides for the issuance of a Temporary C AND D Order when an insured credit union's books and records are so incomplete or inaccurate that the financial condition of the credit union or details or the purpose of any material transaction can not be determined. This section also applies when a credit union does not provide adequate access to the books and records. 2. What are the grounds for issuance of a Cease and Desist Order? The grounds for a cease and desist action are set forth in the FCU Act section206(e)(1), 12 U.S.C. section1786(e)(1). A C AND D Order can be issued if any insured credit union or institution-affiliated party is either: ► Engaging in or has engag...…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://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 Workouts 23-CU-04, Update to Interagency Policy Statement on Allowances for Credit Losses 14-CU-08, Home Equity Lines of Credit Nearing Their End-of-Draw Period 10-CU-03, Concentration Risk 09-CU-19, Evaluating Residential Real Estate Loan Modification Programs 07-CU-13, Evaluating Third Party Relationships 03-CU-01, Loan Charge-off Guidance 91-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 credit union's earnings and net worth. Over the last few years, the rising interest rate environment increased some credit unions' cost of funds faster than the returns on loans and investments, squeezing the net interest margin—a key driver of earnings. In 2023 and 2024, this increase in funding costs put pressure on earnings until loan and investment returns could catch up. If interest rates continue to decline, higher yielding loans and investments are prone to prepayment, which could accelerate as rates drop, reducing interest income from longer-duration assets. For the last several quarters, net interest margins have only slightly exceeded operating expenses. Any increase in operating expenses or further decline in loan performance could put earnings and net worth at risk. In evaluating your credit union's earnings and net worth risk-management frameworks, examiners will weigh the current and prospective sources of earnings and the composition of net worth relative to your credit union's approved plans and thresholds. This approach will help examiners focus on trends in earnings and develop a better understanding of concentration risks for both earnings and net worth. Also, examiners will continue to consider the current and prospective sources of liquidity compared to funding needs to determine the adequacy of your credit union's liquidity risk-management framework. Examiners will review your credit union's policies, procedures, risk limits, and evaluate the adequacy of your credit union's risk-management framework relative to its size, complexity, and risk profile. Liquidity resources and guidance can be found in the N C U A's Examiner's Guide and the Liquidity Risk Resources webpage. For interest rate risk-related resources, refer to the Examiner's Guide and the following regulatory guidance: Letter to Credit Unions 22-CU-09, Updates to Interest Rate Risk Supervisory Framework Super...…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://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 customers---including those who are not victims of fraud--- from accessing their funds. If banks on either side of the transaction do not complete investigations expeditiously, customers may not have access to funds for extended periods of time, which may create financial hardship for them. Banks can continue to support customers by providing information about scam and fraud trends and education of potential preventative measures. For example, to address the prevalence of text messaging and bank impostor scams, it can be beneficial to inform customers about how the bank will contact its customers regarding potential fraudulent transactions, as well as the strengths and limitations of various authentication methods and how to identify potential fraudulent schemes. Banks can also develop policies and procedures regarding what and how to communicate with customers when the bank determines that account access should be limited, taking care not to reveal the existence of any suspicious activity report (S A R) filing, and ensuring that the communication is otherwise consistent with safe and sound banking practices. Communications can provide critical information to customers seeking to access their funds. In addition, staff can be trained to identify and respond to customers seeking to conduct unusual transactions that have signs of fraud, such as a large withdrawal or wire transfer that may be outside of a customer's usual transaction habits. Employee training may also include identifying red flags for different types of financial exploitation, providing proactive approaches to detecting and preventing elder financial exploitation, and detailing actions for employees to take when they have concerns. When multiple departments are responsible for researching unusual account activities across functions such as B S A compliance, fraud prevention, consumer protection, and open lines of communication between the bank's departments are important and may result in enhanced coordination and expedited resolution. This concludes the fraud portion of this report. 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.…
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ CFPB Finalizes Rule to Remove Medical Bills from Credit Reports Today, the Consumer Financial Protection Bureau announced a final rule that will remove approximately forty-nine billion dollars in medical bills from the credit reports of about fifteen million Americans. The C F P B's action will ban the inclusion of medical bills on credit reports used by lenders and prohibit lenders from using medical information in their lending decisions. Director Rohit Chopra expressed that people who get sick shouldn't have their financial future upended. The rule will close a special carveout that previously allowed debt collectors to use the credit reporting system to coerce people into paying medical bills they may not even owe. The C F P B's research has shown that a medical bill on someone's credit report poorly predicts whether they will repay a loan. With this new rule, approximately twenty-two thousand additional, affordable mortgages could be approved yearly. Americans with medical debt on their credit reports could see their credit scores rise by an average of twenty points. This follows changes made by Equifax, Experian, and TransUnion, who previously announced they would remove certain medical debts from credit reports. The rule becomes effective sixty days after publication in the Federal Register. This concludes the announcement. 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 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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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. Happy new Year! This episode covers N C U A Board’s Approval of a Non-Registered Investment Fund Pilot Program The following is an audio version of that 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 press release. NCUA Board Approves Non-Registered Investment Fund Pilot Program On December 30th The National Credit Union Administration Board approved, by notation vote, an investment pilot program authorized under section 703 point 19 C of the N C U A’s regulations. The N C U A will permit up to 30 complex federal credit unions to engage in investment activities prohibited under part 703 but permitted by the Federal Credit Union Act. Note A credit union is considered "complex" if its total assets exceed a specific threshold set by the N C U A. As of today,the threshold is 500 million dollars or more in total assets. A L M First Financial Advisors, LLC., a Securities and Exchange Commission registered investment advisor, requested the investment pilot program. The requested pilot program would allow complex federal credit unions to invest in a series of non-registered investment funds comprised of consumer loans, as follows: The pilot fund would be comprised of permissible consumer loans for federally insured credit unions with maturities of less than 10 years and overnight investments. Federal credit unions must be complex and have a capital adequacy classification of well capitalized to invest in the fund and are limited to an aggregate investment of 50 percent of net worth as defined in part 702 of N C U A’s regulations. The pilot program is subject to the A L M First Loan Fund Investment Pilot Program Requirements and Conditions, which are available on the N C U A website. Under part 703 of the N C U A’s regulations, federal credit unions are authorized to invest in funds that are registered with the S E C or regulated by the Office of the Comptroller of the Currency, provided the underlying assets purchased by the fund are permissible under N C U A rules for federal credit unions. This concludes the press release 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 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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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ NCUA approved their budget for 2025 and 2025 at the December Board meeting. This is a recording of that item. 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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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ https://www.linkedin.com/in/mark-treichel/ https://www.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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