CUNA expressed concern to NCUA that examiners will view the lengthy “guidance” accompanying the
new regulation as a “checklist.”
To address this concern and also concerns about examiners’ inconsistent application of regulations, NCUA has conducted examiner training.
“It’s not the intent of the rule for examiners to subjectively impose unduly standardized supervisory oversight,” the agency says. “Examiners will be expected to apply the standards within a consistent framework based on their knowledge of each credit union’s operations and available resources.”
Expect examiners to ask questions about IRR policies and programs even before the compliance date at the end of September.
Before approving the new IRR regulation last winter, the NCUA Board asked its staff: “Why should we put this regulation in place since interest rates aren’t expected to rise notably any time soon?”
“It’s good to repair the roof before it rains,” agency staff answered.
So get your IRR policy and program nailed down in the coming months.
COLLEEN KELLY is federal compliance counsel for CUNA.
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