WEBVTT NOTE This file was generated by Descript 00:00:00.470 --> 00:00:02.320 Samantha: Hello, this is Samantha Shares. 00:00:02.890 --> 00:00:07.050 This episode covers N C U A’s September 20 24 Board Meeting 00:00:07.050 --> 00:00:09.240 regulation Simplifying Share Insurance. 00:00:09.920 --> 00:00:13.310 Earlier this week we provided the entire long rule in my voice. 00:00:13.860 --> 00:00:17.610 Today is the NCUA Board and staff in their own words and voices. 00:00:18.335 --> 00:00:21.575 This podcast is educational and is not legal advice. 00:00:22.065 --> 00:00:26.185 We are sponsored by Credit Union Exam Solutions Incorporated, whose 00:00:26.185 --> 00:00:29.195 team has over two hundred and Forty years of National Credit 00:00:29.195 --> 00:00:31.105 Union Administration experience. 00:00:31.615 --> 00:00:35.265 We assist our clients with N C U A so they save time and money. 00:00:35.685 --> 00:00:39.615 If you are worried about a recent, upcoming or in process N C U A 00:00:39.615 --> 00:00:44.095 examination, reach out to learn how they can assist at Mark Treichel DOT COM. 00:00:44.395 --> 00:00:48.755 Also check out our other podcast called With Flying Colors where we provide tips 00:00:48.755 --> 00:00:51.335 on how to achieve success with N C U A. 00:00:52.066 --> 00:00:52.896 And now the rule. 00:00:58.258 --> 00:01:01.928 Chairman Harper: The second item of business is final rule part 745, 00:01:02.228 --> 00:01:04.748 simplification of insurance rules. 00:01:04.908 --> 00:01:06.768 Staff presenting are Tom Zells. 00:01:06.938 --> 00:01:12.398 Senior Staff Attorney, Office of General Counsel, and Paul Dibble, Consumer 00:01:12.398 --> 00:01:16.378 Access Program Officer, Office of Credit Union Resources and Expansion. 00:01:16.748 --> 00:01:20.678 Um, I have to give it to you, uh, Tom for having a great soccer 00:01:20.708 --> 00:01:25.268 game today, and Paul for having a fantastic shirt tie combination. 00:01:25.598 --> 00:01:27.348 Uh, good morning to both of you. 00:01:27.508 --> 00:01:28.788 Please start whenever you are ready. 00:01:29.398 --> 00:01:30.118 staff (3): Thank you so much. 00:01:30.628 --> 00:01:32.898 Uh, good morning, Chairman Harper and Vice Chairman Hauptman. 00:01:32.988 --> 00:01:37.928 We are here today to present a final rule to amend Part 745 of the NCOA's 00:01:37.938 --> 00:01:39.948 Regulations Governing Share Insurance. 00:01:41.028 --> 00:01:45.088 The primary intent of the final rule is to simplify the NCOA's share insurance 00:01:45.088 --> 00:01:46.948 coverage rules related to trust accounts. 00:01:48.088 --> 00:01:51.468 Before we get into the specifics about the final rule, I'm going to provide a little 00:01:51.468 --> 00:01:55.538 bit of background on how the Federal Credit Union Act, or FCU Act, addresses 00:01:55.538 --> 00:01:59.078 share insurance and a general description of the current share insurance rules. 00:02:00.688 --> 00:02:05.528 Under the FCU Act, the NCUA is responsible for paying share insurance to any person 00:02:05.538 --> 00:02:09.148 with funds lawfully held in a member account in the event of a federally 00:02:09.148 --> 00:02:13.118 insured credit union's failure up to the standard maximum share insurance amount, 00:02:13.158 --> 00:02:15.828 which is currently set at 250, 000. 00:02:17.208 --> 00:02:20.728 In general, the FCU Act is not overly prescriptive on how the share 00:02:20.728 --> 00:02:24.628 insurance process works, but does specify specific treatments for a 00:02:24.628 --> 00:02:28.848 few types of accounts, for example, accounts held by government depositors 00:02:28.898 --> 00:02:30.248 and certain retirement accounts. 00:02:31.308 --> 00:02:35.238 Otherwise, the FCU Act provides substantial discretion to the NCOA. 00:02:36.588 --> 00:02:40.658 The NCOA has implemented share insurance requirements in Part 745 of its rules. 00:02:41.268 --> 00:02:45.418 Generally, the NCOA determines whether a member account is insured by grouping 00:02:45.418 --> 00:02:49.068 particular categories of accounts held by a member, such as single 00:02:49.068 --> 00:02:52.878 ownership accounts, joint ownership accounts, revocable trust accounts, 00:02:53.128 --> 00:02:54.618 and irrevocable trust accounts. 00:02:55.498 --> 00:02:58.758 If an account meets the requirement for a particular category, the account 00:02:58.758 --> 00:03:01.138 is insured up to the 250, 000 limit. 00:03:01.523 --> 00:03:05.663 Separately from shares held by the member in a different account category at the 00:03:05.663 --> 00:03:10.013 same federally insured credit union, for example, provided all requirements 00:03:10.013 --> 00:03:13.943 are met, shares in the single ownership category will be separately insured 00:03:13.943 --> 00:03:17.363 from shares in the joint ownership category held by the same member at the 00:03:17.363 --> 00:03:18.713 same federally insured credit union. 00:03:19.463 --> 00:03:21.473 We'll now discuss specifics of the final rule. 00:03:21.503 --> 00:03:23.723 I'll turn it over to Paul so that he can discuss the changes 00:03:23.723 --> 00:03:24.863 to the trust account coverage. 00:03:25.583 --> 00:03:26.153 Thank you, Tom. 00:03:26.153 --> 00:03:27.173 Good morning, chairman Harper. 00:03:27.233 --> 00:03:27.863 Good morning, vice Chairman. 00:03:27.863 --> 00:03:28.223 Good morning. 00:03:29.733 --> 00:03:32.523 staff (4): Uh, the share insurance process is fairly straightforward 00:03:32.523 --> 00:03:33.603 for most types of accounts. 00:03:34.223 --> 00:03:36.263 One exception, however, is trust accounts. 00:03:36.723 --> 00:03:40.163 The N2A's current regulations recognize two different types of 00:03:40.163 --> 00:03:42.823 insurance categories for funds held in connection with trust. 00:03:43.423 --> 00:03:46.323 Revocable trusts and irrevocable trusts. 00:03:46.803 --> 00:03:49.783 The share insurance rules include additional complexity related to 00:03:49.783 --> 00:03:53.163 the number of beneficiaries that would receive funds, from revocable 00:03:53.173 --> 00:03:57.463 trusts and whether irrevocable trusts include certain contingencies. 00:03:58.053 --> 00:04:02.893 Despite previous NTU A efforts to address confusion related to trust accounts, 00:04:02.893 --> 00:04:07.763 the NTU A has received over 8, 500 share insurance questions related to 00:04:07.763 --> 00:04:10.293 trust accounts since the end of 2019. 00:04:11.703 --> 00:04:15.113 Additionally, the complexity also causes a potential for delay in 00:04:15.113 --> 00:04:19.493 insurance payouts when the NTU A has been appointed as liquidating agent. 00:04:20.193 --> 00:04:23.113 The FDIC, which has deposit insurance coverage rules that are 00:04:23.113 --> 00:04:27.343 comparable to the NQA's rules, has experienced similar issues related 00:04:27.343 --> 00:04:28.913 to its rules on trust accounts. 00:04:29.073 --> 00:04:33.483 The final rule makes several changes to simplify the treatment of trust accounts. 00:04:34.123 --> 00:04:38.673 First, the final rule merges the revocable and irrevocable trust categories 00:04:39.003 --> 00:04:41.063 into a new trust accounts category. 00:04:41.613 --> 00:04:45.353 This new category includes informal revocable trust accounts, such 00:04:45.353 --> 00:04:46.533 as payable on death accounts. 00:04:47.498 --> 00:04:51.748 Formal revocable trust accounts and irrevocable trust accounts. 00:04:52.368 --> 00:04:57.228 The final rule also treats irrevocable trusts like revocable trusts and 00:04:57.228 --> 00:05:01.188 the fact that contingencies would no longer impact potential coverage. 00:05:02.098 --> 00:05:05.428 While the change creates simplicity as all trust accounts, regardless of 00:05:05.428 --> 00:05:09.938 legal form will be treated the same, it has the potential to reduce share 00:05:09.938 --> 00:05:13.958 insurance coverage as the existing rule provides per the potential for 00:05:13.958 --> 00:05:17.878 increased coverage, depending on whether the member is set up revocable. 00:05:19.793 --> 00:05:24.543 So, for members who establish both large revocable trusts and large irrevocable 00:05:24.553 --> 00:05:29.013 trusts to the same beneficiaries, the final rule may result in reduced coverage. 00:05:29.393 --> 00:05:33.343 However, for other members with irrevocable trusts, the final rule 00:05:33.363 --> 00:05:37.873 could result in increased insurance coverage as irrevocable trusts with 00:05:37.873 --> 00:05:42.433 contingencies to multiple beneficiaries will now have greater insurance coverage. 00:05:44.033 --> 00:05:47.563 Second, the rule simplifies the treatments for shares held in trust 00:05:47.563 --> 00:05:49.033 with more than five beneficiaries. 00:05:49.658 --> 00:05:52.638 Under the final rule, additional share insurance coverage would not 00:05:52.638 --> 00:05:56.768 be provided if a member leaves trust funds to more than five beneficiaries, 00:05:57.168 --> 00:05:59.618 regardless of the number of trusts that establish those funds. 00:06:00.238 --> 00:06:03.498 Therefore, the maximum amount of share insurance coverage for trust 00:06:03.958 --> 00:06:06.268 funds under the final rule would be 1. 00:06:06.378 --> 00:06:07.108 25 million. 00:06:08.088 --> 00:06:12.458 This change streamlines the rule, but has the potential to reduce share 00:06:12.458 --> 00:06:14.888 insurance coverage for certain members. 00:06:15.458 --> 00:06:18.568 The proposed rule included a question on the potential effect of this change. 00:06:19.693 --> 00:06:22.563 As expressed in the proposed rule, we do not believe in practical 00:06:22.563 --> 00:06:25.633 terms that this change will have a substantial effect on the shared 00:06:25.633 --> 00:06:27.513 insurance coverage for most members. 00:06:28.023 --> 00:06:31.543 The comments received also did not provide an indication to the contrary. 00:06:32.203 --> 00:06:35.203 Therefore, under the final rule, the calculation of insurance coverage for 00:06:35.203 --> 00:06:39.413 trust accounts is similar to the rule, to the rule currently used for revocable 00:06:39.423 --> 00:06:41.453 trust for five or fewer beneficiaries. 00:06:42.143 --> 00:06:44.873 An account holder's trust account will be insured in the amount 00:06:44.943 --> 00:06:47.938 up to 250, 000 multiplied by. 00:06:48.228 --> 00:06:52.898 By the number of trust beneficiaries not to exceed five, this is regardless 00:06:52.898 --> 00:06:56.788 of whether the trust is revocable or irrevocable, or regardless of 00:06:56.788 --> 00:07:00.888 contingencies or the allocation of funds among the beneficiaries. 00:07:01.248 --> 00:07:05.308 This, in effect, limits coverage for each grantor's trust accounts at each federally 00:07:05.308 --> 00:07:07.688 insured credit union to a total of 1. 00:07:07.688 --> 00:07:08.048 25 million. 00:07:08.753 --> 00:07:11.533 This treatment of trust for share insurance purposes creates more 00:07:11.533 --> 00:07:16.273 parity between the NCOA and the new trust rules adopted by the FDIC that 00:07:16.273 --> 00:07:19.183 became effective on April 1st, 2024. 00:07:19.613 --> 00:07:21.783 The final rule adopts the changes recommended in the 00:07:21.803 --> 00:07:23.323 proposed rule as proposed. 00:07:23.883 --> 00:07:27.003 Under the final rule, the effective date of the trust account changes will 00:07:27.003 --> 00:07:30.073 be delayed until December 1st, 2026. 00:07:30.973 --> 00:07:34.703 This delayed effective date provides a very similar implementation timeline 00:07:35.083 --> 00:07:36.933 to the one provided by the FDIC. 00:07:37.243 --> 00:07:41.283 And we'll provide the NCUA staff at credit unions and credit union members 00:07:41.303 --> 00:07:43.673 necessary time to prepare for the changes. 00:07:43.983 --> 00:07:47.173 I will now hand it back to Tom so that he can discuss the comments received on the 00:07:47.183 --> 00:07:51.163 proposed trust account changes and some other changes made by the final rule. 00:07:52.073 --> 00:07:52.593 staff (3): Thanks, Paul. 00:07:52.903 --> 00:07:56.503 In terms of comments on the trust account changes, all 11 substantive 00:07:56.503 --> 00:07:59.643 comments that the NCUA received indicated support for the changes. 00:08:00.273 --> 00:08:03.303 Common reasons that the commenters provided for supporting the rule 00:08:03.353 --> 00:08:07.553 included providing parity with FDIC coverage and reducing confusion 00:08:07.553 --> 00:08:08.863 regarding coverage of trust accounts. 00:08:09.813 --> 00:08:12.543 As noted, commenters did not express real concern with the new 00:08:12.543 --> 00:08:16.593 trust rules effectively limiting each grantor to a maximum of 1. 00:08:16.593 --> 00:08:19.163 25 million in coverage for their trust account funds. 00:08:19.863 --> 00:08:22.173 One commenter specifically stated that they did not think the 1. 00:08:22.173 --> 00:08:26.913 25 million per grantor cap was too low, as the vast majority of accounts 00:08:26.913 --> 00:08:31.133 are well below the level, but did ask the NCA to track liquidations 00:08:31.143 --> 00:08:32.353 to ensure it is not too low. 00:08:33.613 --> 00:08:36.433 Other issues commenters addressed included membership requirements for 00:08:36.433 --> 00:08:40.223 trust accounts, reporting of insured shares on the call report, and whether 00:08:40.223 --> 00:08:43.733 the NCOA should provide a delayed effective date or otherwise insure 00:08:43.743 --> 00:08:47.973 already existing accounts or legacy accounts under the current rules. 00:08:48.073 --> 00:08:52.823 The final rule also makes a few other changes in addition to the 00:08:52.853 --> 00:08:54.303 simplified approach to trusts. 00:08:54.313 --> 00:08:57.603 The final rule clarifies the coverage provided to mortgage 00:08:57.603 --> 00:09:01.153 servicing accounts for funds that the mortgage servicer or another party 00:09:01.173 --> 00:09:02.643 deposits on behalf of the borrower. 00:09:03.698 --> 00:09:07.008 The NCOA's current rules include a separate insurance category for mortgage 00:09:07.008 --> 00:09:09.898 servicing accounts that are comprised of principal and interest funds. 00:09:10.428 --> 00:09:14.368 The current regulations, however, do not address funds paid in to 00:09:14.368 --> 00:09:17.138 a mortgage servicing account by someone other than the borrower. 00:09:17.778 --> 00:09:20.658 By not treating funds deposited by the servicer the same as funds 00:09:20.658 --> 00:09:24.148 deposited by the member, NCOA's current rules result in inconsistency 00:09:24.148 --> 00:09:28.738 in the potential for instability during periods of economic stress. 00:09:29.388 --> 00:09:32.768 The final rule clarifies that these funds receive similar share insurance treatment, 00:09:32.768 --> 00:09:36.518 The This is identical to the treatment under the FDIC's recent final rule. 00:09:37.398 --> 00:09:40.578 The NCUA received six comments specifically addressing this change. 00:09:41.098 --> 00:09:42.868 All of these comments supported the change. 00:09:42.938 --> 00:09:46.788 The final rule makes no alterations to the changes recommended in the proposed rule. 00:09:47.568 --> 00:09:50.228 As this change would provide more expansive coverage and should not 00:09:50.228 --> 00:09:53.648 impose additional burden on credit unions or account holders, the final 00:09:53.648 --> 00:09:55.038 rule does not delay its effect. 00:09:55.353 --> 00:09:57.763 It would become effective 30 days after the final rule is 00:09:57.763 --> 00:09:59.003 published in the Federal Register. 00:10:00.673 --> 00:10:04.143 The final rule also makes some changes to the NCOA, NCOA's record keeping 00:10:04.143 --> 00:10:06.053 regulations for share insurance coverage. 00:10:07.273 --> 00:10:10.303 These changes are favorable to members and provide more flexibility to the 00:10:10.303 --> 00:10:15.233 NCOA to include additional documentation evidencing the intent of the account when 00:10:15.233 --> 00:10:16.953 making share insurance determinations. 00:10:17.333 --> 00:10:19.753 These changes pose no additional burden to credit unions. 00:10:20.483 --> 00:10:23.953 The NCUA received seven comments specifically addressing these changes. 00:10:24.573 --> 00:10:26.383 All of these comments supported the changes. 00:10:26.873 --> 00:10:29.393 The final rule makes no substantive changes to the changes 00:10:29.393 --> 00:10:30.853 recommended in the proposed rule. 00:10:32.083 --> 00:10:36.513 As these changes only explicitly clarify the flexibility the NCUA has in terms 00:10:36.543 --> 00:10:40.243 of records the agency can look to in evaluating share insurance coverage 00:10:40.543 --> 00:10:43.823 and would not impose additional burden on credit unions or account holders. 00:10:44.183 --> 00:10:45.903 The final rule does not delay its effect. 00:10:46.013 --> 00:10:48.443 It would become effective 30 days after the final rule was 00:10:48.443 --> 00:10:49.693 published in the Federal Register. 00:10:50.488 --> 00:10:51.758 That concludes our presentation. 00:10:51.778 --> 00:10:53.828 We are happy to answer any questions you may have. 00:10:54.618 --> 00:10:57.018 Chairman Harper: Thank you, Tom and Paul, for your presentation on the 00:10:57.018 --> 00:11:01.148 final rule to simplify certain share insurance requirements related to 00:11:01.148 --> 00:11:05.188 trust accounts and mortgage servicing accounts, among other things, such as 00:11:05.218 --> 00:11:06.788 the record keeping you just mentioned. 00:11:07.188 --> 00:11:10.158 And thank you to the many team members across the agency 00:11:10.158 --> 00:11:11.818 who worked collaboratively. 00:11:14.918 --> 00:11:18.768 It's a common sense package of regulatory changes that I fully support. 00:11:19.388 --> 00:11:23.448 By establishing a unified trust accounts category that treats coverage 00:11:23.448 --> 00:11:28.118 of funds in both revocable trusts and irrevocable trusts deposited at 00:11:28.118 --> 00:11:30.783 federally insured credit unions in the same manner, I fully support. 00:11:30.783 --> 00:11:34.663 This final rule simplifies the share insurance regulations and brings the 00:11:34.663 --> 00:11:39.173 National Credit Union Share Insurance Fund into greater alignment with the 00:11:39.183 --> 00:11:43.333 Federal Deposit Insurance Corporation's Deposit Insurance Fund's rules. 00:11:43.723 --> 00:11:47.143 That's a positive change not only for credit union staff who will have 00:11:47.143 --> 00:11:50.823 streamlined procedures when working on such trust accounts, but it's also a 00:11:50.833 --> 00:11:54.843 benefit for credit union members who will better understand their coverage options. 00:11:55.353 --> 00:11:59.643 It's also a time saver for the NCUA's Share Insurance Fund, uh, Fund 00:11:59.693 --> 00:12:03.793 Specialists who, I'm sorry, Share Insurance Specialists who during the 00:12:03.793 --> 00:12:07.863 last five years have fielded thousands of calls, as you've noted, Paul, uh, 00:12:07.893 --> 00:12:10.753 about share insurance coverage for different types of trust accounts. 00:12:11.163 --> 00:12:14.763 This rule change will also lead to greater efficiency in the NCUA's 00:12:14.793 --> 00:12:18.603 Asset Management Assistance Center when managing future liquidations. 00:12:19.113 --> 00:12:23.083 Specifically, the final rule, as I mentioned, eliminates distinct and 00:12:23.083 --> 00:12:27.293 separate sets of rules and insurance coverage calculations for shares of 00:12:27.293 --> 00:12:29.543 revocable trusts and irrevocable trusts. 00:12:29.873 --> 00:12:33.263 Those rules led to public confusion about the share insurance coverage 00:12:33.273 --> 00:12:36.113 of trust accounts maintained at federally insured credit unions. 00:12:36.583 --> 00:12:40.483 This final rule aligns the coverage standards for both types of trust accounts 00:12:40.663 --> 00:12:45.653 and establishes a simplified formula for calculating coverage for funds deposited 00:12:45.673 --> 00:12:47.083 at federally insured credit unions. 00:12:47.608 --> 00:12:52.628 This final rule also allows for more time for share insurance, more timely 00:12:52.638 --> 00:12:56.968 share insurance fund determinations by NCUA trust, by the NCUA of trust 00:12:56.968 --> 00:13:00.888 accounts, which will facilitate faster payments to account holders in the 00:13:00.888 --> 00:13:02.828 event of a credit union liquidation. 00:13:03.148 --> 00:13:06.788 In fact, Paul, as I understand, uh, we've sometimes had to spend 00:13:06.798 --> 00:13:10.568 months sorting through trust records to determine just how much. 00:13:10.798 --> 00:13:12.628 Exactly what we've had to pay and a payout. 00:13:13.118 --> 00:13:17.278 In addition, this rule provides members at federally insured credit unions with 00:13:17.278 --> 00:13:21.298 the same protections as consumers who use trust accounts at banks and thrifts. 00:13:21.538 --> 00:13:25.368 Yes, such parity between the two federal deposit insurance 00:13:25.368 --> 00:13:29.028 programs promotes greater public confidence in the dual systems for 00:13:29.028 --> 00:13:31.218 protecting shares and deposits. 00:13:31.548 --> 00:13:36.078 And as one commenter noted, such parity is crucial for maintaining consistency 00:13:36.298 --> 00:13:38.308 and fairness in the financial system. 00:13:38.448 --> 00:13:39.648 I couldn't agree more. 00:13:40.148 --> 00:13:43.568 Public trust in our financial system must never be taken for granted. 00:13:43.898 --> 00:13:48.018 We saw firsthand the effects on consumers and turmoil in the markets caused by 00:13:48.028 --> 00:13:50.198 several large bank failures last year. 00:13:50.718 --> 00:13:53.658 Deposit insurance at federally insured credit unions and banks is 00:13:53.668 --> 00:13:57.828 vital as it stabilizes the financial system during periods of economic 00:13:58.038 --> 00:14:00.248 uncertainty and financial stress. 00:14:00.628 --> 00:14:04.438 More importantly, it gives consumers confidence to entrust their hard 00:14:04.438 --> 00:14:08.438 earned savings and nest eggs to a federally insured financial institution. 00:14:09.118 --> 00:14:11.958 Additionally, the final rule modifies the treatment of share insurance 00:14:11.958 --> 00:14:16.348 coverage for mortgage servicing accounts, bringing those standards for 00:14:16.348 --> 00:14:19.988 the credit union system into greater alignment with the banking system when 00:14:19.988 --> 00:14:21.888 it comes to deposit insurance coverage. 00:14:22.298 --> 00:14:26.218 Credit unions have had pronounced increases in their mortgage lending 00:14:26.218 --> 00:14:30.308 and servicing in the 16 years since we last updated this portion of the 00:14:30.308 --> 00:14:35.048 share insurance coverage rule in 2008, so this change is an important one. 00:14:35.448 --> 00:14:38.958 By giving credit union members Um, credit union members and members of 00:14:38.958 --> 00:14:43.198 the public who use trust accounts and credit unions who service mortgage 00:14:43.248 --> 00:14:46.978 accounts in the same level of protection, whether the accounts are maintained at 00:14:46.978 --> 00:14:48.788 federally insured credit unions or banks. 00:14:49.163 --> 00:14:54.423 We must ensure parity to the extent possible and maintain confidence in our 00:14:54.423 --> 00:14:56.513 nation's credit union and banking systems. 00:14:56.793 --> 00:14:58.973 I therefore support this change to our rule. 00:14:59.353 --> 00:15:01.803 That said, before closing, I do have several questions. 00:15:02.263 --> 00:15:06.763 First, will the merger of revocable and irrevocable trust categories 00:15:06.983 --> 00:15:10.833 into one single group for share insurance affect the application, 00:15:11.113 --> 00:15:13.633 um, of, or operation of state law? 00:15:14.363 --> 00:15:14.993 staff (3): No, it should not. 00:15:14.993 --> 00:15:18.483 The rule really just affects the NCUA's coverage of share insurance and 00:15:18.483 --> 00:15:19.733 should have no impact on state law. 00:15:19.813 --> 00:15:23.943 Chairman Harper: So, federalism standards, states can still set their own laws. 00:15:24.263 --> 00:15:25.993 This is just for ourselves. 00:15:26.133 --> 00:15:26.643 Thank you. 00:15:26.803 --> 00:15:28.913 It's good to know that our regulatory change will not 00:15:28.913 --> 00:15:30.203 affect state law in any way. 00:15:30.448 --> 00:15:35.458 Second, um, many credit union staff members, um, staff and members rely 00:15:35.458 --> 00:15:40.108 on the NCUA's Your Insured Funds brochure, as well as MyCreditUnion. 00:15:40.118 --> 00:15:42.928 gov to answer questions about share insurance coverage. 00:15:43.228 --> 00:15:46.478 Once we publish these regulatory changes in the Federal Register. 00:15:46.813 --> 00:15:50.063 How quickly do we anticipate having both resources updated? 00:15:51.083 --> 00:15:51.673 staff (4): We can take that. 00:15:51.723 --> 00:15:55.013 Um, we're fully committed to updating the year insured, um, 00:15:55.033 --> 00:15:56.773 funds brochure and mycreditunion. 00:15:56.823 --> 00:15:58.363 gov as quickly as possible. 00:15:58.793 --> 00:16:01.053 Appreciate the importance of those resources to credit 00:16:01.053 --> 00:16:02.333 union staff and members. 00:16:02.653 --> 00:16:05.723 Staff have already started working on the scope of defining, uh, the 00:16:05.723 --> 00:16:09.663 necessary updates and assuming, um, the board approves this final rule 00:16:09.663 --> 00:16:12.803 today, we will immediately start an update on all the relevant materials. 00:16:12.978 --> 00:16:15.598 Chairman Harper: And if I recall though, your insured funds brochure 00:16:15.598 --> 00:16:18.908 is, it's a lengthy document, so it may take a little bit of time. 00:16:18.908 --> 00:16:18.998 Forty six 00:16:18.998 --> 00:16:19.718 staff (4): pages, I think. 00:16:19.728 --> 00:16:19.968 Yeah. 00:16:21.118 --> 00:16:21.518 Apparently. 00:16:22.168 --> 00:16:25.718 Um, we also recognize the importance of developing materials that accommodate 00:16:25.878 --> 00:16:28.958 the delayed effective date for both, uh, for the trust account changes. 00:16:28.968 --> 00:16:31.838 We're committed to making sure that those resources are available. 00:16:32.103 --> 00:16:36.643 Um, that both help clarify existing share insurance coverage and, uh, what future 00:16:36.643 --> 00:16:38.343 share insurance coverage will, will be. 00:16:38.573 --> 00:16:41.393 We plan to post the updated materials as they are ready. 00:16:41.793 --> 00:16:44.883 CURE staff will also continue to be available to answer any share 00:16:44.883 --> 00:16:48.373 insurance questions, um, that staff and crediting members may have. 00:16:48.473 --> 00:16:48.683 Chairman Harper: Yeah. 00:16:48.723 --> 00:16:52.163 And I know that the FDIC provided for a long time frame for 00:16:52.163 --> 00:16:53.463 implementation of its change. 00:16:53.463 --> 00:16:56.713 Are we providing, uh, equally a long time frame? 00:16:57.098 --> 00:16:57.598 staff (4): Yes. 00:16:57.888 --> 00:16:59.308 I believe it's almost identical. 00:16:59.328 --> 00:16:59.578 Yes. 00:16:59.578 --> 00:17:01.188 It's almost identical to the FDIC one. 00:17:01.198 --> 00:17:01.498 Great. 00:17:01.498 --> 00:17:01.938 Thank you. 00:17:02.298 --> 00:17:04.998 Chairman Harper: I know that I would like to have the updated resources in 00:17:04.998 --> 00:17:09.098 place as soon as possible and appreciate the hard work of the NCUA team that 00:17:09.168 --> 00:17:11.058 will go into completing those tasks. 00:17:11.298 --> 00:17:15.018 Finally, in the preamble to this rule, we note that the 1. 00:17:15.098 --> 00:17:19.368 25 million per grantor cap is unlikely to be too low. 00:17:19.828 --> 00:17:23.008 What evidence do we have for reaching that conclusion, Tom? 00:17:23.238 --> 00:17:27.048 What, for example, is the median size of a trust fund or the 00:17:27.048 --> 00:17:28.898 amount of the average inheritance? 00:17:29.038 --> 00:17:29.328 staff (3): Sure. 00:17:29.618 --> 00:17:33.478 So, uh, the final rule actually cites survey data indicating that the median 00:17:33.478 --> 00:17:37.778 size of a trust fund is around 285, 000, which is obviously well short of the 00:17:37.778 --> 00:17:39.798 maximum coverage available under the rule. 00:17:40.278 --> 00:17:43.288 Uh, additionally, comment or input addressing this issue agreed that the 1. 00:17:43.288 --> 00:17:48.218 25 million per grant or cap was unlikely to be too low as the vast majority of 00:17:48.218 --> 00:17:49.868 accounts are well below that level. 00:17:50.363 --> 00:17:53.263 Uh, this aligns with, you know, staff's general experience as well. 00:17:53.323 --> 00:17:58.313 Um, that commenter did, however, ask that the NCOA track liquidations to ensure 00:17:58.313 --> 00:18:02.053 the cap is not too low, and the final rule actually notes that the agency does 00:18:02.053 --> 00:18:06.923 plan to continue to track uninsured, uh, amounts in liquidations, if any, and 00:18:06.923 --> 00:18:10.373 can further, uh, Uh, can explore further changes if that should become warranted. 00:18:10.373 --> 00:18:11.163 And in fact, 00:18:11.163 --> 00:18:13.703 Chairman Harper: the call report changes that the Vice Chairman and I 00:18:13.703 --> 00:18:17.453 have been both talking about, uh, have changes related to uninsured shares. 00:18:18.143 --> 00:18:19.653 Um, thank you for those answers. 00:18:19.653 --> 00:18:21.143 That concludes my remarks. 00:18:21.143 --> 00:18:22.553 I now recognize the Vice Chairman. 00:18:24.423 --> 00:18:25.163 VC Hauptman: Thank you, sir. 00:18:25.203 --> 00:18:26.503 Chairman Harper: Uh, what was 46 pages? 00:18:27.013 --> 00:18:27.403 staff (4): You mentioned? 00:18:27.413 --> 00:18:28.563 Uh, your insured funds brochure. 00:18:28.603 --> 00:18:29.713 Uh, don't, um, don't quote me. 00:18:30.063 --> 00:18:31.123 I think it's somewhere on there. 00:18:31.383 --> 00:18:31.683 Oh, yeah. 00:18:31.793 --> 00:18:32.843 That's a pretty lengthy guidance. 00:18:32.863 --> 00:18:33.443 It's lengthy. 00:18:34.023 --> 00:18:35.533 VC Hauptman: Today's, uh, rule. 00:18:36.048 --> 00:18:37.738 I was looking at 72 pages. 00:18:37.968 --> 00:18:40.388 I know it can be a, it gives me pause. 00:18:40.598 --> 00:18:41.668 Hey, we're simplifying things. 00:18:41.678 --> 00:18:44.618 Here's a 72 page government document on the simplification. 00:18:44.968 --> 00:18:49.148 It can feel a little weird, but I will, um, I think this is a positive change. 00:18:49.168 --> 00:18:50.758 I'm going to be supporting it. 00:18:50.838 --> 00:18:53.368 I'll say regulatory relief can come in a lot of forms. 00:18:53.438 --> 00:18:56.438 The best kind is what we're doing today, which is regulatory relief 00:18:56.748 --> 00:18:58.338 that isn't taking on more risk. 00:18:58.633 --> 00:19:00.423 Or reducing government oversight. 00:19:00.523 --> 00:19:02.193 It's just adding clarity. 00:19:02.883 --> 00:19:06.213 I think this is a good time to remind ourselves that the question of how easy 00:19:06.213 --> 00:19:11.938 it is to follow the rules It's determined solely by those who have to follow 00:19:11.938 --> 00:19:14.288 them, not those of us who write them. 00:19:15.448 --> 00:19:17.918 NCUA insurance specialists in the last five years have 00:19:17.918 --> 00:19:19.768 received over 17, 000 calls. 00:19:20.648 --> 00:19:24.788 Staff estimates that over half of those are related to coverage for trust 00:19:24.788 --> 00:19:26.978 accounts, revocable and irrevocable. 00:19:26.978 --> 00:19:31.443 And that 17, 000 Again, just over half we think are related 00:19:31.533 --> 00:19:32.783 to this issue, trust accounts. 00:19:33.133 --> 00:19:35.353 That does not include inquiries we got via email. 00:19:35.443 --> 00:19:37.613 It does not include inquiries from MyCreditUnion. 00:19:37.643 --> 00:19:41.803 gov or inquiries received by NCUA staff directly. 00:19:42.323 --> 00:19:45.863 It also doesn't include credit unions that had questions but got the answer from 00:19:45.863 --> 00:19:52.393 another credit union, nor does it include credit unions that had questions but 00:19:52.393 --> 00:19:54.023 were too nervous to tell their regulator. 00:19:55.123 --> 00:19:58.233 That, by definition, happens more often than regulators realize. 00:19:58.923 --> 00:20:00.823 So today's action is Smart Regulatory Relief. 00:20:00.873 --> 00:20:04.093 We at the NCUA are also saving ourselves time and effort. 00:20:04.813 --> 00:20:08.093 Both rules on today's board agenda provide much needed improvements on 00:20:08.233 --> 00:20:10.263 consistency, simplification, and clarity. 00:20:10.823 --> 00:20:12.953 Today's final rule on insurance coverage is substantially 00:20:12.953 --> 00:20:14.563 unchanged from the proposed rule. 00:20:14.583 --> 00:20:18.263 Thank you to the 13 stakeholders who put, uh, who submitted comments. 00:20:18.793 --> 00:20:20.393 These comments were universally supported. 00:20:20.683 --> 00:20:23.303 It provides some suggestions for some changes. 00:20:23.303 --> 00:20:27.963 They appreciate the benefits of a simpler calculation and being at parity 00:20:28.003 --> 00:20:30.043 essentially with what the FDIC does. 00:20:30.223 --> 00:20:33.793 This rule simplifies and reduces the number of rules governing 00:20:33.793 --> 00:20:34.933 the treatment for trust accounts. 00:20:35.613 --> 00:20:38.303 The regulation establishes a single category for trust accounts 00:20:38.303 --> 00:20:41.403 using a common calculation for both revocable and irrevocable. 00:20:41.973 --> 00:20:45.013 The final rule is also intended to streamline the currently 00:20:45.043 --> 00:20:48.903 time consuming trust review process and facilitate faster. 00:20:49.328 --> 00:20:52.558 Payouts to beneficiaries by reducing unclear and confusing 00:20:52.558 --> 00:20:53.338 elements of this rule. 00:20:53.338 --> 00:20:57.298 Credit unions, their employees and NCA staff are better able to serve the public. 00:20:57.788 --> 00:21:00.398 The ultimate beneficiary should be credit union members. 00:21:01.508 --> 00:21:05.518 Uh, one last thing on this topic directly, uh, the way we 00:21:05.518 --> 00:21:06.643 really help small credit unions. 00:21:07.588 --> 00:21:10.638 It's not by increasing our budget and adding lots of more exam 00:21:10.638 --> 00:21:14.828 hours to answer questions about our own rules that we wrote. 00:21:15.948 --> 00:21:19.038 The way to help is you make it less burdensome to operate and 00:21:19.048 --> 00:21:20.438 start a small credit union. 00:21:20.528 --> 00:21:25.328 Succession planning is also easier when NCUA can help make the job of running a 00:21:25.328 --> 00:21:27.518 small credit union a more attractive job. 00:21:27.558 --> 00:21:31.158 Sometimes these are labors of love in some small credit unions and it 00:21:31.158 --> 00:21:32.158 could be a little bit more than that. 00:21:33.043 --> 00:21:36.623 Um, that concludes my remarks directly on this, except just to make a public 00:21:36.623 --> 00:21:39.803 service announcement, which is, folks, please update your beneficiaries. 00:21:41.153 --> 00:21:44.313 When my mother passed away of her three children, for some reason, I was the one 00:21:44.363 --> 00:21:46.573 that had to do all the paperwork, and she didn't have a whole lot of money. 00:21:46.573 --> 00:21:50.693 But boy, was it easier that the three of us were named as beneficiaries, 00:21:50.693 --> 00:21:52.083 including her credit union account. 00:21:52.753 --> 00:21:56.993 Um, got the money quickly to, Dave Ramsey says, uh, you know, the 00:21:56.993 --> 00:21:59.403 one thing you want to leave your heirs is peace and simplicity. 00:22:00.093 --> 00:22:04.033 Um, so, my mother thankfully updated beneficiaries, that was 00:22:04.033 --> 00:22:06.803 a good scenario, and nobody wants to be, you know, the worst case. 00:22:06.983 --> 00:22:11.533 If you remember Atlanta 2016, woman hired a guy, had her new husband 00:22:11.533 --> 00:22:13.963 killed for the insurance money, but the check went to the ex wife. 00:22:14.423 --> 00:22:14.783 You know, 00:22:15.003 --> 00:22:15.403 staff: so, 00:22:17.203 --> 00:22:18.743 VC Hauptman: moral of the story, update your beneficiaries. 00:22:18.993 --> 00:22:20.143 You know, so. 00:22:21.293 --> 00:22:26.033 A couple questions, uh, all right, a member has a trust account worth over 00:22:26.033 --> 00:22:27.343 one and a quarter million, right? 00:22:27.343 --> 00:22:27.913 Mm hmm. 00:22:28.093 --> 00:22:30.563 Got more than five beneficiaries at a single credit union. 00:22:31.703 --> 00:22:33.913 Is there a mechanism to allow credit unions and members the 00:22:33.913 --> 00:22:38.133 ability to restructure their accounts to accommodate the changes? 00:22:38.143 --> 00:22:38.413 I can 00:22:38.993 --> 00:22:39.773 staff (4): take that question. 00:22:40.243 --> 00:22:43.233 Uh, it's true that there may be some instances where a single 00:22:43.233 --> 00:22:44.683 member, um, with more than 1. 00:22:44.723 --> 00:22:48.493 25 million in trust at a single credit union may see their coverage reduced. 00:22:49.043 --> 00:22:52.403 However, because of some of the simplifications, um, of what are currently 00:22:52.403 --> 00:22:54.198 insured as irrevocable trust accounts. 00:22:54.198 --> 00:22:58.967 Um, Regarding restructuring accounts, members with funds in excess of 00:22:58.967 --> 00:23:04.213 the maximum insured amount would have until the new trust account 00:23:04.213 --> 00:23:09.018 coverage provisions go into effect to restructure their accounts. 00:23:09.168 --> 00:23:12.228 The trust account changes in the Final Rule would not go into effect until 00:23:12.228 --> 00:23:16.088 December 1, 2026 over two years from now. 00:23:16.498 --> 00:23:20.578 The delayed effective date mirrors the one the FDIC provided in, in their own rule. 00:23:21.333 --> 00:23:25.353 Members with funds over the insured limit have multiple potential options for 00:23:25.353 --> 00:23:29.913 rearranging their accounts depending on their specific facts and circumstances. 00:23:30.223 --> 00:23:32.703 They may just want to move the excess funds into a different federally 00:23:32.703 --> 00:23:35.603 insured credit union to ensure that all of their funds are insured. 00:23:35.873 --> 00:23:39.103 Alternatively, they may be able to restructure their funds within their 00:23:39.103 --> 00:23:42.763 current federally insured credit union so that the excess funds are insured under 00:23:42.763 --> 00:23:46.603 a different insurance category, such as the single ownership account category. 00:23:47.588 --> 00:23:51.018 Uh, in the rare event a member has a sheriff's certificate that exceeds 00:23:51.018 --> 00:23:54.658 a two year delayed effective date and has trust funds that are over 1. 00:23:54.658 --> 00:23:58.798 25 million that would be uninsured, the member may need to work with their 00:23:58.798 --> 00:24:02.588 credit unit to determine the best path to restructuring the impacted funds 00:24:02.938 --> 00:24:05.908 in advance of December 1st, 2026. 00:24:07.088 --> 00:24:09.348 I do also want to stress that I'm only referring to the 00:24:09.348 --> 00:24:12.018 restructuring of trust accounts at a federally insured credit unit. 00:24:12.108 --> 00:24:15.338 The final rules impact should be limited to the insurance coverage of 00:24:15.348 --> 00:24:18.643 those accounts, Should not require an individual's actual formal 00:24:18.643 --> 00:24:20.773 trust document to be restructured. 00:24:21.323 --> 00:24:25.083 Finally, I think it's worth noting that where two individuals are co 00:24:25.083 --> 00:24:29.443 owners of a trust account, such as a payable unduty account with updated 00:24:29.463 --> 00:24:35.923 beneficiaries and correct beneficiaries, each co owner is entitled to up to 1. 00:24:35.923 --> 00:24:39.423 25 million in coverage if they have at least five beneficiaries. 00:24:39.423 --> 00:24:41.803 In other words, a couple could have as much as 2. 00:24:41.803 --> 00:24:44.393 5 million in coverage of their trust accounts at one 00:24:44.393 --> 00:24:45.493 federal insurance credit union. 00:24:45.693 --> 00:24:46.773 That concludes my response. 00:24:46.843 --> 00:24:46.983 staff: Whew. 00:24:47.383 --> 00:24:47.833 VC Hauptman: Gotcha. 00:24:47.883 --> 00:24:52.323 Uh, um, one of the commenters suggested grandfathering existing trusts. 00:24:52.533 --> 00:24:54.773 What's the reasoning for not doing the grandfathering? 00:24:54.853 --> 00:24:55.113 staff (3): Sure. 00:24:55.113 --> 00:24:56.203 I can, uh, take that one. 00:24:56.223 --> 00:24:57.013 So, that's correct. 00:24:57.033 --> 00:24:59.493 We had three commenters that expressed support for some form of 00:24:59.523 --> 00:25:01.313 grandfathering of existing accounts. 00:25:01.573 --> 00:25:03.963 Um, in discussing this, the final rule of preamble refers 00:25:03.963 --> 00:25:05.353 to this as legacy coverage. 00:25:05.728 --> 00:25:07.068 Those comments were strongly considered. 00:25:07.138 --> 00:25:10.818 However, it's staff view that providing legacy coverage for existing accounts 00:25:10.828 --> 00:25:13.808 poses complications and burdens to federally insured credit unions, 00:25:14.078 --> 00:25:17.918 account holders, and the NCUA that makes such a system largely unworkable. 00:25:18.318 --> 00:25:21.658 Uh, you know, in short summary, legacy coverage would undo the benefits 00:25:21.658 --> 00:25:23.298 of simplifying the proposed rule. 00:25:23.958 --> 00:25:27.158 Uh, to provide legacy coverage, the NCOA would have to effectively 00:25:27.158 --> 00:25:30.468 maintain two sets of rules, the new simpler trust rules and also the 00:25:30.468 --> 00:25:34.788 entire current regime of trust, uh, which have generated so much confusion 00:25:34.788 --> 00:25:36.308 and resulted in so many questions. 00:25:36.338 --> 00:25:39.338 With two sets of rules in place, there's yet another step which would 00:25:39.338 --> 00:25:43.438 need to, which would involve, uh, adding the multiple existing account. 00:25:43.878 --> 00:25:46.848 Which would add to the multiple existing steps we already have under 00:25:46.848 --> 00:25:48.628 the current rules for trust accounts. 00:25:49.418 --> 00:25:53.058 So, in evaluating coverage, NCUA, credit unions, and members would 00:25:53.058 --> 00:25:56.128 then first have to ask whether an account was in existence at the time 00:25:56.128 --> 00:25:59.688 the NCUA adopted this new rule, or the new trust account coverage rule. 00:26:00.218 --> 00:26:03.418 Accounts that did exist at that time would still have the existing complicated 00:26:03.418 --> 00:26:04.948 analysis applied to their funds. 00:26:05.858 --> 00:26:08.808 In addition to largely undermining the simplification, clarity, and burden 00:26:08.808 --> 00:26:12.458 reduction benefits the rule would provide, legacy coverage would also pose 00:26:12.698 --> 00:26:16.438 yet new questions that could further complicate share insurance rules. 00:26:16.788 --> 00:26:19.868 So just by example, the rule would need to address what impact change in 00:26:19.868 --> 00:26:23.588 beneficiary, an account restructuring, or other similar action meant for 00:26:23.588 --> 00:26:25.433 the legacy status of the account. 00:26:26.103 --> 00:26:29.263 Um, so basically add yet another complication to an already 00:26:29.313 --> 00:26:30.663 complicated set of rules. 00:26:31.473 --> 00:26:34.493 I also want to reiterate that the NCUA has consistently tried to make 00:26:34.493 --> 00:26:37.823 sure that where it's possible there's parity between NCUA coverage and 00:26:37.833 --> 00:26:39.633 FDIC deposit insurance coverage. 00:26:39.893 --> 00:26:43.063 If we were to provide a, you know, legacy account situation, we would 00:26:43.063 --> 00:26:46.393 then not have complete parity with what FDIC is currently doing. 00:26:47.323 --> 00:26:50.153 Uh, our hope is that by providing a substantially delayed effective date, 00:26:50.153 --> 00:26:53.103 which is in excess of two years, federally insured credit unions and 00:26:53.103 --> 00:26:56.123 their account holders should have enough time to make any needed changes 00:26:56.123 --> 00:26:59.893 to their accounts to, uh, essentially make legacy accounts not necessary. 00:26:59.923 --> 00:26:59.943 Yeah, 00:27:00.303 --> 00:27:01.123 VC Hauptman: I think that's a fair answer. 00:27:01.193 --> 00:27:03.023 I think the comment is not unreasonable. 00:27:03.693 --> 00:27:05.123 It's one we sort of expected. 00:27:05.163 --> 00:27:05.453 Right. 00:27:05.483 --> 00:27:06.233 But I get it. 00:27:06.283 --> 00:27:10.343 Uh, we're trying to reduce everybody's effort and somebody 00:27:10.343 --> 00:27:13.493 would say, well, my neighbor just told me they don't have to do this. 00:27:13.553 --> 00:27:15.463 And then we'd have to explain that to them. 00:27:15.503 --> 00:27:18.563 The person answering this question would have to know that way back in the day. 00:27:18.573 --> 00:27:20.663 I mean, this conversation could be in 20 years. 00:27:20.703 --> 00:27:20.953 Yeah. 00:27:21.413 --> 00:27:24.493 Um, and it also creates some strange situations where maybe 00:27:24.493 --> 00:27:27.763 you want to take your business elsewhere, but you're tied in. 00:27:27.763 --> 00:27:27.828 Right. 00:27:28.228 --> 00:27:29.328 To this old legacy account. 00:27:29.338 --> 00:27:30.348 You don't want to disturb that. 00:27:30.368 --> 00:27:36.438 Um, so I agree, uh, not a person who sent that in, not a strange request. 00:27:36.438 --> 00:27:37.968 Grandfathering is routinely done. 00:27:38.533 --> 00:27:42.663 Uh, in state and federal law, uh, but our purpose here is simplification, 00:27:42.673 --> 00:27:43.733 and I think it's the right call. 00:27:43.963 --> 00:27:48.553 Um, and where are we, just give me a rundown, uh, updates to the forms, the 00:27:48.553 --> 00:27:51.443 website, uh, our internal training, because people are going to maybe 00:27:51.443 --> 00:27:52.943 ask questions about this change. 00:27:53.583 --> 00:27:55.403 Where are we on preparing people for that? 00:27:56.063 --> 00:27:59.423 staff (4): We have the scope defined, um, so as soon as, you 00:27:59.423 --> 00:28:03.697 know, assuming you approve the rule, today we'll get started, um, on 00:28:03.697 --> 00:28:05.523 creating those materials right away. 00:28:07.338 --> 00:28:07.478 Thank 00:28:07.478 --> 00:28:07.748 VC Hauptman: you both 00:28:07.748 --> 00:28:08.068 Chairman Harper: for that. 00:28:08.238 --> 00:28:08.738 Back to you, Mr. 00:28:08.738 --> 00:28:08.988 Chairman. 00:28:09.278 --> 00:28:10.758 Uh, thank you, Mr. 00:28:10.868 --> 00:28:11.398 VC Hauptman: Vice Chairman. 00:28:11.398 --> 00:28:11.998 Is there a motion? 00:28:12.858 --> 00:28:13.318 Yes, sir. 00:28:13.518 --> 00:28:17.778 I move that the board approve final rule part 745 of N2A's rules and regulations as 00:28:17.778 --> 00:28:19.398 attached to the board action memorandum. 00:28:19.508 --> 00:28:20.638 Chairman Harper: I second the motion. 00:28:20.638 --> 00:28:21.758 All those in favor say aye. 00:28:21.818 --> 00:28:22.068 Aye. 00:28:22.128 --> 00:28:22.548 Aye. 00:28:22.628 --> 00:28:23.828 All those opposed say nay. 00:28:24.648 --> 00:28:29.168 Let the record show that the ayes have it and the motion passes two to zero. 00:28:30.708 --> 00:28:35.328 Samantha: This concludes the N C U A’s September 20 24 Board Meeting action on 00:28:35.328 --> 00:28:37.668 regulation Simplifying Share Insurance 00:28:38.337 --> 00:28:42.607 If your Credit union could use assistance with your exam, reach out to Mark Treichel 00:28:42.607 --> 00:28:45.237 on LinkedIn, or at mark Treichel dot com. 00:28:45.807 --> 00:28:48.467 This is Samantha Shares and we Thank you for listening.