CUSO EXAMS What You Need to Know
Manage episode 447787676 series 3303439
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## Episode Summary
Mark Treichel discusses Credit Union Service Organizations (CUSOs) and CUSO examinations, drawing from his experience as a former NCUA Regional Director. He compares CUSO exams to credit union exams and provides insights into what credit unions and CUSOs can expect during these reviews.
## Key Points
1. CUSO exam frequency and types:
- Less frequent than credit union exams
- Three types: integrated exams, standalone exams, and independent reviews
2. NCUA's authority to examine CUSOs:
- Based on agreements between credit unions and CUSOs
- Allows NCUA complete access to CUSO books and records
3. Types of CUSOs likely to be examined:
- Those offering new or growing services (e.g., commercial loans, student lending, FinTech)
4. NCUA's focus during CUSO exams:
- Systemic risks
- Individual credit union risks
- New or growing services
5. Documents NCUA may request:
- Strategic plans
- Disaster recovery plans
- Organizational charts
- Board minutes
- Customer lists
- Policies and procedures
6. Corporate veil considerations:
- Ensuring independence between CUSO and credit union operations
7. "Primarily serves" requirement:
- Case-by-case determination
- Based on totality of circumstances
## Notable Quotes
"Getting a CUSO review, if your books and records are clean and your services are well documented and you can do a good job of controlling the narrative when NCUA comes in, when that happens, it's actually, can be a plus."
## Upcoming NCUA Developments
- Proposed rule on eligible obligations and loan participations expected between July and September
## Resources Mentioned
- Credit Union Exam Solutions: marktrico.com
- CUSO Law: cusolaw.com
- Previous podcast episode with Brian Lauer on CUSO regulation changes (episode number to be added in show notes)
## Call to Action
Subscribe to "With Flying Colors" on your favorite podcast app for more expert insights on achieving success with NCUA.
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