๐๐ผ๐ ๐ช๐ถ๐น๐น ๐ก๐๐จ๐ ๐ฒ๐ ๐ฎ๐บ๐ถ๐ป๐ฒ ๐ฆ๐ต๐ฎ๐ฟ๐ฒ ๐ข๐๐ฒ๐ฟ๐ฑ๐ฟ๐ฎ๐ณ๐๐ ๐ถ๐ป ๐ฎ๐ฌ๐ฎ๐ฏ?
Yesterday NCUA held an industry webinar on 2023 Supervisory Priorities that included the following information on the scope of review for Overdrafts:
At complex #c reditunions (>$500m+) Examiners ๐๐ถ๐น๐น ๐ฟ๐ฒ๐๐ถ๐ฒ๐:
โข Website Advertising;
โข Balance Calculation Methods;
โข Settlement processes
โข Member Statements and disclosures related to PALS II loans; and
โข Management's actions to address unanticipated overdraft fees.
With CFPB inventing the new term Junk Fees and an apparent ever-increasing NCUA review of overdraft programs, you should be reviewing this area closely now and in the years ahead. I expect NCUA's scope in 2024 will expand in general and also include smaller credit unions.
Watch for future stories and podcasts on NCUA's Supervisory Priorities soon.
Interested in learning how my team of former NCUA subject matter experts assist credit unions in dealing with NCUA? Email me at info@marktreichel.com
NCUA's full letter on Supervisory Priorities can be found here:
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