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How Will NCUA Examine for Share Overdrafts in 2023?


๐—›๐—ผ๐˜„ ๐—ช๐—ถ๐—น๐—น ๐—ก๐—–๐—จ๐—” ๐—ฒ๐˜…๐—ฎ๐—บ๐—ถ๐—ป๐—ฒ ๐—ฆ๐—ต๐—ฎ๐—ฟ๐—ฒ ๐—ข๐˜ƒ๐—ฒ๐—ฟ๐—ฑ๐—ฟ๐—ฎ๐—ณ๐˜๐˜€ ๐—ถ๐—ป ๐Ÿฎ๐Ÿฌ๐Ÿฎ๐Ÿฏ?


Yesterday NCUA held an industry webinar on 2023 Supervisory Priorities that included the following information on the scope of review for Overdrafts:


At complex #c reditunions (>$500m+) Examiners ๐˜„๐—ถ๐—น๐—น ๐—ฟ๐—ฒ๐˜ƒ๐—ถ๐—ฒ๐˜„:


โ€ข Website Advertising;

โ€ข Balance Calculation Methods;

โ€ข Settlement processes

โ€ข Member Statements and disclosures related to PALS II loans; and

โ€ข Management's actions to address unanticipated overdraft fees.


With CFPB inventing the new term Junk Fees and an apparent ever-increasing NCUA review of overdraft programs, you should be reviewing this area closely now and in the years ahead. I expect NCUA's scope in 2024 will expand in general and also include smaller credit unions.


Watch for future stories and podcasts on NCUA's Supervisory Priorities soon.


Interested in learning how my team of former NCUA subject matter experts assist credit unions in dealing with NCUA? Email me at info@marktreichel.com


NCUA's full letter on Supervisory Priorities can be found here:

https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/ncuas-2023-supervisory-priorities

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