California and Nevada's voice in Washington D.C. The Leagues are the only Leagues with a full time staff dedicated to working with Congress, Government Agencies, and Federal Regulators. The resources in this area will help you keep informed of the latest developments and credit union priorities.
State Government Advocacy efforts brings the voice of credit unions to Sacramento and Carson City. Our advocacy team works daily with elected officials, staff, the executive offices, gubernatorial appointees, and the decision-makers of California and Nevada. This area will keep you updated on all advocacy efforts at the state level of Government.
|Sharon Lindeman, Vice President of Regulatory Advocacy for the California and Nevada Credit Union Leagues|
The NCUA noted that before making the changes, they considered feedback from credit union industry officials, as well as specific report recommendations by the Government Accountability Office (GAO) and NCUA’s Office of Inspector General (OIG).
One change highlighted in the letter: The Document of Resolution (DOR) and Examiner’s Findings will now be stand-alone documents. The expectation is that having a separate DOR document to focus on will improve clarity and communication of critical and material items, and help credit unions implement timely corrective action plans.
Outstanding DOR Items
Another specific change outlined in the letter is that 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. Revised Chapter 13 of the National Supervision Policy Manual (page 8) expands on this:
The Leagues' Review
The California and Nevada Credit Union Leagues have noted the manual left the door open for examiners to issue DORs based on opinion rather than failure to meet specific requirements addressed in law, regulation, or guidance. The manual (page 12) states that when drafting a DOR, an examiner shall:
"We are disappointed with this language," said Sharon Lindeman, vice president of regulatory advocacy for the Leagues. "It was our hope that any examination improvements would include that all findings be supported by specific laws or regulations. The Leagues will continue to advocate for this with the NCUA."
On a positive note, Lindeman was pleased to see the manual specifically state that unresolved Examiner’s Findings should not be automatically escalated to a DOR. Of course, numerous uncorrected findings could be reflected in a credit union’s management rating and/or as a separate DOR issue. In discussing what should be included in/excluded from a DOR, the manual (page 7) states:
The Leagues encourage all credit unions to review Letter to CUs 13-CU-09— Examination Report Modernization and its attachments.
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