NCUA Lays Out 2023 Supervisory Priorities

NCUA Chairman Todd Harper notifies credit unions of updates to examination programs for the year.

NCUA official seal. (Source: NCUA)

On Wednesday, NCUA Board Chairman Todd Harper filed a letter to credit unions outlining the 2023 supervisory priorities for the agency’s examination program. The six areas focus on the items believed to be the highest risk to credit union members, the Share Insurance Fund and the industry as a whole.

According to the letter, the 2023 supervisory priorities include the following:

Interest Rate Risk

“Interest rates rose significantly across the yield curve during 2022, elevating interest rate risk (IRR) and the related exposure to earnings and capital,” the letter stated. “This sharp rise in rates has amplified market risk because a credit union’s assets and liabilities do not reprice equally, potentially impacting net economic values and credit unions’ projected earnings.”

Examiners will review a credit union’s IRR program for the following key risk management and control activities:

Liquidity Risk

According to Harper’s letter, examiners will review a credit union’s liquidity policies, procedures and risk limits. Examiners will evaluate liquidity management in the following ways:

Credit Risk

Due to high inflation and rising interest rates, NCUA examiners will evaluate the “soundness of existing lending programs, any adjustments your credit union made to loan underwriting standards and portfolio monitoring practices, and loan workout strategies for borrowers facing financial hardships.”

The letter added, “NCUA examiners will carefully consider all factors in evaluating your credit union’s efforts to provide relief for borrowers, including whether the efforts were reasonable and conducted with proper controls and management oversight.”

Fraud Prevention and Detection

NCUA examiners will continue to review internal fraud controls and separation of duties in 2023.

The agency announced a new management questionnaire this year to help credit unions identify fraud and other potential risk exposures to help protect the Share Insurance Fund.

“The questionnaire will be sent to credit unions in the pre-examination planning stage for all full-scope exams along with the Items Needed List, including on joint exams with State Supervisory Authorities (SSAs),” the letter read. “Credit unions only need to complete one questionnaire per examination. If an SSA uses a similar questionnaire, the federal and state examiners will coordinate to decide which questionnaire the credit union will complete to reduce duplication.”

Information Security

Harper’s letter emphasized cybersecurity as an examination priority in 2023 and asked credit union leaders to “remain very vigilant” in adapting and responding to cyber threats.

“Examiners will evaluate whether credit unions have established adequate information security programs to protect members and the credit union,” the letter stated.

Consumer Financial Protection

Compliance with consumer financial protection laws, as it pertains to federal credit unions, will be another area of focus for NCUA examiners this year. Among the list of items examiners will look at are compliance with the Flood Disaster Protection Act and disclosure requirements “as we continue to evolve our understanding of the impact of climate-related financial risk on credit unions, credit union members and the Share Insurance Fund.”

The letter emphasized the following areas examiners will focus on:

Harper’s letter also emphasized that exam flexibility will continue as examination and supervision will occur onsite and offsite. “Examiners will continue to conduct some examination activity offsite when the activity can be completed efficiently and effectively at credit unions that can accommodate offsite work,” the letter read.

READ MORE: NCUA’s 2023 Supervisory Priorities letter.