Wednesday, November 5, 2014
Hear No Evil, See No Evil, Speak No Evil
Bank regulators -- Federal Deposit Insurance Corporation, Federal Reserve, and Office of the Comptroller of the Currency - are aggressively pursuing banks for violations of the National Flood Insurance Act.
However, I have not seen the same regulatory zeal from the National Credit Union Administration (NCUA) regarding credit union flood insurance compliance.
In fact, I don't recall NCUA publicly citing any credit unions in recent history for flood insurance violations.
It is hard to believe that there is not a single credit union out of compliance with the flood insurance requirements. After all, there are over 6,000 credit unions and credit unions accounted for 7 percent of all mortgage originations, according to the 2013 HMDA data.
I suspect the dearth of flood insurance violations is because NCUA fails to do a deep dive into credit union books regarding flood insurance compliance.
So, while banks and credit unions are subject to the same requirements on flood insurance, there are differences between bank and credit union regulators with regard to the enforcement of these requirements.
NCUA would rather hear no evil, see no evil, and speak no evil about credit unions.
However, I have not seen the same regulatory zeal from the National Credit Union Administration (NCUA) regarding credit union flood insurance compliance.
In fact, I don't recall NCUA publicly citing any credit unions in recent history for flood insurance violations.
It is hard to believe that there is not a single credit union out of compliance with the flood insurance requirements. After all, there are over 6,000 credit unions and credit unions accounted for 7 percent of all mortgage originations, according to the 2013 HMDA data.
I suspect the dearth of flood insurance violations is because NCUA fails to do a deep dive into credit union books regarding flood insurance compliance.
So, while banks and credit unions are subject to the same requirements on flood insurance, there are differences between bank and credit union regulators with regard to the enforcement of these requirements.
NCUA would rather hear no evil, see no evil, and speak no evil about credit unions.
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Writer's block must be incredibly frustrating.
ReplyDeleteFirst let me say that I am sure this is not the case at all credit unions.
ReplyDeleteBut here it goes:
This does not surprise me at all. I work for a decent size ($7B) Community Bank. We provide outstanding service, we are well trained, and we do what is in the best interest of our customer--it's an amazing concept--thus we are pretty darm successful.
I run into a lot of local credit union associates at various Community events and I am stunned at the lack of knowledge and training. You can see the blank look on thier faces as you are talking about certain regulations and new CFPB items. These aren't tellers I am talking to these are Loan Officers and Branch Supervisors. They are good people with good intentions and great CU cheerleaders, but it is stunning to me what they don't know.
The only reason has got to be lack of oversight.
Do not think that it is any different with the employees of banks. And be real. Do you honestly expect employees on the line are going to read and be knowledgeable about the massive amount of regulations pumped out each day by the CFPB? Attorneys for banks, and yes credit unions too, as well as the attorneys on staff for the regulators do not understand them. So please do expect so much from those who are not paid the big bucks to have all the answers.
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