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March 31, 2020

NCUA outlines priorities for exams

NCUA headquartersThe NCUA, in a Letter to Credit Unions released Monday, outlined its priorities for examinations during the coronavirus pandemic. The agency had previously mandated an offsite policy for staff and said exams would take place offsite through May 1; the policy will remain in effect until further notice.

NAFCU has updated its easy-to-read table on regulator actions and guidance related to the coronavirus pandemic to include this new letter on NCUA exams, as well as important updates related to the Small Business Administration lending programs and guidance from the Department of Labor and IRS related to paid leave requirements and other provisions in the Phase 2 and Phase 3 coronavirus relief packages.

"Our top priority is the safety of agency staff, credit union employees, and members," NCUA Chairman Rodney Hood said in the letter. "During this time, the NCUA will limit the burden imposed on credit unions so that they can focus on providing uninterrupted service to their members."

Here are the priorities for exams during this time:

  1. Credit unions experiencing problems: Credit unions that are experiencing significant financial or operational problems will be prioritized in NCUA's supervision efforts: "This includes credit unions that have asked for assistance and those that the NCUA determines may need assistance based on their financial and operational condition." Credit unions are encouraged to contact their NCUA examiner or regional office if agency assistance is needed.
  2. Contacting all credit unions: "Examiners will contact each credit union periodically to discuss the institution's operational and financial status, including any associated challenges, and whether any assistance is needed," the letter stated. Conversations that happen between March 30-April 10 will serve as the baseline for monitoring credit unions' condition and NCUA staff will continue periodic check-ins throughout the pandemic.
  3. Conduct examinations offsite: Credit unions will not be required to provide information to examiners to conduct offsite examination work unless approved by the Office of Executive Director. "If credit unions are occupied with addressing the impact of the COVID-19 pandemic on their operations, employees, and members, they should not be required to address an offsite examination request unless it is a serious or time-sensitive matter. However, when a credit union is able to provide examination documents and make staff available, NCUA examiners will continue to conduct offsite examination work." The agency further detailed the procedures for examinations during the pandemic and noted that "if examination work can be completed offsite during this time, the NCUA may not conduct any further examination work for a credit union during the 2020 calendar year."

Read the full Letter to Credit Unions here.

In addition to the NCUA's exam guidance, NAFCU's coronavirus regulatory table includes NCUA actions related to urgent needs grants, annual meeting flexibility, and handling troubled debt restructurings (TDRs). The table also includes updates from the CFPB, Federal Reserve, Federal Housing Finance Agency, and more.

See the updated table here.