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February 09, 2022

NAFCU Reg Alert reviews NCUA’s proposed rule on succession planning

Regulation AlertNAFCU Tuesday sent members a Regulatory Alert regarding the NCUA’s proposed rule requiring federal credit union’s (FCU) board of directors to establish a process for succession planning. Under the proposed rule, approved at last month’s board meeting, the FCU must establish a plan for positions such as officers of the board, management officials, executive committee members, supervisory committee members, and (where provided for in the bylaws) credit committee members.

Of note, the proposal offers FCUs flexibility with developing a succession plan and encourages all credit unions to have plans in place to mitigate consolidation and prepare for future requirements.

Through the Regulatory Alert, NAFCU highlights:

  • the succession plan, at minimum, must identify the credit union’s key positions, necessary competencies and skillsets for those positions, and strategies to identify alternatives to fill vacancies; 
  • to provide continuity of operations, key positions may include officers of the board, management officials, executive committee members, supervisory committee members, as well as members of the credit committee; and
  • compliance with this rule will be assessed through examinations. 

Comments on the proposed rule are due to NAFCU March 18 and can be submitted through the alert; comments are due to NCUA April 4. 

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