The Credit Union National Association (CUNA) is soliciting comments from it’s members regarding their recent NCUA examination experiences.
“We have heard from credit unions a lot over the last few months that many are finding their examiners and exams to have been a lot more difficult than they were previously,” said Mary Dunn, senior vice president for CUNA.
There is no doubt that the NCUA has been scrutinizing credit unions more closely lately, the question is whether NCUA examiners are being perceived as more difficult because they are holding institutions to a higher standard, or are they just being more difficult. Hopefully this will become clearer as more members weigh in, but I wrote about this here and here, speculating that since the FDIC now has the ability to supersede the primary federal regulator (PFR), the non-FDIC PFR’s may raise their standards to match the traditionally tougher FDIC standards.
I’ll repeat my advice…the best course of action is to adopt the FDIC interpretation of FFIEC regulations, regardless of your PFR. The worst you’ll do is overshoot the mark.
(…and as I posted here, at least one state regulator has already adopted the FDIC pre-examination questionnaire.)