Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

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Jun 2026

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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.

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June 10, 2026Episode 13248 min

Records Preservation Program and Appendices Record Retention Guidelines; Catastrophic Act Preparedness Guidelines

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Proposes to Streamline Vital Records Preservation RuleThe NCUA Board has issued a proposed rule to simplify and streamline Part 749, the regulation governing credit union vital records preservation programs. The proposal responds to years of industry feedback that the current rule, particularly its appendices, has become unnecessarily burdensome and confusing.What NCUA is proposing:Rename Part 749 to "Vital Records Preservation Program" to clarify its scopeAdd formal definitions for "vital member services" and "vital records" rather than relying only on examplesClarify that a records preservation log may be kept in electronic formatConfirm that older versions of vital records may be destroyed once current versions are stored, unless other law or regulation requires otherwiseRequire credit unions that use third-party service providers to maintain effective oversight of those vendorsEliminate Appendix A (Record Retention Guidelines) entirelyEliminate Appendix B (Catastrophic Act Preparedness Guidelines) entirelyRemove the cross-reference to Appendix A from the derivatives rule at 12 CFR 703.105(d)Why the change is occurring:In 2024, NCUA issued an ANPR and received 25 comment letters. Commenters overwhelmingly said Appendix A's recommendation to retain certain documents permanently was being treated as a requirement by examiners and credit union staff, leading to retention of records with no real operational value. Commenters also said the appendices duplicated the regulation, created confusion between guidance and enforceable rules, and drove up storage, conversion, and security costs, especially for smaller credit unions.What is NOT changing:The core obligation for FICUs to maintain a written vital records preservation programThe board of directors' responsibility for establishing the program within six months of insurance certificationSections 749.4 and 749.5 on format flexibility (no changes proposed)NCUA's longstanding practice of not prescribing specific retention periods for individual documentsThe treatment of off-site data processor arrangements as compliant when the service agreement protects against simultaneous destruction of production and backup data10,000-foot takeaway:NCUA is moving away from permanent-retention recommendations and prescriptive destruction procedures, and putting record retention judgment back where it belongs: with each credit union's board of directors. If finalized, credit unions should expect less ambiguity between what is a regulatory requirement and what is merely guidance, and a meaningful reduction in the pressure to retain documents indefinitely. Comments are due by May 11, 2026.Visit MarkTreichel.com for help preparing for your next NCUA exam. 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

June 3, 2026Episode 13114 min

NCUA's Proposed Regulation on Auto Loan Participations

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Proposes to Eliminate Prescriptive Limits on Third-Party Serviced Indirect Vehicle LoansThe NCUA Board is seeking comment on a proposed rule that would remove the agency's longstanding regulation governing federally insured credit union purchases of indirect vehicle loans serviced by third parties. Comments are due by May 26, 2026.What NCUA is proposing:Remove Section 701.21(h), which currently caps indirect vehicle loans and participations purchased from any one third-party servicer at 50% of net worth (rising to 100% after 30 months of experience with that servicer)Remove the parallel requirement in Section 741.203(c) that applies these same limits to federally insured, state-chartered credit unionsRemove the related waiver process, the associated Regional Director timelines, and the related citation in the appeals rule at Section 746.201(c)Why the change:The 2006 rule was built around a rigid, one-size-fits-all framework that the Board now views as unduly burdensomeThe Board believes each credit union's board is in the best position to tailor policies to its own size, risk profile, and complexity of transactionsThe action is consistent with a principles-based supervisory approach and is expected to qualify as a deregulatory action under Executive Order 14192It is also intended to reduce administrative costs and compliance complexity so credit unions can serve members more efficientlyWhat is NOT changing:Credit union boards are still responsible for safety and soundness, due diligence, and appropriate controls over indirect lending programsNCUA will continue to monitor third-party indirect vehicle lending through the examination processThe underlying legal authority, and NCUA's ability to act on unsafe or unsound practices, remains intact10,000-foot takeaway: NCUA is trading a bright-line concentration cap for board-level judgment. Credit unions gain flexibility, but the expectation is that internal policies, third-party due diligence, and concentration management become more robust, not less. If this is finalized, examiner scrutiny of indirect program governance will matter more, not less.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 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

May 27, 2026Episode 1358 min

NCUA Proposal on Purchase, Sale, and Pledge of Eligible Obligations.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA is proposing to streamline its rule on the purchase, sale, and pledge of eligible obligations (12 CFR 701.23).What NCUA is proposing:Remove the prescriptive lists of items that FCUs must address in their written purchase, sale, and pledge policiesRemove the detailed code of conduct in paragraph (g) governing conflicts of interest and compensation tied to these transactionsMake a conforming redesignation (current 701.23(h) becomes 701.23(g)) and update the cross-reference in the appeals rule at 12 CFR 746.201(c)Comments are due April 27, 2026Why NCUA is making the change:The current one-size-fits-all framework is viewed as unduly burdensome, especially for smaller FCUsThe FCU Act requires NCUA to issue rules in this area but does not require a detailed framework for internal credit union policiesAn FCU's board is in the best position to scale policies to its own activities and risk profileThe existing compensation prohibition, with a narrow list of exceptions, is seen as inflexible and may hinder legitimate incentive structuresFCUs are already governed by broader conflict of interest provisions in their bylaws and by the fiduciary duties of their officialsThe change aligns with a more principles-based supervisory approachWhat is NOT changing:FCUs must still maintain written policies covering purchase, sale, and pledge of eligible obligationsBoard approval remains required, and transactions must be conducted at arm's length and in the best interest of the credit unionThe underlying statutory authority under section 107(13) of the FCU Act is unchangedExaminer oversight of these activities continuesThe rule applies only to FCUs — the basic framework for FISCUs is unaffected10,000-foot takeaway: NCUA is shifting from prescriptive checklists to principles-based expectations for eligible obligation policies. FCUs get more flexibility to tailor their written policies and incentive structures, but they also keep full responsibility for safe and sound operations. Boards should start thinking now about how their existing policies would hold up under a principles-based exam — the guardrails are coming out, but the accountability is not.If your credit union would like help preparing for an NCUA exam, visit 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 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

May 20, 2026Episode 13922 min

NCUA's 2025 Annual Report audio book style

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA's 2025 Annual Report audio book 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 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

May 13, 2026Episode 1388 min

NCUA's Request for Information Regarding Enhancing and Streamlining Data Collection From Credit Unions.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA request for feedback on data collections. 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

May 6, 2026Episode 13742 min

NCUA's Annual Performance Plan for Calendar Year 2026.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA just released its 2026 Annual Performance Plan, and it offers a clear look at where the agency is focusing its resources this year. Here are the highlights:What NCUA is announcing:17 annual performance goals supported by 23 performance indicators, all aligned to the new 2026-2030 Strategic PlanA commitment to issue at least 30 regulatory actions or policy revisions that reduce regulatory or administrative burden on credit unionsPlans to eliminate unnecessary or unduly burdensome examination scope stepsFinal regulations on permissible stablecoin activities for all federally insured credit unionsDeployment of the Analytics 2.0 Phase I upgrade to the MERIT examination system by Q1 2026Key milestones in NCUA's AI roadmap, including a large language model pilot, an AI Steering Committee, and a refined AI strategyAt least three joint NCUA-State Supervisory Authority engagements to strengthen the dual chartering systemWhy the change is occurring:NCUA is reorganizing to focus on core statutory functions, eliminate duplication, and reduce non-essential activitiesThe agency wants to reallocate resources toward material risks while reducing lower-priority work for both examiners and credit unionsRapid changes in technology, digital assets, and payment systems require updated regulations and guidanceStronger data, analytics, and AI capabilities are needed to keep pace with an increasingly complex credit union systemWhat is NOT changing:NCUA's core mission to safeguard federally insured credit unions and protect the Share Insurance FundThe statutory requirement to maintain the Share Insurance Fund equity ratio at or above 1.2 percentTimely follow-up examinations for troubled credit unions - target is at least 97 percent initiated within established timeframes for CAMELS 4/5 credit unions and CAMELS 3 credit unions over $250 millionCommitment to an unmodified ("clean") opinion on financial statement audits and a FISMA maturity rating of at least Level 4Ongoing support for low-income credit unions through Congressionally appropriated grantsThe 10,000-foot takeaway: NCUA is signaling a leaner, more risk-focused agency in 2026. Expect meaningful burden reduction, a final stablecoin rule, smarter use of data and AI in examinations, and continued organizational realignment - all while maintaining the financial resilience of the Share Insurance Fund. Credit unions should watch closely for the 30-plus regulatory and policy revisions coming this year, as many will directly affect exam scope, compliance expectations, and innovation opportunities.If your credit union wants help preparing for an NCUA exam, visit 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 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

April 29, 2026Episode 13633 min

NCUA's Five Year Strategic Plan

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA just released its 2026-2030 Strategic Plan, laying out the agency's priorities for the next five years. Here's what credit union leaders should know.What NCUA is announcing:Three strategic goals: safeguarding federally insured credit unions, enabling access to cooperative financial services and responsible innovation, and strengthening the agency's own capabilities and performanceA comprehensive review of the regulatory framework to remove rules that are outdated, duplicative, or unnecessarily burdensomeExpanded use of data, analytics, and AI tools in examination and supervisionA push to foster responsible adoption of financial technology, digital assets, and blockchain-based innovationStreamlined chartering, field of membership, and expansion processesInternal restructuring focused on core statutory functions, merit-based hiring, and reduced duplicationWhy the change is occurring:Feedback from NCUA's first-ever Strategic Planning Town Hall in September 2025 with credit unions, leagues, trade associations, and CUSOsA financial services environment evolving rapidly with AI, digital assets, and shifting member expectationsPresidential executive orders and laws like the GENIUS Act driving new regulatory responsibilitiesA recognition that disciplined, risk-focused supervision serves both safety and soundness and member accessWhat is NOT changing:NCUA's core mission: enabling access to financial services by facilitating safe, sound, and resilient credit unionsStatutory responsibility to protect the Share Insurance Fund and credit union membersRisk-focused examination framework (it's being refined, not replaced)Coordination with FFIEC, FSOC, and state regulatorsAgency values: results, integrity, teamwork, and accountability10,000-foot takeaway: NCUA is signaling a lighter, more targeted regulatory touch paired with a modernized, tech-enabled supervisory approach. Expect continued focus on material risks, fewer administrative burdens, and more room for credit unions to innovate responsibly, while the Share Insurance Fund and safety-and-soundness remain non-negotiable. 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

April 22, 2026Episode 13021 min

NCUA's Proposal to Improve Associational Field of Membership

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Proposes to Loosen Associational Common Bond RulesThe NCUA Board has issued a proposed rule that would amend the associational common bond provisions of its Chartering and Field of Membership Manual. Comments are due by June 8, 2026.What NCUA is proposing:Eliminate the automatic bar that currently disqualifies an associational group from FCU field of membership eligibility when the group requires purchasing a product or service as a condition of membership.Replace the bright-line rule with a totality of the circumstances review, looking at the group's structure, scope, degree of activities, and other operational factors.Clarify that a client-customer relationship can exist, even as a condition of membership, as long as it remains incidental to the group's overall purpose and activities.Use an example of a fraternal association that requires insurance purchase - under the proposal, this would no longer be automatically disqualifying.Why the change:The Board believes the automatic bar goes beyond what the FCU Act actually requires.Neither the FCU Act nor the Credit Union Membership Access Act of 1998 (CUMAA) specifies that a client-customer relationship is automatically disqualifying.The change is intended to enhance consumer access to financial services and eliminate an inflexible restriction, consistent with Executive Order 13563 and deregulatory goals under Executive Order 14192.Moves NCUA toward a principles-based approach rather than a rigid rule.What is NOT changing:Associations based primarily on a client-customer relationship still do not qualify.Health clubs, including YMCAs, remain examples of groups that do not meet the associational common bond requirements.Retail loyalty clubs still would not qualify, since their core reason for existence is the client-customer relationship.The rule does not affect occupational common bond charters, community charters, or federally insured state-chartered credit unions.The core associational common bond definition - members of a recognized association who participate in activities developing common loyalties, mutual benefits, and mutual interests - remains intact.Pre-approved categories of groups under the 2015 automatic qualification amendments are unaffected.10,000-foot takeaway: NCUA is moving from a rigid "if you require a purchase, you're out" standard to a more flexible "look at the whole picture" standard. Associational groups that previously couldn't qualify because membership required buying a product or service may now have a path forward - but only if the client-customer piece is genuinely incidental to why the group exists. If selling something is the core reason the group was formed, the group still doesn't qualify. For FCUs looking to expand their field of membership through associational groups, this proposal could open doors that have been closed for decades. 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

February 15, 2026Episode 12913 min

NCUA’s 2026 Supervisory Priorities Letter to Credit Unions

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The NCUA just released its 2026 Supervisory Priorities (Letter 26-CU-01), giving credit unions a heads-up on where examiners will be focusing this year.Here's what you need to know:The NCUA is doubling down on balance sheet management, with particular attention to lending, interest rate risk, liquidity, earnings, and capital adequacy. Loan delinquency and loss rates are at their highest in over a decade, and examiners will be looking closely at underwriting, loss mitigation, ACL reserves, and charge-off practices.Operational risk is a major theme. Payment systems, fraud prevention, and cybersecurity will all get heightened scrutiny as the payments landscape grows more complex and fraud risks continue to rise.BSA/AML compliance remains a priority, with an emphasis on risk-based programs tailored to each credit union's profile. Expect regulatory changes throughout the year as FinCEN and the NCUA continue implementing provisions of the Anti-Money Laundering Act of 2020.The agency is also signaling a shift toward a more efficient and tailored examination program, building on its 2025 efforts to reduce burden for both credit unions and NCUA staff. Defined scope exams will continue for most federal credit unions with $50 million or less in assets.What is NOT changing: The NCUA will continue enforcing all existing laws and regulations, including consumer financial protection and information security requirements. Risk-focused procedures remain the standard for larger credit unions.The 10,000-foot takeaway: Asset quality and earnings pressure are the story of 2026. Credit unions that can demonstrate strong risk management practices across lending, liquidity, and capital planning will be well positioned. Now is the time to review your ACL methodologies, stress testing, contingency funding plans, and BSA programs before examiners come knocking.One more thing worth noting: the NCUA reminds credit unions they may record their final exit meeting or joint conference for documentation and training purposes.If your credit union could use help preparing, visit MarkTreichel.com or reach out to Mark Treichel on LinkedIn. 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

January 28, 2026Episode 1179 min

NCUA's Corporate Credit Union Proposed Rule Change

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Changes for Corporate Credit Unions – 12 CFR 704.8 and 704.15NCUA is proposing to amend its regulations for corporate credit unions by removing the requirement that a corporate credit union’s asset and liability management committee (ALCO) must have at least one member who is also a member of the corporate credit union’s board of directors. 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 Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.