In an opinion piece appearing in CU Today, National Credit Union Administration (NCUA) Board Member Todd Harper wrote that customers of a bank acquired by a credit union will not have the same level of consumer financial protection oversight in their new credit union.
He pointed out in the column that the Federal Deposit Insurance Corporation (FDIC) has a more robust consumer compliance program than NCUA.
He noted that FDIC regularly conducts dedicated consumer compliance reviews that are separate and apart from safety and soundness exams, while NCUA with the exception of fair lending exams combines consumer compliance exams as part of the agency's safety and soundness exams performed NCUA's regional offices.
The agency has only budgeted for 30 fair lending examines in 2020. Also, the consumer compliance exams conducted by NCUA's regional offices will only cover some of the many consumer financial protection laws on the books.
He further stated that the agency has only 15 or so regional examiners, who are consumer compliance subject matter experts. In comparison, the FDIC has hundreds of examiners committed to performing these exams.
Despite his reservations about the agency's consumer compliance oversight gap, he still supports the agency's proposed rule on combination transactions.
Read the opinion piece.
There is no NCUA requirement for a compliance officer to be appointed by a credit union for general compliance responsibilities at any asset level. Similarly, there is no requirement for separation of internal audit and compliance responsibilities at credit unions regardless of asset size. That becomes a problem when "NCUA does not require" is the decision maker as to creating/funding such aspects of the credit union.
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