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Why Credit Risk is NCUA's Biggest Worry



# Credit Risk: NCUA's Top Exam Priority for 2024 - What Credit Unions Need to Know


In the latest episode of "With Flying Colors," we delve into the National Credit Union Administration's (NCUA) 2024 exam priorities, with a particular focus on credit risk. As economic conditions continue to evolve, credit unions must stay ahead of potential challenges. Here's a comprehensive look at why credit risk is at the forefront of NCUA's concerns and how credit unions can prepare.


## Why Credit Risk is the Top Priority


The NCUA's focus on credit risk stems from several key factors:


1. **Economic Pressures**: Inflation, high interest rates, and increased borrowing costs are putting strain on members' ability to repay debts.

2. **Declining Savings**: Members are seeing their savings levels decrease.

3. **End of Pandemic-Era Support**: The conclusion of stimulus and relief programs has removed a financial safety net for many.

4. **Rapid Loan Portfolio Expansion**: 2022 saw the fastest loan portfolio growth in 30 years.

5. **Signs of Deterioration**: Loan performance began showing concerning trends in 2023.


## Expert Insights


Our podcast featured two former NCUA officials who provided valuable insights:


- **Steve Farrar**, former NCUA problem case officer and VP of Central Liquidity Facility, noted a clear trend of weakening credit quality, particularly in unsecured products like credit cards and junior liens.


- **Todd Miller**, former NCUA examiner and director of special actions, highlighted that for the past two and a half years, median income growth has lagged behind inflation, putting consumers, especially those in lower income brackets, in an increasingly difficult financial position.


## What to Expect in 2024 Exams


NCUA examiners will be focusing on several key areas:


1. **Existing Lending Programs**: Review of soundness and risk management practices.

2. **Loan Underwriting Standards**: Any adjustments made will be scrutinized.

3. **Portfolio Monitoring Practices**: Ensuring robust oversight of loan portfolios.

4. **Modification and Workout Strategies**: How credit unions are handling borrowers facing financial hardship.

5. **Collection Programs**: Effectiveness and compliance of collection efforts.

6. **Allowance for Credit Losses (ACL)**: Review of policies, procedures, documentation, and adequacy of reserves.


## Preparing Your Credit Union


To prepare for increased scrutiny on credit risk, consider the following steps:


1. **Review Risk Management Fundamentals**: Ensure your credit union is adhering to basic credit risk management principles.

2. **Analyze Concentration Risks**: Be prepared to justify your concentration limits, as this has been a common focus in recent exams.

3. **Evaluate CECL Implementation**: Assess whether your Allowance for Credit Losses is appropriately funded.

4. **Monitor Economic Indicators**: Keep a close eye on local economic conditions, as the impact of economic pressures can vary significantly by region.

5. **Enhance Member Support Programs**: Develop strategies to assist members facing financial difficulties while maintaining sound financial practices.


## Conclusion


As credit unions navigate the complex economic landscape of 2024, a proactive approach to credit risk management will be crucial. By understanding NCUA's priorities and preparing accordingly, credit unions can not only meet regulatory expectations but also better serve their members during challenging times.


Stay tuned to "With Flying Colors" for more insights on credit union regulatory and operational challenges.


Reach out to learn how we assist our clients with NCUA so they save time and money.

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