On Jan. 21, the FDIC board approved a joint interim final rule that raised the asset size of banks eligible for 18-month exam cycles to $1 billion. The previous threshold for 1-rated banks was $500 million.

According to a statement from FDIC Chairman Martin J. Gruenberg, recent statutory changes permitted three federal banking agencies – the Federal Reserve, the Office of the Comptroller of the Currently and the FDIC – to expand the availability of longer exam cycles. The statute also authorized the agencies to extend the change to 2-rated institutions that have assets between $200 million and $1 billion and meet other qualifying criteria, if they determine the higher threshold would be consistent with safety and soundness.

"The banking agencies supported these changes to the Federal Deposit Insurance Act as a reasonable step to take as part of regulatory burden relief efforts," Gruenberg said. "I am pleased Congress acted swiftly to adopt the changes and that the agencies have been able to move expeditiously to implement them through this interim final rule. I would like to thank staff at all the agencies for their work to bring this case forward."

The FDIC's move prompted some credit union industry players to call on the NCUA to follow suit. Cooperative Credit Union Association President/CEO Paul Gentile said the potential for the NCUA to move forward is "truly there" as the banking sector moves toward an 18-month examination cycle.

"We were out first on this issue and we've been the one plugging away on this," Gentile said. "It's interesting that the agency is looking at how to proceed. We've already had it."

The agency allowed for the extended examination period during former NCUA Chairman Dennis Dollar's tenure.

"We are not re-inventing the wheel. It's not a crazy idea that's brand new," Gentile said.

Additionally, credit union trade associations also asked the NCUA to join other financial regulators in providing similar regulatory relief for credit unions.

"Given the recent FDIC and OCC actions to allow certain banks an 18-month exam cycle, NAFCU again calls upon the NCUA to lengthen the exam cycle for healthy, well-run credit unions," NAFCU President/CEO Dan Berger said in a statement. "Credit unions did not cause the financial crisis, are in extremely sound shape as an industry, and do not need the additional burden of more frequent exams."

Berger added that the longer exam cycle would allow the NCUA to reserve resources for credit unions that require more oversight. He urged the regulator to approve this "much-needed relief for credit unions as soon as possible."

Gentile mirrored Berger's comments, adding that the move toward a longer examination cycle would allow the NCUA to focus on the credit unions that need the additional scrutiny.

"I just wish they would commit to a more data-driven approach that's smart, that's strategic, and one that doesn't rely on walking in every 12 months," Gentile said.

CU Times readers agreed. An online CU Times poll asked readers if the NCUA should consider a similar move. As of Jan. 28 a majority, 49%, said the agency should lengthen the examination cycle because credit unions are healthier than banks. An additional 37% also said the NCUA should move forward, but only if the regulator is sure the credit unions are completely safe and sound.

Only 7% said the agency should not consider the move, as the economy is still too unstable. Additionally, one commenter suggested the decision should depend on the CAMEL rating for the institution, while another offered that the NCUA should be merged with the FDIC due to incompetence.

In her comments at the NCUA board meeting Jan. 21, NCUA Chairman Debbie Matz indicated her support for lengthening the exam cycle. She said that the NCUA is "not locked into an annual exam cycle every year" and added that the agency may consider moving back to an 18-month exam cycle for credit unions that pose less risk to the share insurance fund.

"For at least the third time, Chairman Matz has said publicly that the agency is taking steps to move to a less frequent exam cycle," CUNA Chief Advocacy Officer Ryan Donovan told CU Times. "These are welcomed words and we look forward to the agency putting those words into actions that make the examination process fairer, more efficient and less frequent for credit unions."

Donovan added, "With the FDIC moving to a less frequent cycle for banks, there is no reason that the NCUA shouldn't do the same. We continue to urge the agency to move with haste to turn the chairman's words into results for credit unions."

NCUA Board Member Mark McWatters, who spoke out in favor of extending the exam cycle during the board's November meeting, said he still supports that move.

fdic approves 18-month exam cycle NCUA exam cycle

"The recent action by the FDIC demonstrates how misguided the NCUA has been in not investigating the possibility of examining a subset of credit unions every 18 months, insisting that every credit union with assets of more than $250 million must be examined every 12 months, not working to rely upon SSA examinations for NCUA insurance purposes and defining small entity by reference to $100 million of assets," he told CU Times.

McWatters said the concept of moving to an 18-month examination cycle has been "all but dismissed" by the NCUA despite the credit union community being "strong and resilient."

He added the agency's "back-burner approach without discussion" among the board offices is further evidence of the "lack of transparency" within the agency. He also said his support for an 18-month examination cycle for low-risk credit unions "is not a foregone conclusion," as the details of a proposal and the definition of low-risk would weigh on his decision in support of a longer examination cycle.

"If you have good analysis of the data, there's so much you can do to monitor how a credit union is doing without being present every 12 months, which is disruptive to the credit union and expensive for the agency," Gentile said, citing data the NCUA collects via call reports. "It makes a lot of sense for them to look at this strategically for the future of how they are going to engage credit unions."

Similarly, McWatters said that a sophisticated, data-driven approach to the examination process would protect "the safety and soundness of the share insurance fund without rigid adherence to unwieldy, inefficient models that generally necessitate year-by-year increases in the operating budget."

NCUA Vice Chairman Rick Metsger told CU Times, "Our goal, however, should always be to meet our statutory mandate to protect the safety and soundness of the system in the most efficient and effective manner possible. While we shouldn't pre-ordain a conclusion, neither should we be hesitant to implement change if the data validates the reasonableness of such a change."

The Independent Community Bankers of America applauded the FDIC's move. ICBA President/CEO Camden Fine said the decision will allow more community bankers "to redirect their resources from excessive regulatory burdens to serving their local communities."

An additional 617 banking institutions will qualify for the extended exam cycle, according to Fine.

Gentile added that the move by the FDIC "validates what we've been saying for a while." He said the lack of parity created by the move, politically, gives credit unions more "fire power when we are on the Hill talking about our regulatory environment."

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