NCUA Letters to Credit Unions
NCUA recently released two Letter to Credit Unions worthy of note.
- NCUA released NCUA Letter to Credit Union 08-CU-08 to announce changes to the EPS questionnaires.
The revision resulted from significant technology changes and increased utilization of electronic payment systems by credit unions to provide services to members. The revised questionnaires replace the Automated Clearinghouse (ACH) and Wire Transfer Control questionnaires used to review a credit unionâÂÂs electronic payment systems program with a focus on specific processes related to ACH processing, wire transfers, and Federal Reserve Bank payment system services. Examiners will use the revised EPS questionnaires to complete their review. Examiners will tailor their review based on the credit union risk, electronic payment services utilized by the credit union, and use the applicable questionnaires to complete their review.
You can access the guidance here. As I've stated before, I place a high value on anything that examiners will use or read when they visit your credit union. If you know the type of questions that examiners will ask, you're a little ahead of the game. If someone would have created similar guidance documents for dating, I would have enjoyed high school much more.
     2. NCUA also released Letter to Credit Union 08-CU-09.
The purpose of this Letter is to provide Federally Insured Credit Unions with the new questionnaire NCUA field staff will use to complete the evaluation of credit union third party relationships. Enclosed with this Letter is a copy of the questionnaire.
NCUA issued Letter to Credit Unions 07-CU-13, Evaluating Third Party Relationships, in December 2007 and enclosed Supervisory Letter 07-01. Letter 07-CU-13 informed Federally Insured Credit Unions of the guidance provided to NCUA field staff regarding the evaluation of credit union third party relationships. This new questionnaire contains the three elements of an effective program as discussed in the enclosure to Letter 07-CU-13. The three elements are:
⢠Risk Assessment and Planning;
⢠Effective Due Diligence; and
⢠Risk Measurement, Monitoring, and Control.Examiners will evaluate third party relationships based on the risk of each relationship and use the questionnaire to document the review.
To summarize, here are all the recently-issued pieces of guidance for evaluating third-party relationships.
- Letter to Credit Unions 07-CU-13.
- NCUA's FAQ Guidance, issued following an NCUA webinar.
- Letter to Credit Unions 08-CU-09.
Enjoy, enjoy.