NCUA letter clarifies DOR vs. exam findings
Oct. 9, 2013 – NAFCU welcomed NCUA’s issuance of a new Letter to Credit Unions on Tuesday that seeks to streamline the examination report and clarify for federally insured credit unions the difference between a document of resolution and examiner findings, as well as other exam documents.
The letter also announced new processes related to issuing and following up on the examination report. For example, under the new process, examiners are now required to follow up with credit union officials on outstanding DOR items within 120 days after the timeframe for completion has passed.
The changes to the examination report and the new processes are contained in the agency’s revised National Supervision Program Manual. The agency stated that full implementation will begin with examinations that start after Jan. 1 of next year.
NAFCU has written to and met with NCUA officials and senior staff often on this issue, noting its members’ concerns about some examiners' reliance on DORs to address matters that are not material in nature and would be better addressed in the examiner findings report. “NAFCU has been in ongoing communications with NCUA about the examination process, and specifically about what seemed to be a rampant use of DORs,” said Tessema Tefferi, NAFCU’s senior regulatory affairs counsel. “We appreciate NCUA’s issuance of today’s letter and will continue to work with the agency to address other examination issues going forward.”
The association has also been working in support of legislation that would require regulators to make the examination process fairer.
In April, Rep. Shelley Moore Capito, R-W. Va., reintroduced last Congress’ “Financial Institutions Examination Fairness and Reform Act” as H.R. 1553. Supported by NAFCU, the measure would create a new standard for financial institution examinations and create an independent examination appeals process. Sen. Jerry Moran, R-Kan., has also introduced the similar S. 727.
NCUA Letter to Credit Unions (10-8-13)