NCUA Board Member Tanya Otsuka Statment on Collection of Overdrafts and Non-Sufficient Fund Data

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

Hello, this is Samantha Shares. This episode covers N C U A Board Member Tanya Oatska’s statement on the agency’s Collection of Overdraft and Non-Sufficient Fund Data

The following is an audio version of that statement. 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 N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, 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.

NCUA Board Member Tanya Oatska Statement on N C U A’s Collection of Overdraft and Non-Sufficient Fund Data

during a meeting of the NCUA Board.

As Prepared for Delivery on May twenty second, twenty twenty four

The N.C.U.A. has a responsibility to ensure we have a safe and sound system of cooperative credit and a mandate to ensure that credit unions are following all applicable laws. The actions that N C U A has taken over the years with respect to overdraft and fee income is consistent with those responsibilities.

It’s important for the N C U A to understand the data both at the individual institution level and system wide. We also need to make sure that it is transparent for credit unions, credit union members and the public. Overdraft practices and fees should already be disclosed to members and in compliance with applicable laws.

An overreliance on overdraft and NSF fees adversely affects both members and their credit unions. Institutions that rely more on fee income have greater concentration risk.

N C U A’s supervisory priorities have included overdrafts for several years. In 20 18 and 20 19, N C U A examiners reviewed credit union overdraft practices, including opt-in disclosures, and conducted transaction testing to verify that credit unions were complying with the applicable regulatory provisions.

In 20 22, examiners requested information about a credit union’s policies and procedures governing its overdraft programs.

In 20 23, NCUA examiners started conducting reviews of overdraft website advertising, balance calculation methods, and settlement processes for federal credit unions with assets totaling 500 million dollars or more.

I think it is prudent to not prejudge the data or assume a narrative before assessing the data in aggregate. Our very capable staff is currently assessing the newly collected data and I look forward to reviewing it to get a better sense of the bigger picture.

This concludes the statement.

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.