Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA Proposes to Loosen Associational Common Bond RulesThe NCUA Board has issued a proposed rule that would amend the associational common bond provisions of its Chartering and Field of Membership Manual. Comments are due by June 8, 2026.What NCUA is proposing:Eliminate the automatic bar that currently disqualifies an associational group from FCU field of membership eligibility when the group requires purchasing a product or service as a condition of membership.Replace the bright-line rule with a totality of the circumstances review, looking at the group's structure, scope, degree of activities, and other operational factors.Clarify that a client-customer relationship can exist, even as a condition of membership, as long as it remains incidental to the group's overall purpose and activities.Use an example of a fraternal association that requires insurance purchase - under the proposal, this would no longer be automatically disqualifying.Why the change:The Board believes the automatic bar goes beyond what the FCU Act actually requires.Neither the FCU Act nor the Credit Union Membership Access Act of 1998 (CUMAA) specifies that a client-customer relationship is automatically disqualifying.The change is intended to enhance consumer access to financial services and eliminate an inflexible restriction, consistent with Executive Order 13563 and deregulatory goals under Executive Order 14192.Moves NCUA toward a principles-based approach rather than a rigid rule.What is NOT changing:Associations based primarily on a client-customer relationship still do not qualify.Health clubs, including YMCAs, remain examples of groups that do not meet the associational common bond requirements.Retail loyalty clubs still would not qualify, since their core reason for existence is the client-customer relationship.The rule does not affect occupational common bond charters, community charters, or federally insured state-chartered credit unions.The core associational common bond definition - members of a recognized association who participate in activities developing common loyalties, mutual benefits, and mutual interests - remains intact.Pre-approved categories of groups under the 2015 automatic qualification amendments are unaffected.10,000-foot takeaway: NCUA is moving from a rigid "if you require a purchase, you're out" standard to a more flexible "look at the whole picture" standard. Associational groups that previously couldn't qualify because membership required buying a product or service may now have a path forward - but only if the client-customer piece is genuinely incidental to why the group exists. If selling something is the core reason the group was formed, the group still doesn't qualify. For FCUs looking to expand their field of membership through associational groups, this proposal could open doors that have been closed for decades. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The NCUA just released its 2026 Supervisory Priorities (Letter 26-CU-01), giving credit unions a heads-up on where examiners will be focusing this year.Here's what you need to know:The NCUA is doubling down on balance sheet management, with particular attention to lending, interest rate risk, liquidity, earnings, and capital adequacy. Loan delinquency and loss rates are at their highest in over a decade, and examiners will be looking closely at underwriting, loss mitigation, ACL reserves, and charge-off practices.Operational risk is a major theme. Payment systems, fraud prevention, and cybersecurity will all get heightened scrutiny as the payments landscape grows more complex and fraud risks continue to rise.BSA/AML compliance remains a priority, with an emphasis on risk-based programs tailored to each credit union's profile. Expect regulatory changes throughout the year as FinCEN and the NCUA continue implementing provisions of the Anti-Money Laundering Act of 2020.The agency is also signaling a shift toward a more efficient and tailored examination program, building on its 2025 efforts to reduce burden for both credit unions and NCUA staff. Defined scope exams will continue for most federal credit unions with $50 million or less in assets.What is NOT changing: The NCUA will continue enforcing all existing laws and regulations, including consumer financial protection and information security requirements. Risk-focused procedures remain the standard for larger credit unions.The 10,000-foot takeaway: Asset quality and earnings pressure are the story of 2026. Credit unions that can demonstrate strong risk management practices across lending, liquidity, and capital planning will be well positioned. Now is the time to review your ACL methodologies, stress testing, contingency funding plans, and BSA programs before examiners come knocking.One more thing worth noting: the NCUA reminds credit unions they may record their final exit meeting or joint conference for documentation and training purposes.If your credit union could use help preparing, visit MarkTreichel.com or reach out to Mark Treichel on LinkedIn. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Changes for Corporate Credit Unions – 12 CFR 704.8 and 704.15NCUA is proposing to amend its regulations for corporate credit unions by removing the requirement that a corporate credit union’s asset and liability management committee (ALCO) must have at least one member who is also a member of the corporate credit union’s board of directors. Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ the Board, seeks comment on a proposed rule to remove the segregated deposit and collateral requirements when a federally insured credit union, referred to as a F I C U, acts as a surety and guarantor. Removing this regulation will provide F I C U s with greater flexibility to design products that meet member needs. F I C U s would remain subject to the other requirements regarding surety and guaranty agreements.  Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA's 2026 Priority Letter to Credit Unions is out! Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union achieves flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.