Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

Tanya Otsuka’s Speech at the 2024 Governmental Affairs Conference

 

This episode of 'Samantha Shares' features an audio version of National Credit Union Administration Board Member Tanya Otsuka’s speech delivered at the 2024 Governmental Affairs Conference, sponsored by Credit Union Exam Solutions Incorporated. Otsuka discusses her background, experiences, and the lessons learned from previous financial crises, emphasizing the importance of safety and soundness, consumer protection, and the role of credit unions in the economy. She outlines her commitment to supporting small, low-income, and minority depository institutions, combating geography, racial, and socio-economic disparities in financial services, and improving access to safe and affordable financial products. Otsuka highlights initiatives and examples of credit unions positively impacting their communities and addresses the challenges faced by credit unions, including cybersecurity and economic pressures. She underscores the unique advantages of credit unions and the NCUA's role in ensuring a healthy, competitive, and inclusive financial system for all members.

 

00:00 Introduction

00:48 Opening Remarks and Background

01:29 Vision and Priorities as a Board Member

02:06 Importance of Safety, Soundness and Consumer Protection

03:41 Addressing Geographic, Racial, and Socio-economic Disparities

04:44 Examples of Credit Unions Making a Difference

05:27 Agency Resources and Initiatives

06:28 Challenges Faced by Credit Unions

07:03 The Credit Union Difference

08:01 Conclusion and Future Engagement

08:05 Closing Remarks

What is Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC?

This podcast provides you the ability to listen to new regulatory guidance issued by the National Credit Union Administration, and occasionally the F D I C, the O C C, the F F I E C, or the C F P B. We will focus on new and material agency guidance, and historically important and still active guidance from past years that NCUA cites in examinations or conversations. This podcast is educational only and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated. We also have another podcast called With Flying Colors where we provide tips for achieving success with the N C U A examination process and discuss hot topics that impact your credit union.

NCUA Board Member Tanya Otsuka Remarks at the 2024 Governmental Affairs Conference
Samantha: [00:00:00] Hello, this is Samantha Shares. This episode covers National Credit Union Administration Board Member Tanya Otsuka’s Remarks at the twenty twenty four Governmental Affairs Conference
The following is an audio version of her published speech. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with NCUAso they save time and money. If you are worried about a recent, upcoming or in process NCUAexamination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.
And now the speech.
As Prepared for Delivery on March 5, 2024
Thank you, and everyone at America’s Credit Unions for the invitation. Special thanks to the convention center staff and everyone behind the [00:01:00] scenes who helped put this event together and are making sure it runs smoothly.
And of course, thank you all for being here and for the work you do in your communities every day.
I am honored to be here at this year’s Governmental Affairs Conference. It has been a dynamic two days and I have enjoyed speaking with so many people dedicated to the credit union movement.
Conferences like these give me the opportunity to hear directly from you about the challenges facing credit unions and their communities, as well as their many successes. It also gives me the chance to share my vision and priorities as a National Credit Union Administration Board Member.
As many of you know, prior to joining the Board, I served as Senior Counsel for the majority staff of the U.S. Senate Banking, Housing, and Urban Affairs Committee, where I handled banking and credit union issues. Before that, I was an attorney at the F D I C for nearly ten years, working on many issues that cross over to credit unions. During my time in these roles, the aftermath of the two thousand and eight financial crisis, [00:02:00] the COVID 19 pandemic, and the spring 2023 bank failures left a lasting impression on me. These experiences showed me firsthand the importance of safety and soundness and consumer protection, and the vital role that small and community based financial institutions play in our economy.
My work as a board member will be guided by a commitment to a safe and sound financial system of cooperative credit that ensures members benefit from fair and affordable products and services. Safety and soundness and consumer protection are not two separate issues.
Safety and soundness rules mitigate risks to the Share Insurance Fund so that the NCUA can protect member shares in case of failure and not rely on taxpayers for support. Consumer protection laws are intended to ensure members understand the financial products and services offered to them and that they are offered on fair terms. They both depend on strong management. Consumer compliance failures can often indicate problems with internal controls, operational risk, or lead to [00:03:00] broader financial risks. And unfair banking practices are not sound banking practices. When fees or costs for products and services exceed operational expenses, raise concentration risk, or are disproportionate to the benefit, that not only raises safety and soundness and consumer protection concerns, but it also goes beyond the member-first mission.
That is why it is important to stay focused on how well credit unions are serving their members. When members are harmed, we have a responsibility to hold institutions accountable and make sure customers are made whole. These guardrails are in place to make sure we have a stronger, fairer, and more competitive marketplace for credit unions and consumers alike.
I will also focus on making sure that credit unions, especially small, low-income, and minority depository institutions, can continue to stay competitive and provide affordable financial services to their members in a constantly evolving financial system. We know that across the country there are many communities that have limited access to [00:04:00] safe and affordable financial services. The number of banking deserts is increasing. Many rural communities have fewer resources after years of disinvestment and face higher levels of persistent poverty. Black and Hispanic families have about one million dollars less wealth, on average, than white families, and racial disparities in lending still exist today across income levels.
Home ownership is out of reach for most Americans – just 15 percent of homes for sale are affordable for a typical U.S. household. As a country, we have a lot of work to do to address these geographic, racial, and socio-economic disparities, and credit
As not-for profit cooperatives, credit unions have an obligation to meet the deposit and credit needs of their members. I am encouraged by the many examples of credit unions doing just that. To encourage more workforce housing, a credit union in Oregon offered lower interest rates for properties that maintained affordable rental rates. There’s a credit union in Virginia that partners with Habitat for [00:05:00] Humanity, the Federal Home Loan Bank, local government, the CDFI Fund, and others to offer down payment assistance and non-conforming home loans for those who may not qualify for a traditional mortgage. An Ohio M D I credit union recently expanded to a former bank branch to continue to serve that area of the community. There are several credit unions that have auto portfolios with an average credit score in the 500s, but their delinquency rates are below one percent.
The NCUA has many resources available through its ACCESS initiative, grants to low-income credit unions under the Community Development Revolving Loan Fund, and free online classes on strategic planning and serving underserved communities. We recently finalized our updated M D I policy statement, and the NCUA has several small credit union initiatives, including the small credit union exam program and small credit union support program.
I hope to keep learning from credit unions that are finding creative ways to meet the unique needs of their members. [00:06:00] And I will continue to focus on the efficacy of these programs to see how we can improve and build on them. I welcome your feedback and ideas – if the NCUA isn’t hitting the mark on these efforts, let us know. So many of you and those in your communities are thinking about the same issues, and I look forward to working together. While not all credit unions may be solely dedicated to serving marginalized communities, ALL credit unions must contribute to a fairer, more just, and inclusive financial system.
I also appreciate many of the challenges your institutions are facing. I heard from the Small Credit Union Committee on Sunday about cybersecurity challenges and the potential for increased delinquencies. I’ve heard about the increasing cost of funds and a slowdown in lending growth, which has put pressure on earnings. The increasing number of large credit unions with CAMELS 3 scores is a concerning trend, and I am watching this closely. Broader economic challenges come on top of external pressures to adopt cutting edge technology to compete with banks and [00:07:00] fintech while ensuring you can prevent the next cybersecurity breach.
This is where the credit union difference really matters. Lower interest rates, lower fees, more affordable products, and member-driven relationship banking are what gives credit unions their competitive edge. For example, a recent C F P B survey found that credit unions offer some of the lowest credit card interest rates. We want to see more consumers go to credit unions to get a checking account, credit card, or auto loan, instead of online lenders, fintech apps, and megabanks that have no connection to the local community.
The NCUA’s job as a strong, effective, and independent regulator is critical to protecting the millions of members who rely on us to safeguard their hard-earned money. By focusing on the fundamentals before there is a problem, we can ensure credit unions are well positioned for the future and able to meet their members’ financial needs in good times and bad. Ultimately, members benefit from access to a healthy credit union system and protecting that is central to why we [00:08:00] are all here today.
Thank you, and I look forward to continuing to engage with all of you.
This concludes Board member Otsuka’s speech.
If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening.