Friday, February 26, 2016

Board Member Education

Who would argue against Mom, apple pie, or greater financial training for board members?  

Not me, because it is clear that some boards do not fully understand 1) accounting requirements, 2) financial statements, and 3) fiduciary responsibility. 

For example one Board with which I am familiar has repeatedly and very publicly in the past appeared to have significant lapses in all three of the above areas.  What is particularly intriguing is that this Board is perhaps the best Board that the institution has ever had in terms of financial, regulatory, political, and philosophical moorings.   It's a very, very highly talented group.  

The institution which this Board directs has:

  • Produced a $15 billion meltdown.

  • Failed in the past to publish in a timely fashion its required annual financial statements in violation of Federal law.
  • Been cited by its big four accounting firm for a material weakness in its internal controls. 
  • First lesson in your new financial training!!  "A material weakness is a deficiency, or combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the entity's financial statements will not be detected and corrected on a timely basis."
  • Avoided a major prior year restatement of its financials only through a "sleight of hand" and by switching financial audit firms.
  • Botched embarrassingly, the initial release of the risk-based capital rule (RBC).
  • Verbally dissed Congress.
  • Has not established a solid, professionally experienced staff, nor a reputation for informed, progressive management.
  • Failed to appropriately update its technology.
  • Lacks transparency and accountability to its primary constituency - the American public. 

Pass that buck!
A board under the financial training provisions of the new NCUA regulation 701.4  "...may delegate operational functions to management, but not the responsibility..."

NCUA management's response to the above mentioned irregularities and material weakness in internal controls was:  

"NCUA is a small Federal agency and must focus its resources on essential functions."

"Small" is an unusually amusing "explanation".  A small whale is after all still a whale, isn't it?

Training like leadership is always a matter of setting the example.

One would hope that all boards will take that idea and responsibility to heart.

NCUA is no one's example!
That needs to change!


Anonymous said...

There is zero doubt, Jim.
In addition to your points, there's also dissing congress on the low income designation.
Ignoring congressional intent on charter choice rules.
Ignoring executive order on contingency lawsuits.
5+ years of opaque CCU loss reporting.
OTR shenanigans.
"Sneaking"(?) their insurance fund ideas to congress while trades "covered" for them.
Dissing congress in open board meetings on "reg relief" ...nice going metsger.
The list goes on and on.
Question is, who holds them accountable?
And when?
Guess their supervisory prowess is so exemplary, they can get away with this.

Anonymous said...

The federal government is accountable to no one. That has been very clear for years and extends from the Executive branch to Congress to the agencies. Everyone in the credit union industry is well aware of the inabilities of NCUA to get anything done right. But this inability is promiscuous throughout the bloated government system. Will it ever change? We can only hope.