CUNA anticipates that NCUA moving to more offsite examinations will have a positive impact on the industry, despite an early learning curve. CUNA submitted comments Monday on NCUA’s Request for Information (RFI) on future examinations using technology.

“We are encouraged by the current RFI, as it shows the agency has elevated its focus on shifting to offsite examinations. We are excited for the agency to utilize input received in response to this RFI to develop an implementation strategy that reduces burden while maintaining the agency’s ability to determine whether federally insured credit unions (FICU) are operating safely and soundly and in compliance with applicable laws and regulations," the letter reads. "We believe an examination model that enables examiners to review a credit union’s operational and financial condition from an alternate worksite, such as a home office, is wholly appropriate, given adequate safeguards from both the credit union and the NCUA are in place.”

The letter emphasis the importance of NCUA adhering to “even more rigorous security standards [than FICUs] given the fact that the agency receives sensitive information from all FICUs. It is critical that the agency not only adhere to such standards but also be transparent in its compliance with safeguards. We urge the agency to share information with the industry that is sufficient to allow credit unions and other relevant stakeholders to ensure the agency—including any third-party vendors it works with—follows proper protocols.”

Other highlights of the letter include:

• Credit unions should provide the capabilities necessary for data security and encryption so that data transfers can be made without risk of compromise by outside parties
• NCUA should be more forthcoming on what it plans to review, what data it needs from credit unions and what efforts credit unions can take to correct any compliance issues;
• There is concern that a lack of face-to-face interaction could cause communication challenges. Increased reliance on video communications could be helpful, as could regular onsite meetings at least two or three times a year for a couple of hours per visit;
• For smaller credit unions, there is a concern about the burdensome requests that may be an issue in producing certain information electronically;
• Small credit unions must have the ability to effectively communicate with the NCUA on a regular and as-needed basis. NCUA should incorporate a process for such timely communication into an offsite examination model.

CUNA also recognized recent efforts by NCUA to extend the examination cycle for certain credit unions and urged the agency to extend the credit union asset threshold for the 18-month examination cycle to $3 billion (up from the current $1 billion).