Compliance Blog

During yesterday's NCUA Corporate Stabilization webinar, I picked up the following points.:

• NCUA is still working on a Supervisory Letter.  Once they release this, probably in the form of a letter to credit unions, we'll have some clarity on how examiners are supposed to view credit unions that might take a hit to their ROA or capital due to any required payments to the NCUSIF.
• Payments to the NCUSIF are not inevitable.  NCUA has indicated that they are still working on alternatives that might change their initial stabilization plan. 
• If payments come, it sounded to me like your credit union would make the payment in September.
• How do you book this?  Follow GAAP.
• Dave Marquis indicated that there were more than 1,200 questions submitted.  I estimate that they answered 20.  Be on the lookout for a Q and A document that synthesizes all the questions, along with NCUA's response.
• And for the latest, don't' forget that NCUA has created a Corporate Stabilization Program page on its website.

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Yesterday, I stumbled upon two things that made me go hmmmm.

• First, a GAO report indicates that understaffing at the Social Security Administration is causing huge problems. 
• But then I find where the Social Security Administration apparently has the time to track the most common names given to baby boys and girls.  (This was a legitimate find. I was researching whether a person possibly could receive 2 social security numbers.  The answer, apparently, is yes.)

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Hey NAFCUers, our Book of Answers has been updated again. Access it here. (Member login needed.)

For you non-NAFCUers, here's a taste of what you're missing.

Question: As our credit union staff expands, we find ourselves with a shortage of secure storage space. Our employees rarely pull physical signature cards since we use an optical system. Can our credit union dispense with the metal signature boxes by placing each member’s signature card in their respective files? It would save us a lot of filing trouble and ease the issue of pulling signature cards and files.

Answer:There is nothing in the National Credit Union Administration’s (NCUA’s) Records Preservation Program and Record Retention Appendix stating that a credit union can not keep the original signature card together and within the member file. The regulations state “Preserved records may be in any format that can be used to reconstruct the credit union’s records.” 12 C.F.R. § 749.4. In addition, NCUA indicates that “(c)redit unions may use any format, electronic or other, for maintaining the writings records or information that accurately reflects the information, remains accessible to all persons who are entitled to access by statute, regulation or rule of law, and is cable of being reproduced by transmission, printing or otherwise.” 12 C.F.R. § 749.5.
August 2007

Have a great weekend, everyone!