On December 5, Scott Simpson and I joined league professionals from other NCUA Western Region states to meet with the Western Region Director, Cherie Freed, and several of her top staff members.
The meeting is an annual tradition, and over the years we’ve developed a cordial rapport with Cherie. She and her team members are personable and diplomatic. The conversation is always friendly.
It’s worth relating a few things that were said. I won’t bore you with a minute-by-minute breakdown of all 3 hours.
At the very close of the meeting, after we’d covered the pre-planned discussion topics. Scott Simpson, the intrepid president of our Utah association, raised his hand and asked to revisit the first topic on the list.
The topic was how the NCUA’s top leadership was throwing around words like “junk fees”.
Scott wanted to make sure Cherie understood that despite the friendly and cordial nature of the meeting, and how quickly the topic was covered earlier that morning, Utah credit unions—and all credit unions—are puckering over how a the NCUA board chairman is joining in his political party’s rhetoric against legitimate fees used to help consumers manager their behavior.
In no uncertain terms—but in an even tone—Scott expressed the importance of these fees to credit unions as they manage their business and deter negative member practices. He offered to flip over a table if it would help convey the seriousness of our point of view. Cherie assured him it wasn’t necessary.
Another item worth mentioning is the conversation surrounding exam findings and exam reports.
Credit unions routinely express frustration with recommendations from examiners being listed as findings on the final exam report. It’s a common topic at the meetings.
The NCUA team, careful not to roll eyes at the issue being raised again, patiently explained that in an exam report, findings must always be accompanied by citation of a rule or law. The region has a quality control process in place to ensure that such findings do have a citation.
The report may also include other items—recommendations—that are not findings. NCUA staff members indicated that these recommendations are optional. The credit union should consider them, but ultimately can completely ignore them. In the report, they will be differentiated from findings by being in a different section of the document.
The NCUA team also discussed the dispute process. If a credit union would like to dispute a finding on the exam report, credit unions can reach out to Cherie Freed. She indicated that she receives perhaps 5 disputes each year, and places heavy emphasis on not retaliating against credit unions who raise disputes. There should be no reason to dispute an item on the report that is not a finding—a recommendation. It’s not required to address those; there’s no reason to dispute them.
If you’d like to hear more about what we discussed at the meeting, please reach out.