Credit Union Policy Reviews

¹ Sections of the Federal Credit Union Act and NCUA regulations require credit unions to have written programs, which may be in the form of a policy. For example, part 748 (opens new window) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) requires a written Bank Secrecy Act compliance program.

² Per §741.203(a), federally insured, state-chartered credit unions are required to adhere to the requirements stated in part 723 (opens new window) (You will be leaving NCUA.gov and accessing a non-NCUA website. We encourage you to read the NCUA's exit link policies. (opens new page).) concerning commercial lending and member business loans unless the state supervisory authority administers a rule that at least covers all the provisions in part 723 and is no less restrictive, upon determination by NCUA. In nonexempt states, all required NCUA reviews and approvals will be handled in coordination with the state supervisory authority.

³ See footnote #2 above.

⁴ Other policies may be required by federal or state statute. This list is limited to policies or procedures required by the Federal Credit Union Act, NCUA regulations, or the Federal Credit Union Bylaws. Policies should be established prior to beginning the program. Credit unions are not required to establish standalone policies for each item listed; similar subjects may be combined into a single policy. Other sections of the Federal Credit Union Act and NCUA regulations require credit unions to have written programs, which may be in the form of a policy.

⁵ FCU Act §1772d(b)(2) states the NCUA Board shall issue a notice of its intention to terminate a federally insured credit unions rights, privileges, and franchises if the credit union is convicted of certain money laundering or cash transaction reporting offenses. In deciding whether the credit union’s franchise should be forfeited, one factor the Board must consider is if the extent to which the offense occurred despite the existence of policies and procedures within the credit union which were designed to prevent the occurrence of any such offense.

⁶ See footnote #2 above.

⁷ See footnote #2 above.

⁸ §717.90(b)(3)(i)&(ii) of the regulations define a covered account as an account offered primarily for personal, family, or household purposes, that involves or is designed to permit multiple payments or transactions, such as a credit card account, mortgage loan, automobile loan, checking account, or share account; (and), any other account for which there is a reasonably foreseeable risk to members or to the safety and soundness of the federal credit union from identity theft, including financial, operational, compliance, reputation, or litigation risk.

⁹ Part 741, Appendix B includes guidance related to nonaccrual policies and procedures.

¹⁰ §741.6(b) does not require a federally insured credit union with total assets less than $10 million to file financial and other reports reflecting GAAP, unless state law requires a federally insured state-chartered credit union to follow GAAP regardless of asset size.

¹¹ Part 741, Appendix B includes guidance related to workout policies and procedures.

¹² Per §701.25, “other credit unions” includes corporate credit unions and privately insured credit unions.

¹³ This list is limited to policies recommended by the Federal Credit Union Act, NCUA regulations, or the Federal Credit Union Bylaws.

¹⁴ Part 748, Appendix A provides information security program guidelines, but the Gramm-Leach-Bliley Act and §748.0 incorporate mandatory requirements related to a credit union’s information security program.

¹⁵ Each credit union should report to its board or appropriate committee of the board at least annually the overall status of the information security program.