2011.03.22_SAS_Workshop_Exam_Rights

LSCU Small Credit Union Workshops March 22 and 23, 2011

LSCU Regulatory Compliance Examination Bill of Rights

Regulatory Affairs Contact Information  Bill Berg

Vice President of Regulatory Affairs  

866.231.0545, ext. 1028 bill.berg@lscu.coop

 Scott Morris

Director of Compliance  

866.231.0545, ext. 2165 scott.morris@lscu.coop

Examination Bill of Rights 

SUPERVISORY ISSUES AND EXAMINATIONS

The regulatory environment for credit unions has changed dramatically since 2008 due to:    

Real Estate / Economic crisis Subsequent Weak / Tepid Recovery Regulators Emphasis on Credit Union Performance Increased Attention to Safety and Soundness Issues

Examination Bill of Rights 

SUPERVISORY ISSUES AND EXAMINATIONS

Credit unions benefit from strong, reasonable safety and soundness supervision. Leagues across the country support a review process that: 

Allows regulators to perform oversight duties efficiently and effectively.



Permit credit union officials to exercise sound business judgment and operate in the best interest of members.



Provide a reasonable balance between regulator and credit unions official working together yet independent of the other for the benefit of the institution.

Examination Bill of Rights SUPERVISORY ISSUES AND EXAMINATIONS Based on directives from the NCUA Examiner’s Guide, the list of rights available to credit unions includes the types of processes, procedures and professionalism credit unions should expect during examinations.

Section I -

General duties of Examiners.

Section II -

Responsibilities of CU officials

Section III - Resolving disagreements with examiners and regulators

Examination Rights Summary Section I: General Duties of Examiners The NCUA and state credit union regulators follows a risk-focused examination program in which examiners evaluate a credit union’s performance based on its financial condition and management’s ability to identify, measure, monitor, and control current and potential risks.

Examination Rights Summary 

General Duties of Examiners / Risk

Examiners review policies, practices, personnel, and control procedures for managing risks in seven key areas: 

Credit risk – Are credit union loans and investments performing well?



Interest rate risk – Are changes in interest rates affecting credit union products and investments?

Examination Rights Summary 

General Duties of Examiners / Risk 

Liquidity risk – Can the credit union meet its current obligations when due and could it quickly liquidate assets if necessary without sizeable losses?



Transaction (or operational) risk – Does the credit union maintain adequate internal controls and can it process transactions, deliver products and services, and manage information flows well?

Examination Rights Summary 

General Duties of Examiners / Risk Considered 

Compliance risk – Is the credit union meeting its compliance responsibilities and preparing for future requirements, and are credit union officials meeting their fiduciary duties?



Strategic risk – Are the credit union’s strategic goals appropriate and reasonable; do the credit union’s business decisions line up with its goals?



Reputation risk – Has the credit union avoided negative publicity or minimized the impact of negative publicity, given the current economic circumstances?

Examination Rights Summary 

Role of Credit Union Officials

The priorities, expertise, and commitment of credit union management and board are essential to effective risk management. 

Well-defined policies and CU procedures, including monitoring systems, are characteristics of well managed credit unions.



Credit union’s should always cooperate with examiners to provide requested data and materials and access to personnel.

CU and examiner cooperation, including in the development of solutions to problem areas, will help ensure the credit union benefits from the examination.

Examination Bill of Rights 

Credit Union Examination Rights

“Credit unions have the right to manage risk without being directed by examiners to eliminate it.”

NCUA Examiner’s Guide (NEG) page 1-3.

Commentary: Examiners should not ―insist that a credit union eliminate risk but, instead, should ensure that credit unions identify and manage their risks. The desired reward for taking risk is stable profitability and increased net worth. Credit unions must balance risk and reward responsibly.

Examination Bill of Rights 

Credit Union Examination Rights “Credit unions have the right to respectful conduct from the examiner.”

NCUA Examiner’s Guide (NEG) pages 21-3/4

Commentary: Credit unions expect examiners to always act professionally— which they do most of the time, according to credit unions. However, if a credit union feels that an examiner has stepped over the line in terms of conduct, the credit union should report the incident to the supervisory examiner or regional office, without fear of retaliation.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to question and seek corrections to examiner findings, conclusions, and directives.“ NCUA Examiner’s Guide (NEG) page 1-15 Commentary: Accuracy is essential to a strong safety and soundness regulation. Examiners are human and humans make mistakes. It is important and appropriate that credit unions work with examiners to ensure all reports and directives are as accurate and timely as possible.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to know the specific authority or legal basis for an examiner’s directive, and this authority should be provided by the examiner in the exam report or directive.”

NCUA Examiner’s Guide (NEG) page 20-7 Commentary: NCUA examiners must be willing and able to provide to credit union officials the legal authority for the action they are suggesting or directing the credit union to take. In addition, examiners do not have flexibility to insist on actions or policies that are counter to or inconsistent with statutes, agency policy, or GAAP.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to receive clearly written examination reports in a timely manner. Any other directives and notices from the examiner should also be clearly communicated in writing.”

NCUA Examiner’s Guide (NEG) page 20-1 Commentary: Credit unions should not be expected to comply with directives that are not in writing. In order for the credit union’s record of performance, including efforts to address problem areas, to be as accurate as possible, directives should be provided in writing to the credit union and included in the credit union’s examination history.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to have examination reports, findings, directives and administrative actions that are based on all relevant facts, including current data.”

NCUA Examiner’s Guide (NEG) page 1-27 Commentary: The examination report should present a current, factual picture of the credit union’s financial performance and risk management. When material problems arise that the examiner expects the credit union to correct, the record must include a complete and well-documented accounting of the problems and the efforts by the credit union and the examiner to address them fully.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to be evaluated on their own strengths and weaknesses and not solely on the basis of regulator concerns about trends or general problems in the credit union system or within their peer group.”

NCUA Examiner’s Guide (NEG) page 3-5

Commentary: While examiners must be mindful of problems and conditions in their regions and even across the country, it is essential for the accuracy of each credit union’s examination report that the examiner’s assessment reflects an accurate depiction of the performance and operations of the credit union under review.

Examination Bill of Rights 

Credit Union Examination Rights “Credit unions have the right for their examination findings and directives to be risk prioritized.”

NCUA Examiner’s Guide (NEG) pages 1-1 & 20-1

Commentary: Examiners are directed to focus their reviews and reports on applicable risks, and those activities that present the greatest risk receive the most attention. A standard procedure that the examination findings and directives must be listed in order of their importance based on the amount of risk presented is fully consistent with the risk-focused exam process.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to appeal examiner findings, conclusions, or directives without fear of retaliation from their regulator.”

NCUA, Interpretive Ruling and Policy Statement (IRPS) 02-1

Commentary: The FCU Act states credit unions have the right to appeal supervisory determinations to the NCUA Board. Appeals can include cease and desist, removal of officials, and conservatorships. Material examination report findings, conclusions, and directives from the examiner may also be appealed. DORs and LUAs are not generally eligible because they are technically considered voluntary agreements, but the credit union should be able to appeal to the regional director as part of the DoR or LUA process.

Examination Bill of Rights 

Credit Union Examination Rights “Instructions on how to appeal examiner findings, conclusions, or directives should be detailed on every examination report form that is provided to credit unions.”

NCUA Examiner’s Guide (NEG) page 17-1.

Commentary: NCUA’s process for allowing an appeal is not clear.

NCUA, ACUA, and OFR regulators should ensure that all examination report forms which examiners provide to credit unions include sufficiently detailed information as to which issues may be appealed/challenged and the process for making such an appeal.

Examination Bill of Rights 

Credit Union Examination Rights “Credit unions have the right to have any published orders—at least consent orders—address only facts and not conjecture or speculation by the examiner.”

NCUA Examiner’s Guide (NEG) pages 20-1, 20-6, and 30-3

Commentary: Published orders must be based on facts in an exam report reviewed by the credit union. The Examiner’s Guide states the examination report must reflect documentation to support an examiner’s findings and conclusions. For the confidential section of the report, examiners should only cover pertinent matters that are based on fact, and not statements based on gossip or hearsay.

Examination Bill of Rights 

Credit Union Examination Rights “Credit unions have the right to develop and use highlevel policies, which should be separate and distinct from detailed procedures.”

NCUA Examiner’s Guide (NEG) page 21-5.

Commentary: Examiners should not dictate broader credit union policies, but rather should lead and persuade officials to proper action. Credit union management and officials have the right to use business judgment in developing their policies.

Examination Bill of Rights 

Credit Union Examination Rights “State credit unions have the right to a lead examiner that is a state regulator, consistent with the credit union’s charter type.”

NCUA Examiner’s Guide (NEG) page 22 B-3

Commentary: NCUA staff often accompanies state regulators during the examination of state-chartered credit unions, particularly on federal hot button issues such as MBL and indirect lending. Thus, it is important that the lead examiner be comparable to the credit union’s charter type. It is also important that the state regulator—not NCUA— be responsible for assigning the credit union’s CAMEL rating during an examination.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to know the timing of when their regulators, such as NCUA, will publish an LUA.” NCUA Examiner’s Guide (NEG) page 29-10 Commentary: The NCUA should provide notification to a credit union of the date a pending LUA will be published. Currently, credit unions are learning about publication by either checking NCUA’s website or, more likely, via NCUA’s mass emails—which can be unintentionally inflammatory. NCUA should follow the lead of a number of state regulators that inform the credit union on when publication will occur.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to defer to their certified public accountant (CPA) in a disagreement between the officials and their regulator regarding issues related to U.S. generally accepted accounting principles.”

NCUA Examiner’s Guide (NEG) pages 5A-4 and 7-28 Commentary: CUs over $10 million in assets are required to follow GAAP with a CUs CPA responsible for ensuring that the activities and financial statements are in compliance with GAAP. Therefore, to avoid becoming involved in specific accounting issues, an examiner should not seek to override the CU’s CPA when disagreements on accounting issues arise.

Such practice will benefit not only the credit union but also the examiner by freeing up its resources.

Examination Bill of Rights 

Credit Union Examination Rights “Credit union officials have the right to communication (i.e., draft findings) with their examiner prior to final issuance of the examination report.”

NCUA Examiner’s Guide (NEG) page 21-1

Commentary: Examiners should set aside ―time periodically to discuss with management and officials developments in the examination. In addition, an examiner should provide ―credit union officials and management sufficient time to review it before the joint conference or exit interview.

Examination Bill of Rights 

Credit Union Examination Rights “Credit unions have the right to expect directives from examiners (including verbal & written comments) to be consistent with agency policy, such as NCUA’s letters to credit unions.”

NCUA Examiner’s Guide (NEG) pages 3-1, 6-15, 6-16, 6- 20, 7-35, 9A-18, and 10-1 – 10-14 Commentary: NCUA examiners must follow the guidelines in the Letters to Credit Unions. For example, the Examiner’s Guide states that credit unions must follow Letters to Credit Unions in areas such as CAMEL ratings, risk-based lending, and risk management.

Examination Bill of Rights 

Examination Appeals Process 

Informal Examination Appeals • Appeal of Material Operating Exceptions   



Violation of Law or Regulation Unsound Policy Unsafe Procedure or Practice

Timing of Informal Examination Appeals • CU can submit written appeal to Regional Director w/in 30 days of receipt of Exam Report.

• Within 60 days of receipt, Regional Director will send written response and take corrective action, if necessary.

• If Regional Director fails to respond or credit union wishes to appeal Director’s decision, a written appeal (with CU Board approval) can be submitted to the Supervisory Review Committee (SRC).

Examination Bill of Rights  Examination 

Appeals Process

Informal Examination Appeals (SRC) • SRC is made up of 3 NCUA staff members serving in independent appellate role for review of material.

• A credit union personal appearance before the SRC is permitted with a decision rendered within 30 days.

• SRC determinations are limited to: 



Composite CAMEL ratings of 3, 4, and 5 and all component ratings of those composite ratings; Adequacy of loan loss reserve provisions; and loan classifications for ―significant loans as determined by the appellant.

Examination Bill of Rights 

Examination Appeals Process 

Supervisory Review Committee - Timeline •

If the SRC fails to respond favorably, the credit union may appeal to the NCUA Board w/in 30 days of the SRC’s response.

1.

2.

3.

4.

Credit Union Disagrees with Final Examination Report CU appeals to Regional Director w/in 30 days of report CU appeals “material determinations” to SRC w/in 60 days of Regional Director’s response CU appeals to NCUA Board w/in 30 days of SRC’s decision

Examination Bill of Rights 

Examination Appeals Process 

Prompt Corrective Action Enforcement •

Within 45 days of becoming undercapitalized (less than 6% net worth) credit unions must submit a net worth restoration plan (NWRP) to NCUA. A state credit union must submit a NWRP to its state regulator (ACUA or OFR) as well. The plan is required unless the net worth category was downgraded on the basis of other safety and soundness issues. The director may extend the filing deadline.

•

The NCUA regional director (and ACUA Administrator or OFR Bureau Chief) will review the plan and approve, reject, or request modifications.

•

Credit unions should make every effort to work out its NWRP with the NCUA, ACUA, or OFR. While there is no formal process for appealing requirements of a NWRP, a credit union may raise concerns during the process.

Examination Bill of Rights 

Examination Appeals Process 

Prompt Corrective Action Enforcement •

NCUA has authority to take supervisory actions under PCA. 

Mandatory supervisory actions include: • • • • •

Requiring an earnings transfer for credit unions with less than 7% net worth; Limiting asset growth and specifically limiting member business loan growth, Submission of an Net Worth Replenishment Plan.

NCUA may liquidate or conserve a critically undercapitalized credit union within 90 days of its classification NCUA can take other action if it is determined to be appropriate.

Examination Bill of Rights 

Examination Appeals Process 

Prompt Corrective Action Enforcement - Appeals •

NCUA has an independent appeals process under which credit unions may appeal Prompt Corrective Action supervisory actions. 

The NCUA Board will provide advance notice and an opportunity for a credit union to have a hearing before a PCA discretionary supervisory action is taken, unless NCUA feels the action is necessary to further PCA purposes.



The credit union may also challenge the discretionary supervisory action in writing and request the action be modified or withdrawn.



The credit union is not entitled to a hearing before the NCUA Board.

Upon review, the Board, or its independent designee, may decide not to initiate the action or modify.



The credit union may request the NCUA Ombudsman to review a proposed discretionary supervisory action.

Examination Bill of Rights 

Examination Appeals Process 

NCUA Administrative Actions Other Than PCA •

NCUA may take ―administrative actions that are separate from PCA supervisory actions. These separate measures are among the most serious supervisory steps NCUA may take against a credit union or its officials. These actions can include:        

.

Letters of Understanding and Agreement; Cease and desist orders; Civil money penalties; Removal of officials; Termination of insurance; Conservatorship; Revocation of charter; and Liquidation

Examination Bill of Rights 

Examination Appeals Process 

NCUA Administrative Action and Credit Unions Challenge - LUAs •

Credit unions have the right to challenge a number of administrative actions. The appeals process may vary depending on the action. It is important to note that there are only limited appeals associated with Letter of Understanding and Agreement (LUAs). Once an LUA is signed, it is at that point when it becomes an enforceable agreement between the credit union and the regulator. Issues related to the signed LUA are not eligible for appeal to NCUA but may be subject to review by the courts. Credit unions should discuss issues related to LUAs with a competent legal representative and, as appropriate, LSCU representatives.

Examination Bill of Rights  Examination 



Appeals Process

NCUA Administrative Action and Credit Unions Challenge – Cease & Desist Appeals for Cease and Desist Orders The FCU Act empowers the NCUA to issue a Notice of Charges and to arrange for an administrative hearing to enforce a cease and desist order.

When the notice is provided to the credit union, the examiner must make officials aware of: •

The timeframe in which they must answer all changes

•

Filing of a written notice of appearance with the administrative law judge. A credit union has the right to challenge a temporary cease and desist order in federal court within ten days.

•

A 30-day period between when the notice is provided to the credit union and the date of the hearing.

Examination Bill of Rights 

Examination Appeals Process  NCUA Administrative Action and Credit Unions Challenge – Cease & Desist 

The credit union may agree without contesting the order, and it will become final. If there is no agreement however, a hearing is held before an administrative law judge and the following process will occur: • The judge sends a recommendation and the hearing record to NCUA Board.

• In 90 days, the Board makes a decision using evidence supporting the action.

• The CU may appeal to the U.S. Court of Appeals w/in 30 days of final notice.

• The court may overturn the Board’s action if it determines the action is arbitrary.

Examination Bill of Rights 

Examination Appeals Process  Credit Unions Challenge – Cease & Desist • The final order remains in place during appeal unless removed or modified by the court.

• The order is effective 30 days after the credit union has been notified.

• A final cease and desist order becomes effective 30 days after notice to the credit union and remains in effect unless modified or set aside by a reviewing court.

If the credit union violates the terms of a cease and desist order, NCUA may enforce it in U.S. district court or by imposing civil money penalties (fines).

Examination Bill of Rights



Examination Appeals Process  Credit Unions Challenge – Civil Money Penalties NCUA may assess fines against a credit union for violations of laws, orders, rules, or other violations. The size of the penalty depends on the seriousness of the violation, and is based on the following: • First tier - Any credit union or affiliated party that violates a law or regulation may receive a fine of not more than $5,000 for each day of the violation.

• Second tier - If the credit union commits a ―first tier violation and exhibits reckless conduct or does not carry out its duties properly, and the violation is part of a pattern of misconduct, causes more than a minimal loss, or results in a monetary gain or other benefit to the party involved, the NCUA Board may assess a fine not more than $25,000 a day for each day of the violation.

Examination Bill of Rights 

Examination Appeals Process  Credit Unions Challenge – Civil Money Penalties NCUA may assess fines against a credit union for violations of laws, orders, rules, or other violations. The size of the penalty depends on the seriousness of the violation, and is based on the following: • Third tier – A CU that knowingly commits violations, engages in unsafe/unsound practices, breaches any fiduciary duty, or recklessly causes a substantial loss to the credit union or a substantial monetary gain or other benefit to an involved party may receive a fine of not more than $1,000,000 per day for each day of the violation, or 1 percent of assets, whichever is less.

Examination Bill of Rights 

Examination Appeals Process  Credit Unions Challenge – Civil Money Penalties The procedure for the issuance of a CMP involves the following timeline: 

The NCUA Board issues a Notice of Assessment, which addresses the law and the facts on which it based.



The CU has 90 days to make payment, but may request a hearing within 20 days.



An administrative law judge holds a formal hearing if requested by a CU.



After the administrative hearing, the judge submits a recommended decision to the NCUA Board.



The NCUA Board issues a final order, but the order may be appealed by the CU to a U.S. court of appeals w/in 20 days of receipt of the final order.

Examination Bill of Rights 

Examination Appeals Process  Credit Unions Challenge – Official Removal or Suspension NCUA may remove directors, officers, or committee members as an initial course of action or as a continuation of a cease and desist order if the officials refuse to comply as directed.

NCUA may also suspend or remove institution-affiliated parties for certain criminal offenses pursuant to legal authority provided by The FCU Act. Removal can occur only if NCUA has issued a Notice of Intent to Remove or a Notice of Suspension and Intent to Remove and after completion of the appropriate administrative procedures.

Examination Bill of Rights 

Examination Appeals Process  Credit Unions Challenge – Official Removal or Suspension 

The notice to remove an official will contain a statement of facts for removal and establishes the time and place for holding a hearing before an administrative law judge; this is usually between 30 and 60 days after serving the notice.



The examiner informs the official when the notice is delivered that unless the official personally or an authorized representative, appears at the hearing, the judge will assume the official has consented to the removal.



A party who has been removed or suspended from office is also automatically removed, suspended, and prohibited from participating in the affairs of any federally insured financial institution unless the credit union’s regulator provides express written consent.

Examination Bill of Rights 

Examination Appeals Process  Credit Unions Challenge – Termination of Insurance The termination of insurance is the most severe action NCUA can initiate for federally insured state credit unions. 

The following are the administrative procedures for termination of insurance: • The NCUA Board issues a Notice of Charges, requesting corrective action. The CU has 120 days to make corrections, although the Board may reduce this time to not less than 20 days if the risk is sufficient.

Examination Bill of Rights 

Examination Appeals Process  Credit Unions Challenge – Termination of Insurance • If the credit union does not take corrective action, then the NCUA Board may issue a Notice of Intent to Terminate Insured Status. This sets out a statement of the facts justifying termination, and establishes a time and place for an administrative hearing within 30 to 60 days.

• An administrative law judge holds an administrative hearing. The administrative law judge files a recommended decision with the NCUA Board.

• The NCUA Board issues its final order.

• The credit union may appeal to the U.S. Court of Appeals, but the order is effective unless modified or lifted by the Board or the court.

• NCUSIF insurance continues for one year from the date of termination on current shares; however, the NCUSIF does not insure new shares.

Examination Bill of Rights 

Examination Appeals Process 

Credit Union Challenge - Revocation of Charter

NCUA may place a solvent federal credit union into involuntary liquidation for PCA or safety and soundness reasons. This is the most severe enforcement action NCUA can take against a solvent federal credit union.

• NCUA issues a Notice of Intent to Revoke Charter and Place into Involuntary Liquidation or a Notice of Suspension of Charter and Intent to Place into Involuntary Liquidation. *If a Notice of Suspension is issued, operational control of the credit union is immediately transferred to NCUA. All subsequent administrative steps are the same for both a Notice of Intent and a Notice of Suspension.

Examination Bill of Rights 

Examination Appeals Process 

Credit Union Challenge - Revocation of Charter

Once initiated, the credit union has 40 days in which to: 

File a written statement stating why it should not be liquidated;



Request an oral hearing; or consent to liquidation by a board of directors’ resolution.



If the credit union files a written statement, the NCUA Board will render a decision within 45 days. A Notice of Revocation of Charter and Involuntary Liquidation will be issued where the grounds for liquidation are found to exist.

Examination Bill of Rights 

Examination Appeals Process 

Credit Union Challenge - Revocation of Charter



If the credit union files a written statement, the NCUA Board will render a decision within 45 days. A Notice of Revocation of Charter and Involuntary Liquidation will be issued where the grounds for liquidation exist.



If the credit union requests a hearing, it will be held before an administrative law judge. The judge submits the recommendation to the NCUA Board.



The NCUA Board issues a final order.

Revocation of Charter & Involuntary Liquidation of Insolvent CU 

NCUA must appoint itself liquidating agent of an insolvent federal credit union upon ―finding that it is insolvent. The credit union may challenge the liquidation in court

Examination Bill of Rights League of Southeastern Credit Unions (LSCU) 1-866-231-0545 Alabama Office 22 Inverness Parkway, Suite 200 Birmingham, AL 35242 Fax: (205) 991-2576

Florida Office 3773 Commonwealth Blvd.

Tallahassee, FL 32303 Fax: (850) 574-6374

Will McCarty, Senior Vice President, Governmental Affairs 866-231-0545, ext. 2137 (Birmingham) will.mccarty@lscu.coop Bill Berg, Vice President, Regulatory Affairs 866-231-0545, ext. 1028 (Tallahassee) bill.berg@lscu.coop Scott Morris, Director of Compliance 866-231-0545, ext. 2165 (Birmingham) scott.morris@lscu.coop.

Examination Bill of Rights ACUA – Alabama Credit Union Administration Alabama Credit Union Administration – Montgomery, AL 1789 Cong Wm L Dickinson Dr. Montgomery, Alabama 36109 Tel: (334) 271-2381 Fax: (334) 409-9635 Larry Morgan, Administrator Lloyd Moore, Assistant Administrator Peter C. Ukeje, Exam Coordinator

James M. Arndt Jr, Exam Coordinator

Robert J. Russell, Exam Coordinator

Keith Shepherd Lowery, CU Exam Specialist

Keith C. Edwards, Exam Specialist

Marie H. Steele, BSA Examiner

Cindy J. Davis, Executive Secretary

Christy Ealum, Administrative Assistant

Examination Bill of Rights Florida OFR – Florida Office of Financial Regulation Florida Office of Financial Regulation – Tallahassee, FL 200 E. Gaines Street Tallahassee, FL 32399-0371 Tel: (850) 410-9800 Fax: (850) 410-9548 E-mail the Florida Office of Financial Regulation at: ofr@fldfs.com Linda B. Charity, Director – Office of Financial Regulation (850) 410-9800 linda.charity@flofr.com Bruce Ricca, Bureau Chief - Bureau of Credit Unions (850) 410-9528 bruce.ricca@flofr.com

Examination Bill of Rights CUNA - Credit Union National Association CUNA -Washington, DC 601 Pennsylvania, Avenue, NW South Bldg., Suite 600 Washington, DC 20004-2601 Tel: (202) 638-5777 Fax: (202) 638-7734

CUNA - Madison, WI 5710 Mineral Point Road Madison, WI 53705

Kathleen Thompson Associate General Counsel 202-638-5777, ext. 6740 (Washington, DC) kthompson@cuna.com

Mike McLain Assistant General Counsel 800-356-9655, ext. 4185 (Madison, WI) mmclain@cuna.com

Valerie Moss Director of Compliance Information 202-638-5777, ext. 6741 (Washington, DC) vmoss@cuna.com

Nichole Seabron Federal Compliance Counsel 202-638-5777, ext. 6739 (Washington, DC) nseabron@cuna.com

Paulette Young Regulatory Affairs Specialist 202-638-5777, ext. 6737 (Washington, DC) pyoung@cuna.com

Tel: (800) 356-9655 Fax: (608) 231-1869

Examination Bill of Rights NCUA – National Credit Union Administration NCUA Region III – Atlanta, GA 7000 Central Parkway, Suite 1600 Atlanta, GA 30328 Tel: (678) 443-3000 Fax: (678) 443-3020 E-mail NCUA at: Region3@ncua.gov Herb Yolles, Director, NCUA Region III Joe Ostrowidzki Associate Regional Director, Operations

David Hibshman Associate Regional Director, Programs

Donna Woods, Director Division of Supervision

Larry Maynard, Director Division of Insurance

Mark Skaggs, Director Division of Special Actions

TBD, Director Division of Management Services

Small Asset Size Credit Union Conference