Much ado has been made of late, within the credit union regulatory world, about the need for you to perform "due diligence reviews" of third party providers of services to your credit union. Such advice, within reason, appears to be sound and finds little objection among the credit union community.
Still, even sound regulatory "guidance" continues
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At "NCUA Disney":
"It's a Small World After All" |
to be delivered in letters, findings, and DORs laced with strong traces of "arsenic intimidation" and lightly veiled threats of fiduciary irresponsibility for your slightest failure to conform.
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| Z-z-z-tam !!! |
Evidently "The Agency Attitude" (despite that repeated annual "Disney" training) remains entrenched: "We know you're a criminal; we just haven't caught you yet... but we will." Guilty until proven innocent remains "best practices" out in the regional provinces and along the banks of the Alexandrine Potomac.
In performing third party due diligence, it is quite logical to rank providers by the degree of risk they pose to your credit union. Clearly, attention and review should be focused first on those providers which have or may cause your credit union the greatest loss.
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| "And, now for the $15 billion answer..." |
Q: Which third party provider has caused your credit union the largest unexpected loss over the last five years?
That's right by far it's ...
A: The National Credit Union Share Insurance Fund (NCUSIF)!**
** "Someone" might imply you were "fiduciarily irresponsible" if you don't do a little due diligence on this crowd!
That "someone" might just be your member-owners!
[Don't you think you should start asking a few questions - publicly?]
6 comments:
Scripted questions is the choice method of communication at NCUA. Interviews are only conducted when questions are submitted in advance. Don't write a story they may not like or you will be forever persona non grata. In other words they will tell you what they want you to know when.
You know Chair Matz has a "little reckoning" with a Congressional finance committee - testimony under oath - this Friday the 24th.
Believe you have a couple of blog followers who can make sure the Chair is asked important policy questions.
So, just for sport; what questions would you suggest be posed by a Congressman to Ms. Matz? What does Congress - and all Americans - need to know about the NCYA?
Why would any one rob a credit unions when they can be employed by NCUA and do it under Union Contract?
You should have done this particular post during the week, because people should jump the opportunity to load up the HFSC. Here’s my question.
Why are credit unions subject to such inconsistent and incoherent supervision, where there is an office of separate supervision for credit unions that splits us into 3 groups (under $50m, $50m - $10b, and over $10b)? Is it because the NCUA is beyond its skis in trying to deal with how credit unions have become so different from each other? Much the same way that the trade associations are struggling for comprehensive relevance, but failing?
Let's get some discussion going.
Mrs. Matz why the hedging rule is written in such a way to cause covered credit unions to have no interest in pursuing. Is it because "We are a small federal agency with limited resources" as you said when you declared the agency couldn't handle the stress test for the ONES? Is the agency attempting to hide how it has not evolved, as many credit unions have evolved? That the agency in fact, suffers from a lack of modernization? And at the expense of credit unions?
Why shouldn't the NCUSIF be separated from the NCUA given clear monetary and administrative conflicts of interest?
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