Key accomplishments by the interagency working group include:The NCUA will continue communicating with credit unions, engaging with law enforcement, and collaborating with the other banking regulators on several initiatives associated with this supervisory priority, including:The NCUA will also continue focusing on proper filing of SARs and CTRs, as well as reviews of bi-weekly 314(a) information requests from FinCEN. Following challenges related to the COVID-19 pandemic, the NCUA has delayed the rollout, training and launch of these applications to all examination staff until the second half of 2021. These amendments went into effect Jan. 6, 2020. Relative to supervisory committee audits, NCUA published a minimum procedures guide on January 8, 2020 which can be found here. In addition to the requirements outlined in Appendix A of the rule, NCUA has released a guide to assist those supervisory committees choosing this option. Officials use this information regularly to identify and thwart illicit and terrorist financing activities, and to prosecute and convict guilty parties.
Cornerstone Credit Union League | Jan 09, 2020 InTREx-CU harmonizes the IT and Cybersecurity examination procedures shared by the Federal Deposit Insurance Corporation, the Federal Reserve System, and some state financial regulators to ensure consistent approaches are applied to community financial institutions. The InTREx-CU will be deployed to identify gaps in security safeguards, allowing examiners and credit unions to identify and remediate potential high-risk areas through the identification of critical information security program deficiencies as represented by an array of critical security controls and practices.The NCUA has also published information for credit unions on the increased cybersecurity threats resulting from the COVID-19 pandemic and additional resources for protecting their members. National Credit Union Administration, 1775 Duke Street, Alexandria, VA 22314 The Final Rule, which goes into effect 90 days after publication in the Federal Register, replaces the Guide with a simplified appendix, making it easier for credit unions to complete the audit process. The National Credit Union Administration has issued a new guide to minimum procedures for other supervisory committee audits.The NCUA Board in September 2019 unanimously approved a rule amending Part 715 of agency regulations governing federally insured credit unions’ responsibilities to obtain an annual supervisory committee audit. These may be subject to increased legal, financial, and operational risks once the reference rate is no longer available. The NCUA is also piloting an Information Technology Risk Examination solution for Credit Unions (InTREx-CU). Examiners will also ensure credit unions have evaluated the impact of COVID-19 pandemic decisions on their capital position and financial stability.In addition, credit unions’ risk-monitoring practices should be commensurate with the level of complexity and nature of their lending activities, provide for safe and sound lending practices, and ensure compliance with consumer protections and regulatory reporting requirements.Further, due to the recent developments in economic conditions and the Financial Accounting Standards Board’s (FASB) decision to delay its requirement to comply with the current expected credit losses (CECL) standard until January 2023, NCUA examiners will not be assessing credit unions’ efforts to transition to the CECL standard until further notice. With these revised priorities, the NCUA is focusing its examination activities on areas that pose elevated risk to the credit union industry and the National Credit Union Share Insurance Fund given the current environment.The NCUA understands the challenges credit unions are facing during the COVID-19 pandemic. The NCUA encourages credit unions to continue to assess their needs and evaluate methodologies for the eventual implementation of the CECL standard.Credit unions must still maintain an ALLL account in accordance with FASB Accounting Standards Codification (ASC) Subtopic 450-20 (loss contingencies) and/or ASC 310-10 (loan impairment).
The NCUA has added the CARES Act as a supervisory priority to reflect the importance of the provisions outlined in the Act. Many smaller and noncomplex credit unions opt for the Supervisory Committee exam, to be conducted either by an external auditor or by their own Supervisory Committee.
