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Harper Calls for Dedicated Consumer Compliance Exams of Large Credit Unions

October 2019
Harper Calls for Dedicated Consumer Compliance Exams of Large Credit Unions

NCUA Board Member Asks for Comments during 2020-2021 Budget Consideration

ALEXANDRIA, Va. (Oct. 30, 2019) – National Credit Union Administration Board Member Todd M. Harper is requesting public comment on his proposal to create a dedicated consumer compliance exam program for large, complex credit unions.

“For more than three decades, the NCUA has focused its examination program primarily on safety and soundness reviews,” Harper said. “This policy worked well when the NCUA oversaw a large number of small credit unions serving a limited field of membership with only a few basic financial products, but today’s credit unions are larger and more complex, with 317 credit unions exceeding $1 billion in assets having 71.7 million members.”

The NCUA’s current compliance examinations covering consumer financial protection laws in credit unions with total assets of $10 billion or less differs from other financial institutions regulators. Other regulators complete regularly scheduled, risk-focused consumer compliance reviews and assign a separate consumer compliance rating outside of the CAMEL process for institutions under their jurisdiction.

Harper noted the NCUA’s approach to consumer financial protection reviews also runs counter to the congressionally mandated mission of the Federal Financial Institutions Examination Council, which works to develop uniform standards and processes across all financial institution regulators.

Harper would like to add three new full-time employees in the NCUA’s Office of Consumer Financial Protection in 2020, who would develop and later launch a dedicated consumer compliance examination program for large, complex credit unions.

“As the largest credit unions continue to grow in size, the time has come for the NCUA to evolve its consumer compliance program,” Harper said. “I invite all interested parties to comment on my proposal during the public deliberations over the NCUA’s proposed 2020–2021 budget.”

To comment on the proposal for a dedicated consumer compliance program, email by Dec. 2. To request to present at the Nov. 20 budget briefing, email For more details about commenting on the budget and presenting at the budget briefing, see the NCUA’s press release on the proposed 2020–2021 budget available at the NCUA Budget and Supplementary Materials page.

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