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Statement of CFPB Director Rohit Chopra, Member, FDIC Board Member, on Stopping Fintech Deposit Meltdowns

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Content provided by Credit Union Exam Solutions by Mark Treichel and Credit Union Exam Solutions Inc.. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by Credit Union Exam Solutions by Mark Treichel and Credit Union Exam Solutions Inc. or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://ppacc.player.fm/legal.

www.marktreichel.com

https://www.linkedin.com/in/mark-treichel/


Hello, this is Samantha Shares. This episode covers the Statement of C F P B Director Rohit Chopra, Member, F D I C Board of Directors, on Stopping Fintech Deposit Meltdowns

The following is an audio version of that statement. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

And now the statement.

Statement of C F P B Director Rohit Chopra, Member, F D I C Board of Directors, on Stopping Fintech Deposit Meltdowns

Over the past decade, we have seen a significant incursion into consumer deposit taking and payments activities by companies that aren’t banks or credit unions. These firms want the public benefits of being a bank or credit union, without the public obligations.

This trend poses significant risks. We have developed a legal framework for banks over the past century designed to ensure people’s deposits are safe and that they have constant access to their funds. Deposit insurance and the special F D I C resolution process protect people if the bank fails and they retain quick access to their cash. When nonbanks engage in deposit taking, whether directly or in partnership with a bank, all these protections may not apply.

Today, the F D I C Board of Directors is proposing a rule that would strengthen requirements for banks that partner with nonbanks in offering deposit-style products.

This year, Synapse, a middleman between nonbanks offering deposit-style products to end users and their partner banks, filed for bankruptcy. The firm appears to have failed to properly track customer account balances and may have engaged in other shady practices. As a result, tens of thousands of customers have had their funds frozen for months. The banks have been unable to reconcile all the records necessary to get end users their funds back. This has led to severe harm, especially for people who were using the nonbank account as a primary checking or savings account.

If one of the bank partners had failed, instead of Synapse, the horrible account balance tracking may have prevented the F D I C from making quick deposit insurance determinations and returning funds promptly to end users. When consumers do not have access to their funds, it can undermine confidence in the financial system and ruin lives.

The proposed rule would require banks to maintain records identifying the ultimate end users, their balances, and other information for custodial accounts with transaction-style features. Banks would still be permitted to maintain these records through a third party as long as certain protections are in place, including daily reconciliations to make sure the numbers at the customer-level add up. Banks would also have to maintain constant access to the records, including in the event of the nonbank’s bankruptcy or other disruption. This framework would expedite an F D I C insurance determination if the bank fails and prevent the type of chaos we’re seeing with the Synapse bankruptcy if the nonbank fails.

To be clear, this rule would not address all the risks posed by banking with a nonbank. Even if all the records are appropriately maintained, there still may be some delay in getting end users their money back as the nonbank’s bankruptcy proceeding plays out.1 In addition, nonbank deposit taking offered directly without a bank partner is generally outside the jurisdiction of the federal banking agencies.2 If the firm fails, consumers become unsecured creditors of the nonbank’s bankruptcy estate and may lose their funds.

This proposal must not be the end of our collective work on this issue.

First, disclosure requirements related to the intricacies of pass-through deposit insurance are woefully inadequate. Consumers should, at the very least, be told clearly and concisely that they could face delays or lose their money by banking with a nonbank.

Second, we must continue to take enforcement actions against nonbanks that make misrepresentations about deposit insurance or misuse the F D I C name or logo.

Finally, for nonbanks like Venmo, PayPal, and Cash App, that offer deposit-style products directly, state and federal policymakers should consider requiring these firms to promptly sweep people’s balances to their linked insured account automatically. Under their state licenses, these nonbank firms are supposed to be in the money movement business, not the banking business of keeping deposits.

This concludes the C F P B Directors’ statement.

If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening.



Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!

We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.

Hire us and gain:

• Peace of mind during your exam process

• Insider knowledge of NCUA procedures and expectations

• Strategies to address potential issues before they become problems

• Continuous access to our extensive subject matter expertise

With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.

Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

  continue reading

102 episodes

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iconShare
 
Manage episode 442944656 series 3543943
Content provided by Credit Union Exam Solutions by Mark Treichel and Credit Union Exam Solutions Inc.. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by Credit Union Exam Solutions by Mark Treichel and Credit Union Exam Solutions Inc. or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://ppacc.player.fm/legal.

www.marktreichel.com

https://www.linkedin.com/in/mark-treichel/


Hello, this is Samantha Shares. This episode covers the Statement of C F P B Director Rohit Chopra, Member, F D I C Board of Directors, on Stopping Fintech Deposit Meltdowns

The following is an audio version of that statement. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

And now the statement.

Statement of C F P B Director Rohit Chopra, Member, F D I C Board of Directors, on Stopping Fintech Deposit Meltdowns

Over the past decade, we have seen a significant incursion into consumer deposit taking and payments activities by companies that aren’t banks or credit unions. These firms want the public benefits of being a bank or credit union, without the public obligations.

This trend poses significant risks. We have developed a legal framework for banks over the past century designed to ensure people’s deposits are safe and that they have constant access to their funds. Deposit insurance and the special F D I C resolution process protect people if the bank fails and they retain quick access to their cash. When nonbanks engage in deposit taking, whether directly or in partnership with a bank, all these protections may not apply.

Today, the F D I C Board of Directors is proposing a rule that would strengthen requirements for banks that partner with nonbanks in offering deposit-style products.

This year, Synapse, a middleman between nonbanks offering deposit-style products to end users and their partner banks, filed for bankruptcy. The firm appears to have failed to properly track customer account balances and may have engaged in other shady practices. As a result, tens of thousands of customers have had their funds frozen for months. The banks have been unable to reconcile all the records necessary to get end users their funds back. This has led to severe harm, especially for people who were using the nonbank account as a primary checking or savings account.

If one of the bank partners had failed, instead of Synapse, the horrible account balance tracking may have prevented the F D I C from making quick deposit insurance determinations and returning funds promptly to end users. When consumers do not have access to their funds, it can undermine confidence in the financial system and ruin lives.

The proposed rule would require banks to maintain records identifying the ultimate end users, their balances, and other information for custodial accounts with transaction-style features. Banks would still be permitted to maintain these records through a third party as long as certain protections are in place, including daily reconciliations to make sure the numbers at the customer-level add up. Banks would also have to maintain constant access to the records, including in the event of the nonbank’s bankruptcy or other disruption. This framework would expedite an F D I C insurance determination if the bank fails and prevent the type of chaos we’re seeing with the Synapse bankruptcy if the nonbank fails.

To be clear, this rule would not address all the risks posed by banking with a nonbank. Even if all the records are appropriately maintained, there still may be some delay in getting end users their money back as the nonbank’s bankruptcy proceeding plays out.1 In addition, nonbank deposit taking offered directly without a bank partner is generally outside the jurisdiction of the federal banking agencies.2 If the firm fails, consumers become unsecured creditors of the nonbank’s bankruptcy estate and may lose their funds.

This proposal must not be the end of our collective work on this issue.

First, disclosure requirements related to the intricacies of pass-through deposit insurance are woefully inadequate. Consumers should, at the very least, be told clearly and concisely that they could face delays or lose their money by banking with a nonbank.

Second, we must continue to take enforcement actions against nonbanks that make misrepresentations about deposit insurance or misuse the F D I C name or logo.

Finally, for nonbanks like Venmo, PayPal, and Cash App, that offer deposit-style products directly, state and federal policymakers should consider requiring these firms to promptly sweep people’s balances to their linked insured account automatically. Under their state licenses, these nonbank firms are supposed to be in the money movement business, not the banking business of keeping deposits.

This concludes the C F P B Directors’ statement.

If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening.



Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!

We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.

Hire us and gain:

• Peace of mind during your exam process

• Insider knowledge of NCUA procedures and expectations

• Strategies to address potential issues before they become problems

• Continuous access to our extensive subject matter expertise

With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.

Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

  continue reading

102 episodes

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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ https://www.linkedin.com/in/mark-treichel/ www.marktreichel.com Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Enforcement actions range from formal to informal, and minor to drastic. Today we discuss what NCUA's philosophy is in this regard. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ The Federal Credit Union Act allows NCUA to remove officials. We explain how. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/enterprise-risk-management-erm Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ The National Credit Union Administration (NCUA) today liquidated Unilever Federal Credit Union of Englewood Cliffs, New Jersey. The NCUA made the decision to liquidate Unilever Federal Credit Union and discontinue operations after determining the credit union was insolvent and had no prospect for restoring viable operations. Member deposits are federally insured by the National Credit Union Share Insurance Fund to at least $250,000. NCUA’s Asset Management and Assistance Center will issue correspondence to individuals holding verified share accounts in the credit union within one week. Members may direct questions and other inquiries concerning their accounts to NCUA’s Asset Management and Assistance Center: Unilever Federal Credit Union c/o National Credit Union Administration 10910 Domain Dr., Suite 200 Austin, Texas 78758 1.877.715.0777 or 512.231.7940 amacmail@ncua.gov Members with additional questions about their insurance coverage may contact NCUA’s Consumer Assistance Center toll free at 800.755.1030. The Center answers calls Monday–Friday between 8 a.m. and 5 p.m. Eastern. Individuals may also visit the MyCreditUnion.gov (Opens new window) website at any time for more information about their insurance coverage. Unilever Federal Credit Union served 1,448 members and had assets of $46,669,599, according to the credit union’s most recent Call Report. Chartered in 1948, Unilever Federal Credit Union primarily served employees of UNUS, Unilever United States, Inc, and its directly or indirectly wholly owned subsidiaries who work in or are paid from Englewood Cliffs, New Jersey. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This episode covers NCUA’s reopening the public comment period on two recently finalized rules that haven’t fully taken effect yet. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. Today, we’re diving into an important update from the National Credit Union Administration. This update comes straight from the April twenty-third Federal Register. If you’re a board member, executive, or compliance officer, you’ll want to pay close attention. On April twenty-third, the NCUA announced something a little unusual—they are reopening the public comment period on two recently finalized rules that haven’t fully taken effect yet. Here’s why this matters. Earlier this year, the White House issued what’s called a “Regulatory Freeze Pending Review.” In plain English, that means federal agencies were asked to hit pause and review any major new rules that hadn’t already kicked in. NCUA, just like other agencies, is now inviting the public—yes, that means you—to weigh in again on two big rules. The first is called Simplification of Share Insurance. This rule was finalized back in September twenty twenty-four and is scheduled to fully take effect December first, twenty twenty-six. The goal is to make NCUA’s share insurance rules simpler and clearer for both credit unions and your members. With this new comment window, you have another chance to raise questions, flag concerns, or support the parts of the rule you think are working. The second rule is about Succession Planning. This one was finalized in December twenty twenty-four and is set to take effect January first, twenty twenty-six. It’s designed to make sure credit unions have solid plans in place for leadership succession—a big deal, especially for smaller credit unions and those with retiring executives. This new comment period is your opportunity to share whether you think the rule strikes the right balance, or if it creates any challenges for your operations. So how can you submit your comments? You have until June twenty-third, twenty twenty-five. You can go online to regulations dot gov and look up the docket numbers for each rule, or send your comments to the NCUA Secretary in Alexandria, Virginia. If you’re old school, you can even hand deliver them. You might be thinking, didn’t we already comment on these rules? Yes, many did—but this is a second bite at the apple, thanks to the new administration’s regulatory review. If your credit union has operational concerns, needs more clarity, or has suggestions for how the rules are implemented, now is your chance to be heard. Here are your quick takeaways. NCUA is actively seeking comments on the share insurance simplification and succession planning rules, both of which are set to take effect in twenty twenty-six. The deadline for comments is June twenty-third, twenty twenty-five. Your feedback could help shape how these rules roll out, or even whether they proceed as planned. That’s it for today’s update. We’ll keep you posted on any new developments and what they mean for your credit union. If you have questions or want to share how your credit union is preparing for these changes, send us a note—we might feature your insights in a future episode. Thanks for tuning in Stay informed, stay compliant, and stay ahead. If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ NCUA Releases Staff Message on the Current NCUA Board Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Understanding Conflicts of Interest in Asset Management: Show Notes In this episode, Samantha Shares explores the critical topic of conflicts of interest in asset management based on the OCC Comptroller's Handbook. While originally created for banks, these principle-based guidelines provide an excellent framework for credit unions managing conflicts in their asset management activities. The episode covers what constitutes a conflict of interest, common scenarios where conflicts arise, the four main risk categories (compliance, operational, reputation, and strategic), and key components of effective risk management. Samantha details specific conflict situations including self-deposits, proprietary investment products, brokerage allocation, and soft dollar arrangements, while outlining four essential principles for handling conflicts: proper authorization, full disclosure, fairness and reasonableness, and maintaining the client's best interest. The episode emphasizes that managing conflicts effectively isn't just about regulatory compliance—it's fundamental to maintaining client trust and protecting your institution's reputation. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Show Notes: Model Risk Management (OCC Comptroller's Handbook) In this episode, Samantha Shares discusses the OCC's "Model Risk Management" handbook (Version 1.0, August 2021). This comprehensive handbook provides guidance on how financial institutions should manage risks associated with their use of models. Key topics covered: Definition of models and model risk Types of risk associated with model use Governance framework requirements Three lines of defense in model risk management Model development, testing and implementation Validation process and requirements Third-party model risk management Documentation and inventory requirements This handbook is essential knowledge for anyone dealing with model risk management in financial institutions, particularly those subject to OCC supervision. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Reach out to learn how we assist our clients. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
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www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ NCUA wants you to build a good contingency funding plan. We discuss their guidance on this important topic. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This episode covers NCUA Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data The following is an audio version of that STATEMENT. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the STATEMENT N C U A Board Member Tanya Otsuka Statement on the Decision to Remove Total Overdraft and Non-sufficient Fund Fee Data N C U A Board Member Tanya F. Otsuka issued the following statement about the agency’s decision to remove total overdraft and non-sufficient fund (NSF) fee data for federally insured credit unions with more than $1 billion in assets from Call Reports beginning with the first quarter of 2025. Member empowerment is a cornerstone of the cooperative credit movement. For credit unions, which are built on the philosophy of “people helping people,” increasing transparency is a simple way to demonstrate the credit union difference, enable consumers to make informed financial decisions, and help maintain trust and confidence in our cooperative system of credit. In that spirit, the N C U A began collecting and publishing quarterly Call Report data on revenues credit unions with over $1 billion in assets made from overdraft and non-sufficient funds (NSF) fees last year. Unfortunately, the fourth quarter 2024 data published today will be the last to include information on overdraft and NSF fee income. On March 3, 2025, Chairman Hauptman unilaterally announced changes to the way the N C U A collects overdraft and NSF fee information. 1 Specifically, starting on March 31, 2025, the agency would “no longer publish overdraft and non-sufficient fund fee income for individual credit unions” and this information would ostensibly be collected during supervisory examinations. This is a step in the wrong direction. There is no data to suggest credit unions limited the services they provide low-income or underserved consumers last year simply to avoid having to report fee income on the N C U A’s Call Reports. Credit unions with higher overdraft and NSF fees also do not appear to offer lower fees to members for other services, nor better interest rates. 2 Overdraft and NSF fees put a strain on members who are likely already struggling and may further trap them in a cycle of financial hardship that can be difficult to escape. That is why providing the public information about fees through the N C U A’s Call Reports enabled consumers across the country to more readily compare between credit unions and choose the institution that best fit their needs. 3 Credit unions are already required to disclose to their members the fees that they charge. Instead of providing overdraft and fee income in a transparent, consistent, and standardized way, collecting overdraft and NSF fee data through the exam process will erode the quality of the data and hamstring our ability to monitor trends. The decision to collect this data through the supervisory process rather than through the quarterly Call Report must not be used as an excuse to withhold it from credit union members or the broader public. Transparency is vital for promoting fair competition within the financial system. Limiting access to individual credit union data does not help consumers, encourage the chartering of de novo institutions, or reduce regulatory burden on small cooperatives, which were exempt from the requirement to report these data. It just enables larger institutions that rely heavily on fee income to operate in the shadows, resulting in less competition and less choice for consumers, and places institutions that stay true to the principles of the credit union movement at a disadvantage. At the end of the day, members, as owners of their credit union, have a right to know how their institution operates, just like any investor would if they purchased stock in a publicly traded company. We shouldn’t keep credit union members in the dark. I urge the N C U A Chair to prioritize transparency and to continue the practice of quarterly reporting and public disclosure of overdraft and NSF fee income for individual credit unions. I look forward to continuing to work with the entire N C U A Board to protect consumers and the credit union system. This concludes the STATEMENT If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ Hello, this is Samantha Shares. This episode covers NCUA Board Member Todd Harper Statement on the Decision to Curtail the Collection of Overdraft and Non-sufficient Fund Fees The following is an audio version of that Statement This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A. And now the Statement. NCUA Board Member Todd Harper issued the following statement about the agency’s decision to curtail the collection of total overdraft and non-sufficient fund (NSF) fees for federally insured credit unions with more than $1 billion in assets beginning with Call Reports for the first quarter of 2025. For markets to work efficiently, transparency is needed. That’s a bedrock principle of economics. And, it’s one of the many reasons why credit union member-owners and the public should have clear visibility into the income a credit union generates from overdraft and NSF fees charged to its member-owners. To advance credit union efforts to benchmark fees against other financial institutions, improve marketplace competition, and increase consumer understanding of the fees they’re charged within the credit union system, the NCUA required federally insured credit unions with more than $1 billion in assets to disclose, separately, income from overdraft and NSF fees beginning with the 2024 first quarter Call Report. With today’s release of the 2024 fourth quarter Call Report results, however, that desirable transparency experiment will regrettably end. During the last year, we’ve found that reporting institutions have collected $3.8 billion in such fees. Some charged no fees at all. For most reporting credit unions, overdraft and NSF fees accounted for between 2 and 5 percent of revenue. Some outliers charged fees amounting to as much as 18 percent of income. For those billion-dollar-plus credit unions with higher overdraft and NSF fees, we also found that they did not use those fees to subsidize better interest rates or lower other fees. Federally insured banks with more than $1 billion in assets began reporting these numbers in 2015. Since then, consumers have benefitted as banks have lowered their reliance on such fees. In fact, the Consumer Financial Protection Bureau found that roughly two out of three banks with $10 billion or more in assets have eliminated NSF fees, saving consumers $2 billion annually. Yet, among credit unions with greater than $10 billion in assets, four out of five continue to charge NSF fees. That overreliance on such fees is one of the many reasons why the NCUA began collecting and publicly reporting this data on Call Reports. But, by unilateral action by the Chairman, credit union member-owners and the public will now no longer have access to this important information. If credit unions are to live up to their statutory purpose of supporting the financial needs of ‘people of modest means and the credit union movement’s oft-touted ‘people-helping-people’ philosophy, then credit union member-owners should have access to this basic market information, so they can make better decisions about how and where to deposit and access their hard-earned money. While the NCUA will no longer publish overdraft and NSF fee income for individual credit unions on a real-time quarterly basis, the agency will instead collect the data during supervisory examinations. This approach, however, will likely shield credit union members from accessing the information through the Freedom of Information Act. Ultimately, this non-disclosure will result in financial exclusion, especially when one considers that NSF is a fee for not paying for an item. In my view, the NCUA should restore fee transparency for overdraft and NSF fees on Call Reports. If the Chairman is unwilling to reverse course, then the overdraft and NSF fee data collected in the exam process at individual credit unions shouldn’t be shielded from public release through the Freedom of Information Act. If such data was once already public information, why now sweep it under the rug? The Chairman also noted that the appropriateness of overdrafts and NSF fees charged is a matter between a credit union and its member-owners. If those member-owners ultimately determine how their credit union is run, then credit union management should make their overdraft and NSF income upon member-owner request. As a steward of the credit union system and someone whose father and grandfather started credit unions, I strongly believe in the concept of a credit union movement to lift up everyone. But, this unnecessary decision moves that credit union movement closer to an industry, one that’s worse than banks when it comes to fee disclosures. Profiting from consumers’ problems will come back and bite you. America’s credit union member-owners deserve better. This concludes the statement. If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC
Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC podcast artwork
 
www.marktreichel.com https://www.linkedin.com/in/mark-treichel/ NCUA Board Member Tanya F. Otsuka Remarks at the 2025 Governmental Affairs Conference As Prepared for Delivery on March 4, 2025 Thank you to Jim, Carrie, and everyone at America’s Credit Unions for the invitation. Special thanks to the convention center staff and everyone behind the scenes who helped put this event together and are making sure it runs smoothly. And of course, thank you all in the audience for being here. It is an honor to serve on the Board of the NCUA and to see the great work credit unions are doing for their members every day. The NCUA’s mission of protecting the cooperative credit system is imperative for the millions of families that rely on credit unions for a checking account, buy a car or a home, or save for retirement. Congress has entrusted the NCUA with the responsibility to protect credit union members and the credit union system, and our ability to do so depends on a strong, independent agency, with dedicated staff who understand the unique role that credit unions play in our economy. Our independence is critical to maintaining confidence and stability in the credit union system. If you put your money in a credit union with the words “insured by the NCUA” emblazoned on the door, you can trust that you won’t lose your life savings if that credit union fails. Share insurance creates confidence in the credit union system, which not only protects Americans’ hard-earned money, but also helps credit unions attract new members and continue to grow. "Congress has entrusted the NCUA with the responsibility to protect credit union members and the credit union system, and our ability to do so depends on a strong, independent agency, with dedicated staff who understand the unique role that credit unions play in our economy. Our independence is critical to maintaining confidence and stability in the credit union system." As the primary federal regulator of credit unions, the NCUA understands the unique characteristics of credit unions and their members. Our independence from politics and distinction from other financial regulators allows us to focus on what matters to the credit union system. It also allows us to maintain long-term stability, mitigate risks and act quickly during a crisis, and prudently manage the share insurance fund. We must not lose sight of why these guardrails are in place. The NCUA, as we know it today, is the product of one too many dark periods in our nation’s history. During the Great Depression, the stock market crashed, our economy collapsed, and thousands of banks failed, wiping out many Americans’ entire life savings. In response, Congress created independent financial agencies and consumer protections – like deposit insurance – to promote stability and provide a safety net for American families. Congress also encouraged the creation of federal credit unions under the Federal Credit Union Act of 1934, allowing more people of modest means to access affordable credit, secure their savings, and ultimately begin to recover from financial hardship. The credit union movement continued to grow, and in 1970, Congress established the NCUA as an independent agency to charter and supervise federal credit unions and manage the Share Insurance Fund, which extended the deposit insurance safety net to credit union members. Fast-forward to the 2008 Financial Crisis, when years of deregulation and lax oversight paved the way for risky and unethical financial practices on Wall Street to wreak havoc on our economy. As financial institutions failed, markets crashed, and businesses shuttered, everyday Americans were left holding the bag. Millions of families lost their homes. While credit unions fared better than banks overall, credit unions were not spared. Between 2008 and 2012, the NCUA oversaw over 130 involuntary liquidations and mergers. To create a more resilient financial system, Congress passed the Dodd-Frank Act, which put in place higher standards for the largest banks and financial companies, established stronger consumer protections, and increased the maximum share insurance for credit union members. "That is why credit unions must continue to show the American people what the credit union difference means and live up to the mantra of 'people helping people.' . . . Too much is at stake to be seen as no different than a bank or a tech company or any other financial institution. The credit union difference is the ultimate competitive advantage." It is no coincidence that credit unions were not the catalyst for our past financial crises. That is a reflection of the credit union ethos. From its inception, the credit union movement has sought to advance access for all and prioritize the economic interests of its members. Credit unions are an integral part of our financial system, serving over 142 million consumers across the United States. Credit unions are often a lifeline for the communities they support. And for many Americans, they are the only source of access to affordable and equitable financial products and services. That is why credit unions must continue to show the American people what the credit union difference means and live up to the mantra of “people helping people.” As not-for-profit, mission-driven institutions, credit unions must embrace the importance of strong consumer protection, lower cost financial products, and service over profit. Too much is at stake to be seen as no different than a bank or a tech company or any other financial institution. The credit union difference is the ultimate competitive advantage. Over the past year, I have focused on small credit unions and promoting and preserving minority depository institutions, and we have made sure that credit unions who have expanded to underserved areas are meeting the needs of those communities. There is much more we would like to achieve, including dedicating more time and staff to support smaller credit unions and looking at proposing a new rule to reimburse credit union board members for childcare and dependent expenses. To accomplish our shared goals, we need an independent regulator designed to regulate credit unions. That is the NCUA. The NCUA is critical to protecting the millions of members who rely on us to safeguard their hard-earned money. By focusing on our mission, we can ensure credit unions are well positioned for the future and able to meet their members’ financial needs in good times and bad. Ultimately, our society benefits from a healthy credit union system that provides access to affordable financial services to those of modest means. Protecting that system is central to why we are all here today. I hope we never forget that. Thank you. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone! We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out. Hire us and gain: • Peace of mind during your exam process • Insider knowledge of NCUA procedures and expectations • Strategies to address potential issues before they become problems • Continuous access to our extensive subject matter expertise With our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination. Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.…
 
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