Matthew J. Biliouris, Director of Supervision
Office of Examination and Insurance
Anticipating Your
Next Exam
June 7, 2013
Part of an Ongoing Process
Call
Report
Review
Policy
Changes
Annual
Exam
FollowUp
Periodic
Phone
Calls
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Before the Exam
• Scheduling the Exam
– EIC will call to schedule the examination
• Information and Request Letter
– Information on Examination (i.e., Examiner-in-Charge (EIC),
start date, list of participants, etc.)
– List of Information Needed for the Examination
• Items Needed for Examination
–
–
–
–
Be complete
Have the items ready when the examiners arrive
Label the items with corresponding numbers as requested
If you have questions, call the EIC. Don’t wait.
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Day One
• Entrance Meeting
– Schedule time to meet with the EIC/Exam Team
– Discuss changes since the preceding exam
• Introductions
• Working Space
– Provide adequate space, privacy, conditions, and
seating for the exam team.
• Set Expectations
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Day One
• Other Helpful Suggestions
– Organizational Chart
– List of credit union contacts
– Management’s schedule
– Passcodes or badges
– Building map
– Power strips, if available
– Food recommendations
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Communication
• Try to be open and honest when
communicating with your examiner.
• Be responsive to examiner requests.
• Be prepared to discuss new products and
services
– Advance Strategic Planning
– Internal Controls that have been implemented
– Ongoing Risk Mitigation Efforts
– Board Reporting
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Communication
• Preceding Examination Concerns
– Be prepared to discuss the corrective actions
taken in response to the findings at the preceding
examination.
• Exit Conference
– Open Dialogue
– Agreements and Commitments
• Joint Conference
– Options for credit unions
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Communication
• Examination Report
– Examiners are encouraged to provide the credit union with a
draft copy of the exam report so it can be reviewed before the
exit interview.
– The report should be received by the credit union as early as the
Exit Conference or the examiner has up to six business days
after the Exit Conference to mail the report.
– The report should be read by the Manager/CEO, all Board
Members, and the Supervisory committee, regardless of the
CAMEL rating.
– Any questions about the content of the report, should be
directed to the examiner.
– If you have issues with or disagree with the report:
• Contact the examiner or Supervisory Examiner
• Instructions on filing an appeal are contained in the cover letter to the
report.
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Following the Exam
• Monitor status update on items needing
corrective action
• Inquiry about local or regional economy or
news items
• Perform quarterly financial performance
analysis
• Respond to inquiries from credit union
– Strategic vision
– New products or services
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What Should the Supervisory Committee Expect?
• Be prepared to discuss/present information
about your periodic reviews & Verification of
Member Accounts
• Examiners want to:
– Review work papers
– Ensure your work papers are organized
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What Should the Supervisory Committee Expect?
(continued)
• NCUA’s examiner determines if the
Supervisory Committee:
– Fulfills obligation as an independent watchdog of
the credit union
– Ensures an annual audit is made
– Ensures a report of that audit gets submitted to
the board of directors
– Provides a summary of the report to the members
at the credit union’s next annual meeting
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Annual Audit Schedule
• Create an annual audit schedule identifying:
– Review Areas
– Frequency of Reviews (Monthly/Quarterly)
– What is specifically reviewed ( example: all paid
ahead loans)
– Identify Party Responsible for each review area
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Annual Audit Schedule
Sample Audit Schedule
Audit/Review
Recommended # of
times per year
Follow up on prior audit or
examination report
File Maintenance Review
Monthly
Review shares under a
specified $ amount
2 times per year
Paid ahead loan report
Loans by Interest Rate Report
2 times per year
2 times per year
Dormant Account Report
2 times per year
Delinquency Review
2 times per year
What to review each
time
All Items from the previous
audit/exam outstanding
Monthly or as often as possible All reports for the month
Randomly select at least 10
days throughout the month
other than month end
Loans paid ahead 3 months
All loans
All new dormant accounts on
report
All accounts for the month
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How to Review and Comment on Proposed
NCUA Regulations
• NCUA proposes regulations for federally
insured credit unions
• NCUA encourages comments on proposed
rules because it enhances the rulemaking
process
• Officials are encouraged to review and send
comments on proposed regulations
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How to Review and Comment on Proposed NCUA
Regulations
• The public can visit NCUA.GOV to review
regulatory proposals and view other proposed
rule comment letters before writing a comment
letter
• All proposed rule comments are categorized by
content and reviewed internally prior to NCUA
drafting final regulations
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How to Review and Comment on Proposed NCUA
Regulations
• Tips for commenting on proposed regulations
continued:
• Comments should specify unintended consequences to
proposed rules
• Comments should propose reasonable alternatives to
new rules if proposed rules are burdensome
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Questions??
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Office Contact Page
Feel free to contact our office with questions or
comments.
Staff:
Matthew J. Biliouris
Director of Supervision
Office of Examination & Insurance
matthewb@ncua.gov
Amanda Parkhill
Loss Risk Analysis Officer
Office of Examination & Insurance
aparkhill@ncua.gov
Maggie Miller
Program Officer
Office of Examination & Insurance
mmiller@ncua.gov
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