What additional information has NCUA issued regarding exams?

NCUA issued Letter to Credit Unions 20-CU-17 on 5/28/20 that provides an Agency update regarding Offsite Examination and Supervision Approach.

What impact is this having on the NCUA’s examination and supervision program?

Effective Monday, March 16, 2020, all examination related staff are required to be offsite through at least March 30, 2020. This policy will be reevaluated at least every two weeks and is subject to change. Any exceptions to this policy must be approved by the Office of the Executive Director. Generally staff will not be scheduling any onsite exam work until further notice. However, NCUA may conduct onsite work at a credit union if necessary to deal with an exigent circumstance.

NCUA examiners will take advantage of technology to securely exchange information, and will use teleconference and videoconference capabilities to interact with credit union management.

Source: NCUA Actions Related to COVID-19; LCU 20-CU-02

What technology is available to credit unions to share exam documents with their examiners?

Examiners and credit unions can exchange information through the NCUA’s Secure File Transfer Portal (STFP). A credit union guide for using the SFTP portal is available online, and provides instructions to access and use the portal. The STFP is a protected workspace where NCUA staff and partners can share large or sensitive files.

The SFTP portal is the preferred method for exchanging information; however, other secure methods may be used to share examination documents.

NCUA examiners can initiate an encrypted email exchange using the Zix Gateway. Recipients without Zixit will receive an email notification and, for first time users, will be required to register an account to receive the secure email message. Returning users will enter their password to sign in to receive the secure email message. To respond securely, recipients must respond using the link within the original encrypted email message.

Password-protected zip files may be used. Strong passwords should be used. NCUA examiners must use strong passwords that meet current agency requirements.

Credit union file transfer portals are permitted under certain conditions. NCUA examiners may use a credit union’s portal or other non-portable electronic transmission solution to download electronic documents that contain PII. NCUA staff will not use a credit union or third party provided solution to upload or transfer any electronic documents (whether they contain PII or not) to the credit union or third party.

Source: NCUA Actions Related to COVID-19; LCU 20-CU-02

For California state-chartered credit unions, beyond needing to report branch closures, are there any other notification requirements to DBO and/or NCUA regarding changes to normal business practices?

The DBO, like the NCUA, has no other required notifications at this time. However, both agencies advise keeping your examiner up-to-date, as that will help with the next examination or contact. Also, if a credit union has any outstanding Documents of Resolution they definitely should be discussing those with the applicable agency along with the timing requirements based on what is happening.

Has NCUA issued any additional information regarding exams or supervision?

Yes, NCUA issued an Offsite Examination and Supervision Approach—FICU 20-CU-05 letter to Federally Insured Credit Unions (March 30, 2020). This letter provides information on NCUA’s three priorities:

  • Priority 1 — Credit Unions Experiencing Problems
  • Priority 2 — Contacting All Credit Unions
  • Priority 3 — Conduct Examinations Offsite