The goal of the AIRES modernization project is to make the exam process is much more effective and efficient, Fazio said. Upgrading the AIRES system could mean examiners would only need to visit a credit union when they were required to meet with credit union executives.

“Most of it (the exam) should be able to be done off-site electronically through a much more secure portal and an information exchange process, so (there will be) more to come on that,” Fazio said.

He said the NCUA will build AIRES in a way that is modular and takes advantage of off-the-shelf products.

Fazio also discussed NCUA's new exam procedures for small credit unions with less than $50 million in assets. Examiner training for this new process is expected to be completed by the end of March.

“We've really narrowed the scope of the exam down to record keeping, internal controls and fraud red flags to really target some of the issues that tend to get smaller credit unions in trouble,” he said. “Going forward, we hope that will also make the exam process for small credit unions more effective and efficient.”

The new exam process also will require examiners to take a deeper look at red flag issues. The depth of those exams will determine the areas of concern.

Since implementing a policy last year on exam findings and DORs, Fazio reported the NCUA has seen an 18% drop in DORs. However, he could not say whether the current policy is solely responsible for the reduction.

The current policy requires exam findings and DORs to be kept completely separate.

He said when examiners identify an issue, they need to decide how material it is, and that some findings are issues than can be corrected by the credit union and require no follow-up from examiners. DORs are more significant issues because they can threaten the safety, soundness and viability of the credit union, he said.

“If findings are not resolved and are minor, they won't be elevated to DOR,” he said. “However, if it represents some systematic weakness in management or some other concern then it might be elevated to a DOR.”

DORs also can be issued by examiners when major or systematic violations of regulations are detected Examiners are required to follow up on DORs to ensure they have been resolved.

Fazio reminded credit unions that NCUA's current policy also requires examiners to cite a regulation, act or other authoritative policy when they issue DORs.

“They can't say it's a best practice or something the credit union down the street does,” he said.

Examiners are allowed to share best practices with credit unions informally, but they are not allowed to include them in the exam report or cite best practices in DORs, he said.

Currently, about 52% of federal credit unions have not been issued DORs, while 48% of federal credit unions have been issued DORs, according to the NCUA.

Fazio also noted examiners are undergoing extensive training to learn how to communicate with credit union management teams, though he said the effects of that training will take some time.

“There should be no surprises,” he said. “You shouldn't show up at a joint conference and be surprised by something an examiner brings to the table with the board of directors.”