Tuesday, May 06, 2014

Contingency Planning….

What gives with "the finger"?
Several of you asked what the "Hope your finger's doing better." phrase meant in yesterday's blog. When a finger was mentioned as part of my interaction with the Agency,  many of you naturally assumed the worst. Well, that's not exactly what happened… let me explain.

First, let me acknowledge that Gerry Poliquin did call me back bright and early Monday morning. We had a very pleasant conversation about the process and procedures which NCUA uses for posting comment letters.  Mr. Poliquin was polite, informative and gracious.
Finger on the pulse of the Agency.

But by the time of his call, I had already "sniffed around" a bit in the back alleys and had received an "unofficial and confidential" rundown on NCUA's position.  You don't exactly have to be an Edward Snowden to "hack" into the NCUA "grapevine". Lot's of long-term, good-hearted folks at the Agency still willing to speak truth to power. 

Here's what I learned about NCUA's policy on posting comment letters:   They don't have one!

During several exchanges I heard a lot of explanations: "We do the best we can"; "We are a small Agency"; "We only have one webmaster"; "Usually every Thursday, but there is no set schedule"; "Sometimes it can take a couple of weeks"; "We don't have enough help"; "Gerry broke his finger"….

Which finger?
Never mind….
Guess I was a bit put-out by all those "explanations", but "Gerry broke his finger" kinda hit a nerve.  I asked if NCUA had a contingency plan for posting comment letters and I was advised that yes the plan was to get the comments posted when Gerry got back.  Which I guess, in a weird, twisted sort of way, does make some sense. 

No policy, no consistency, no backup, no contingency plan… but know what really got the tighty-whiteys in a wad?

Day Two plan?
It was remembering the self-righteous  pomposity of several recent Agency examiners,  who demanded written CU policies and procedures for every impossible, potential CU operational snafu - including the destruction of the credit union's home office by a once in a millennium asteroid strike.   A requirement with which the credit union could have abided (grin and bear it… right?), until the two robust, senior-capital-administrative-executive-regional-specialist-experts also demanded that the CU prepare a "Day Two" contingency plan for the aftermath of the asteroid strike!

So note in drafting future policy statements and contingency plans, CU's might find a finger helpful in making an NCUA exam response "more robust".... 

So what is the rule at NCUA:
 "Do as I say, or do as I do?"

(I'll let you know when Gerry gets back....)


Anonymous said...

I am not a technological savant, the lack of time or staff is a butt! I mean excuse and it stinks!

How difficult is it to paste a comment that comes in an email? This is not like they have to retype it and get it printed. Talk about not passing the sniff test!

Also the suggestion that NCUA does not have a policy is bull. They have a standard for performance on everything. It forms the basis for their blotted capricious bonuses paid to over paid bureaucrats. Suspect the standard of performance for posting difficult comments about very questionable regulatory proposals is delay as long as you possibly can and claim over work when questioned! Your bonus become a lock!

Jim Blaine said...

Well, we have one unhappy camper….