In the six months since the banking industry began facing unprecedented turmoil, U.S. financial regulatory leaders have been taking a hard look at the scope of risks tied to regional and small banks in an attempt to triage the credit tightening and liquidity that could leave its mark on the economy for months or years. While credit unions are not under the auspices of the same federal regulators, they are connected to the financial system and subject to the same contagions. A regulatory day of reckoning is coming for U.S. banks and credit unions, especially rules for small- and medium-sized institutions on liquidity risks. Since banks began borrowing at a record clip in spring, they are still scooping up Federal Reserve emergency loans from three programs at a rate of tens of billions each week.

As federal agencies move to scrutinize the regional banks, the NCUA and various state authorities are also reviewing their own policy frameworks to shore up protection of credit unions and their members, and ultimately to prevent systemic failures, with trade associations such as NAFCU advocating for changes that best meet credit unions' needs. The FDIC and two other regulators recently unveiled new rules for larger banks' capital requirements to address evolving international standards and the recent regional banking crisis. While nobody can predict when and what exact FDIC and NCUA rules will drop aimed at smaller institutions, financial institutions will need to be agile with change and have a confident mastery of risk management to be ready to comply. Consumers, regulators and investors alike will also be expecting demonstrable action and rapid operationalization of any new or amended regulations.