The credit union reported 9.2% net worth at year-end 2025, alongside loan-to-assets of 27.8%, $108 million in cash on deposit at correspondent banks, and $41.8 million in non-member deposits. Mark works through why these patterns, taken together, are statistically extreme — Jackson Area is the only large credit union in the country with non-member deposits over 25% and loan-to-assets under 30%.

The episode also covers a roughly $2.13 million Q4 net worth entry that lifted capital back above the well-capitalized threshold against just $42,000 in reported quarterly income, the timing of NCUA’s filing of an estimated March 31 call report the day before the conservatorship, and what the language in the press release may signal.

Mark closes with five lessons for credit union boards: healthy ratios are not safety; the income statement can tell the truth the balance sheet hides; non-member deposits without lending growth deserve scrutiny; equity entries without income demand explanation; and NCUA examinations are not fraud audits.

This is a solo episode — Mark’s analysis is based entirely on public data, with no insider information.

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel sits down with Travis Goodman, CFA, Principal at ALM First Financial Advisors, and Mark Sun, Portfolio Manager at ALM First, to discuss the recent launch of the ALM First Loan Fund — the first non-registered investment fund approved by the National Credit Union Administration Board for federal credit unions, and the first trade just executed under it.

The conversation covers:

•        How the loan fund structure differs from a traditional loan participation, and why standardization matters at scale.

•        The institutional discipline built into the structure: third-party loss estimates, third-party agreed-upon procedures, and third-party cash agent functions.

•        Eligibility and guardrails: the 30-credit-union lifetime cap, the complex-credit-union requirement, the 50% and 15% net worth limits, and how state-chartered credit unions with federal parity can participate.

•        The pilot timeline: seven years from approval, or five years from the first trade — whichever comes first — and what it means for the path to permanence.

•        The role of credit union deposits as a unique, counter-cyclical source of funding in the institutional capital markets.

•        Asset eligibility, including the under-10-year maturity rule and the focus on consumer loan products.

•        How smaller credit unions might eventually benefit from the structure even if they are not eligible for the current pilot.

For credit unions interested in learning more about the ALM First Loan Fund, contact: loanfund@almfirst.com

https://www.linkedin.com/in/mark-treichel/

Mark Treichel is joined by Mike Macchiarola, Partner and CEO of Olden Lane, for a structured deep-dive into the most recent NCUA Annual Report. Mike organizes his analysis into seven interlocking themes — what he calls the Magnificent Seven — and the conversation walks through each one with quantitative detail and practical implications for credit union leadership.

In this episode:

•        The system is strong but the tone of the report is cautious — and why that is the right posture

•        Consolidation math: credit union count down roughly 3.7% year over year, with losses concentrated on the small end of the barbell

•        Average age of a credit union member (53) versus the average U.S. resident (38.5), and what the widening gap implies

•        Member acquisition cost approaching $900, roughly double the level of two to three years ago

•        The median credit union has posted negative member growth for six consecutive quarters

•        Why return on assets and net worth are stronger than they look — and the one-time factors propping them up

•        Regulatory philosophy pendulum: elimination of reputational risk, rejection of regulation by enforcement, extended exam cycles, and ten-plus deregulation announcements

•        Innovation is now central to the agenda: stablecoin rulemaking, NCUA's historical pattern of being ahead on derivatives and non-member shares

•        FinTech competitive picture: SoFi, Robinhood, Wealthfront, and Coinbase deposits and growth rates against the credit union industry

•        The bigness question: 73% of credit unions hold 13% of assets; the top 21 credit unions hold 25%

•        How NCUA itself is changing — roughly 25% of staff exited through the departure plan, single-member board, and what that means for industry timing

•        The announcement that Olden Lane is joining Stifel Nicolaus

Mike's analysis at Olden Lane is built on quarterly tier-by-tier data on the credit union industry. This conversation is a concentrated version of the themes his team tracks and the practical conclusions they draw from them.

https://www.linkedin.com/in/mark-treichel/

Mark is joined by Rob Johnson, president and a principal owner of c. myers, for a wide-ranging conversation on strategic planning, capital strength, and the habits separating the strongest credit unions from the rest right now.

The discussion covers:

•       Why a one-year budget is already wrong by January, and why multi-year scenario planning has become table stakes.

•       What Jamie Dimon actually means by "fortress balance sheet" — and how credit union boards often misread the concept.

•       An adventure motorcycle analogy on looking five seconds ahead and one second down, and what it means for executive attention.

•       Net Economic Value (NEV) improvements across the industry over the last two years, and why earnings risk deserves equal billing.

•       The trap of FinTech contracts that only work at small scale.

•       Why treating scenario analysis as a regulatory exercise leaves real decision information on the table.

•       Redwood Credit Union as a case study in product design, crossing $10 billion, and building engaged membership through benefits checking.

•       Growth through rate versus growth through experience — and why framing it that way misses the point.

•       The Super Bowl analogy on execution and why no team wins with a material weakness.

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel breaks down NCUA’s latest proposed rule — one that would eliminate the long-standing loan participation regulation that has been in place since 2006. This is part of NCUA’s broader deregulatory push, driven in part by an executive order mandating a ten-to-one ratio of rule eliminations to new rulemaking.

Mark walks through what the original 2006 rule established: a 50% of net worth cap for the first 30 months of a loan participation program and a 100% cap after that, with a waiver process for institutions that wanted to exceed those thresholds. The rule applied to both federal credit unions and federally insured state charters.

The proposed change would remove those bright line caps entirely and replace them with a principles-based approach — one where the credit union’s board sets its own policies, calibrated to the institution’s size, complexity, and risk profile.

Mark then explains why this change is less dramatic than it might sound. NCUA’s concentration risk guidance letter — which already requires board-approved limits, documented risk frameworks, stress testing, servicer performance tracking, and regular board reporting — remains active. General safety and soundness authority also remains, and NCUA examiners still have tools to require reduced exposure, improved policies, or even a pause in lending until programs meet expectations.

That said, Mark identifies where the risks are real: smaller credit unions without sophisticated concentration risk frameworks, less experienced examiner staff following NCUA’s recent workforce reductions, and regional variability in how principles-based supervision gets applied.

The episode closes with four practical steps for credit unions to take now:

•        Review your board policy — if it references the old 50% or 100% net worth limits, it will need to be updated when the rule is finalized.

•        Run a concentration risk letter checklist against your current policies.

•        Document your rationale for concentration risk limits and build it into strategic planning.

•        Submit a comment letter by May 26th if you have a view on the proposal.

Topics covered:

•        What the 2006 loan participation rule established and why it was created

•        What NCUA is now proposing and why

•        Why the concentration risk guidance letter is the more important tool

•        How NCUA’s safety and soundness authority works as a backstop

•        The sophistication gap facing smaller credit unions

•        NCUA staffing reductions and their impact on exam consistency

•        What credit unions should do before the rule is finalized

Steve spent 15 years as a Problem Case Officer on the West Coast before moving to NCUA's Division of Risk Management in the central office, where he worked on enforcement, corporate resolution, and risk-based capital. Todd spent 34 years with NCUA, including a decade as an examiner and PCO, followed by 11 years as Director of Special Actions in the Western Region.

Together, they cover: what NCUA is actually doing when they code you a 4 (hint: building an administrative record), how often you'll see your examiner (more than you think), why the Federal Reserve, FHLB, and Fannie Mae all find out about your status, what Section 701.14 means for management and board changes, why assignment to Special Actions isn't always bad news, and what separates credit unions that recover from those that don't.

If you're a Code 4 — or worried you might become one — this episode gives you the insider perspective on what's coming and how to navigate it.

https://www.linkedin.com/in/mark-treichel/

In this episode, Mark Treichel responds directly to a podcast released by the American Bankers Association (ABA) titled “Are Credit Union Commercial Loans Risky Business?” — a 12-minute episode that contains significant factual errors, conflates distinct regulatory mechanisms, and presents advocacy as analysis.

Mark draws on 33 years at NCUA — including eight years as Executive Director — and nearly six years in consulting to walk through eight specific claims from the ABA podcast, providing historical context, regulatory detail, and current data from NCUA call reports to address each one.

Topics Covered

Historical Background

The ABA’s 35-year campaign against credit union expansion — from the 1990 field-of-membership lawsuit argued for the ABA by then-attorney John Roberts, through the Supreme Court victory, through the congressional response with HR 1151, the Credit Union Membership Access Act of 1998, and the origin of the 12.25% MBL cap as a political compromise rather than a safety-and-soundness limit. How that cap ended up jumpstarting the credit union business lending industry — the law of unintended consequences.

Claim 1 — The 2016 Rule Change Was a Relaxation

Mark untangles two separate errors: the invented waiver mechanism for exceeding the MBL cap (which does not exist — the cap is statutory and cannot be waived by NCUA) and the conflation of the loan-level underwriting waiver process (what actually changed in 2016) with the cap itself. Over 1,000 active waivers were on file before the change; NCUA replaced prescriptive checkboxes with a principles-based framework consistent with OCC and FDIC practice.

Claim 2 — The MBL Cap Is Notional
Every exemption the ABA criticizes — low-income designation, bank acquisitions — was created by Congress, not by credit unions circumventing the system. Using a congressionally authorized exemption is compliance, not circumvention.

Claim 3 — The Low-Income Designation Explosion
The total number of federally insured credit unions fell from 5,048 in 2021 to 4,374 by year-end 2025, a decline of more than 13% in four years. A shrinking denominator drives percentage increases independent of raw count changes. NCUA outreach encouraged eligible institutions to apply for a designation they were already entitled to.

Claim 4 — NCUA Lacks Commercial Lending Expertise

NCUA has had member business lending regulations since the 1980s, updated comprehensively in 2003 and modernized again in 2016. The agency maintains specialized commercial lending examination staff, concentration risk guidance, and net worth standards that apply to commercial lending activity.

Claim 5 — Bank Acquisition Commercial Loan Comparison

When a credit union acquires a commercial bank, it acquires that bank’s loan portfolio. The finding that post-acquisition credit unions carry more commercial loans is a mathematical inevitability, not evidence of a supervisory problem.

Claim 6 — These Loans Haven’t Been Through Stress

Bank commercial real estate delinquencies peaked at 9% in 2009 and 2010 under OCC, FDIC, and Federal Reserve supervision. Current credit union commercial loan delinquency as of year-end 2025 is approximately 1% — or 0.44% using the 60-plus-day definition. Former NCUA Chairman Todd Harper has observed that well-underwritten member business loans have the ability to perform differently across economic cycles than auto or mortgage loans — diversification into business lending, done right, is a protection for the system.

Claim 7 — Small Business Satisfaction Data

The Federal Reserve Small Business Credit Survey measures satisfaction among approved applicants at institutions borrowers chose to apply to — a population filtered by membership eligibility requirements. It is not a direct comparison between institution types. Credit unions consistently score among the highest of any financial institution type in the American Customer Satisfaction Index across the full membership.

Claim 8 — The Tax Exemption and Level Playing Field

The credit union tax exemption reflects the cooperative structure: member-owned, with earnings returning to members through lower loan rates, higher deposit returns, and reduced fees. Congress has reviewed this treatment many times and has chosen to maintain it.

Takeaways for Credit Union Executives
Know the history and be prepared to counter these arguments with facts. Run a well-managed institution with strong underwriting standards and appropriate capital. Engage proactively with your exam process. Know your data. Be skeptical of statistics presented without context.

Resources Referenced

•        Credit Union Conversations podcast with Mark Ritter (episode featuring former NCUA Chairman Todd Harper and Mike Radway on HR 1151 history)

•        NCUA call report data, year-end 2025

•        Federal Register — 2016 NCUA Member Business Lending rule

•        America’s Credit Unions Governmental Affairs Conference (GAC)

https://www.linkedin.com/in/mark-treichel/

In this episode, Mark Treichel walks through the full-year 2025 CAMEL code data across all four quarters, providing a comprehensive analysis of where the industry stands and what the numbers mean for credit unions at every asset tier.

The episode opens with context: in September 2024, then-National Credit Union Administration Chairman Todd Harper sounded a public alarm after the number of complex credit unions — those over $500 million in assets — coded at CAMEL four or five tripled in a single quarter. That alarm set the benchmark for evaluating 2025's results.

Mark frames the analysis around three perspectives: the glass half full (optimistic), the glass half empty (skeptical), and the base case (pragmatic). He works through the data at an industry level before breaking it down by asset tier, where a more complicated picture emerges.

Key findings include: the overall improvement in code four and five counts; a significant reduction in dollar exposure in troubled institutions; the resolution of Harper's specific alarm as the complex credit union count returned to seven at year-end; and the Q2 2025 anomaly, where the code three count fell but assets in that bucket jumped by $25 billion — illustrating how quickly the composition of a tier can shift even when the headline count moves in the right direction.

A critical section covers the mid-size tier — $100 million to $500 million in assets — where 2025 produced almost no improvement. Code fours and fives in that range actually ticked upward. Mark explains the particular pressures mid-size institutions face and why the headline numbers can obscure their reality.

The episode also addresses the National Credit Union Administration's staffing situation in depth: a 27% reduction in force, a shift in exam cycle requirements from mandates to goals, and the quiet update to the National Supervision Policy Manual extending exam cycles for larger institutions. Mark raises a pointed question: do the CAMEL code improvements reflect genuine rehabilitation, or do they partly reflect an agency adjusting to resource constraints?

The episode closes with practical guidance for what to do based on your CAMEL code, and a look ahead to 2026 — including the hiring freeze, rising delinquency trends, and potential leadership changes at the agency.

Topics Covered:

•        The Harper Alarm: context from September 2024 and how 2025 resolved it

•        Full-year CAMEL code trends across all five quarter-ends

•        Asset tier breakdown: $500M+, $100M–$500M, and under $100M

•        The Q2 2025 anomaly: count down, dollar exposure up

•        National Credit Union Administration staffing: 27% reduction, exam cycle changes, and the truth-in-coding question

•        Glass half full: genuine improvements and the resolution of the Harper alarm

•        Glass half empty: uneven distribution, merger effects, and delinquency trends

•        The base case: what every credit union should do based on its CAMEL code

•        What to watch in 2026

https://www.linkedin.com/in/mark-treichel/

In this solo episode of With Flying Colors, host Mark Treichel presents a comprehensive data analysis of credit union mergers using thirty quarters of NCUA quarterly merger reports, covering activity from the third quarter of 2018 through 2025. The dataset includes 1,901 credit unions involved in merger activity, 1,298 completed mergers, and over $111 billion in merged assets.

Mark walks through the consolidation math: credit union mergers typically run between 130 and 180 per year, representing three to four percent of all charters annually. The most notable trend in the data is the dramatic increase in the average size of merging credit unions—from $36 million in average assets in 2018 to $285 million in 2025, roughly an eight-fold increase. Total merged assets in 2025 reached $45 billion, the highest annual figure in the dataset.

The episode examines the 80/20 split between voluntary and involuntary mergers, clarifying what the "involuntary" designation actually means in NCUA's reporting—and why it is frequently misunderstood. Mark also profiles the characteristics of serial acquirers, including one credit union that completed 24 mergers in four years, and discusses the different strategic approaches active acquirers take.

The pre-merger financial profile section compares median data from merging credit unions against the broader population, with return on assets, membership growth, loan-to-share ratios, net worth, and delinquency all examined. Mark identifies the two metrics he considers most predictive: earnings and membership growth.

The episode closes with a look at charter conversion trends—specifically the significant swing back toward federal charters since 2021—and a projection of where the industry is headed over the next 25 years under different consolidation rate scenarios.

Topics covered include:

•        Annual merger volumes and the peak year of 2019 (254 mergers)

•        The dramatic rise in average merger size: $36M (2018) to $285M (2025)

•        What "voluntary" and "involuntary" really mean in NCUA merger data

•        The 265 involuntary mergers: financial condition, official challenges, management, and sponsor loss

•        Serial acquirers and scale players: different strategies, same data source

•        Pre-merger profile: median $11M in assets, negative ROA, membership declining at -91bps

•        Acquirer profile: median $2.5B in assets, 82bps ROA, 139,000 members

•        Charter conversion trends: $41B moved back to the federal charter since 2021

•        Industry projections: 1,555 to 2,015 charters by 2050 under current consolidation rates

•        Strategic implications: board governance, membership growth, earnings discipline

https://www.linkedin.com/in/mark-treichel/

In this episode, Mark Treichel is joined by Steve Farrar, Todd Miller, and Dennis Bauer for their quarterly review of the National Credit Union Administration call report data. The group walks through the Q4 2025 numbers across each component of the CAMEL framework, discussing what the data is showing, where the risks are building, and what credit union leaders should be paying attention to heading into 2026.

TOPICS COVERED

Capital

The industry net worth ratio stands at approximately 11.28%, down slightly from 11.35% at the end of Q3 2025 but up from 11.2% at year-end 2024. Only 59 credit unions are below the 7% well-capitalized threshold. GAAP net worth has improved nearly 200 basis points over the past two years as unrealized investment losses continue to recover. Community bank core capital ratios are comparable at approximately 11.05%.

Asset Quality – Investments

Credit unions have been extending investment maturities in a flat yield curve environment, with dollars growing in the three-year, five-year, and ten-year buckets. The spread between a three-year and ten-year investment is only about 14 basis points. Combined with growth in mortgage and commercial loans, balance sheet duration is extending on multiple fronts simultaneously.

Asset Quality – Loans

Industry delinquency crossed 1% for the first time in a decade. Non-owner occupied residential real estate delinquency jumped from approximately 62 basis points to 141 basis points. Commercial real estate, construction and development, and student loan categories also showed meaningful increases. Auto loan balances actually declined in 2025 — a rare occurrence. Allowance coverage of delinquency declined from 140% at Q3 to 131% at year-end. Community bank charge-off rates were 0.21%, compared to 0.78% for credit unions. The group discusses the regional nature of credit stress and how national averages can mask concentrated problems in specific geographies.

Earnings

Return on assets improved approximately 16 basis points year-over-year, driven by a 27-basis-point improvement in net interest margin. Net interest margin appears to have peaked — up only one basis point from Q3 to Q4. The efficiency ratio improved to approximately 69-70%. Operating expenses have grown at 7% or more for at least three consecutive years, with salary and benefits (nearly half of all operating expenses) up roughly 8% annually in 2024 and 2025. About 11.7% of credit unions were unprofitable in 2025, compared to approximately 5% of community banks. Seventeen credit unions over $1 billion reported losses.

Liquidity and Membership

Deposit growth ran at approximately 5%, while membership growth fell to just 2% — the lowest level in roughly a decade. Certificate of deposit growth is decelerating as rates fall, with money market and share draft accounts growing faster. Approximately 80% of CDs are expected to reprice in 2026. Wholesale funding was repaid, improving borrowing capacity.

NCUA and the Broader Environment

The group discusses National Credit Union Administration staffing reductions and what that means for examination priorities. With limited resources, the focus will necessarily concentrate on asset quality and concentration risk. Mark raises the pending change to the CAMEL 1 designation and calls for the agency to communicate that change publicly to stakeholders. CAMEL rating distribution improved modestly, with a $155 billion reduction in assets held in CAMEL 3-rated institutions.

GUESTS

Steve Farrar – Former National Credit Union Administration examiner, problem case officer, and VP of the Central Liquidity Facility; now with Credit Union Exam Solutions

Todd Miller – Former Director of Special Actions, National Credit Union Administration Western Region; now with Credit Union Exam Solutions

Dennis Bauer – Former CFO and EVP of Ideal Credit Union (St. Paul, MN); former National Credit Union Administration examiner; now with Credit Union Exam Solutions

Todd, who spent over 33 years at NCUA including a decade as Director of Special Actions, draws on his experience examining credit unions across the full performance spectrum. He shares what he consistently saw in top-performing organizations: strong written policies that created transparency at every level, from the boardroom to the branch.

The conversation covers why policies matter beyond regulatory compliance, including their role as training tools, culture builders, and accountability mechanisms. Todd outlines the general principles that underpin effective policy management — from top-down implementation and accessibility to the importance of consequences for non-compliance and the disciplined handling of policy exceptions.

The heart of the episode is Todd's breakdown of common elements that should appear in every credit union policy, regardless of subject matter: purpose and objectives, accountability structures, risk appetite statements with real limits, systems of trend-based reporting, and scheduled review processes. He explains why policy limits should be unique to each credit union, why guidelines are no substitute for hard limits, and why trend reporting matters more to board members than point-in-time snapshots.

Mark and Todd also discuss the connection between policy compliance and organizational culture, including how violations of individual authority limits can erode morale, create bond claim exposure, and — in the most serious cases — lead to insurance fund losses.

https://www.linkedin.com/in/mark-treichel/

Episode Summary

Mark Treichel sits down with Jason Stverak, Chief Advocacy Officer at the Defense Credit Union Council (DCUC), for a wide-ranging conversation on the policy threats credit unions are currently facing. From the government shutdown's impact on Coast Guard members to the proposed 10% interest rate cap, interchange regulation spreading into the states, and the banking lobby's opposition to credit union bank acquisitions — Stverak covers the full landscape of what's moving in Washington and why credit union leaders need to be paying attention.

What We Cover

The partial government shutdown and its direct impact on Coast Guard members working without pay — and how credit unions are stepping in with forbearances and emergency lending.

The ICBA's renewed push against credit union bank acquisitions, and why Stverak argues the real driver is dues protection rather than principled policy.

The proposed 10% interest rate cap: why credit unions and banks have issued joint opposition, and what a cap at that level means for members with lower credit scores.

How interchange regulation is moving from Congress into state legislatures — and why Illinois is just the beginning.

DCUC's growth (30% membership increase in the past year), its due structure, and what it means for non-defense credit unions to engage with a defense-focused trade organization.

The concept of operating "over the event horizon" — anticipating threats before they become crises.

Upcoming DCUC events including Defense Matters at GAC, CU Unplugged in San Francisco, regional sub-council meetings, the annual meeting in Miami, and an overseas meeting in Bangkok.

Connect with Jason Stverak and DCUC

Website: dcuc.org

Email: jstverak@dcuc.org

In this episode, Mark and John discuss:

•        Why silence during a crisis creates a dangerous vacuum—and how to avoid it

•        The principle of being “first with the truth” and why speed matters

•        How to identify and prioritize your key stakeholders during an incident

•        The value of tabletop exercises and crisis communication plans

•        Real examples from the 2008 financial crisis and recent cyber incidents

•        Why your members need to hear that their insured funds are safe—early and often

•        Setting up a landing page as a single source of truth during a crisis

•        The importance of conducting a postmortem after any incident

•        How a crisis can actually strengthen the bond between a credit union and its members

Whether your credit union has a crisis communication plan on the shelf or is starting from scratch, this episode offers practical guidance on how to prepare—and how to perform when it matters most.

Connect with John McKechnie:

Email: john@mckechniellc.com

Phone: 202-997-5816

https://www.linkedin.com/in/mark-treichel/

Episode Title: My Takeaways from Monday at GAC: Structure, Supervision, and Stablecoins

In this episode, I share my takeaways from Monday at GAC in Washington, D.C.

This was my first GAC in 2000 as Deputy Executive Director at NCUA. I’ve attended more than 20 since. It was good to be back in D.C., reconnect with colleagues, clients, and former NCUA staff — and to see how the tone of the conference felt this year.

Three sessions stood out:

1️⃣ Scott Simpson – Stewardship & Advocacy

Scott Simpson’s first GAC as head of America’s Credit Unions set a different tone.

He emphasized:

• Credit unions as a social movement
• The importance of advocacy
• The reality that tax status and field of membership are not automatic
• Unity between large and small institutions

In a chaotic political and regulatory environment, the reminder that credit unions exist because Congress allows them to exist matters.

2️⃣ Brené Brown – Strengthening the Foundation

Brené Brown’s keynote focused on “strong ground.”

Her theme: leaders often compensate around weaknesses instead of strengthening the foundation.

Key ideas:

• Vulnerability = uncertainty, risk, and exposure
• No risk, no courage
• Armor (resistance, avoidance, overconfidence) blocks real leadership
• In times of uncertainty, strengthen the core

In an environment shaped by technology shifts, mergers, geopolitical tension, and regulatory changes, that message resonated.

3️⃣ Chairman Hauptman – Supervision & Stablecoins

Chairman Hauptman’s fireside chat focused on rethinking supervision and discussing stablecoins.

Supervision

With NCUA staffing down significantly (I reference roughly 27%), he raised the question:

Is the juice worth the squeeze?

Topics discussed:

• Consistency and transparency in exams
• Fewer document requests
• Rethinking supervisory touchpoints
• Reorganization within NCUA
• Extending exam cycles for well-run institutions

I also discuss how regulatory inconsistency — when priorities swing dramatically — can create real operational risk for credit unions.

Sometimes NCUA can be a credit union’s biggest risk — not due to bad intent, but because uncertainty affects strategic decisions.

Consolidation

Consolidation is happening. That’s math.

But it’s not inevitable individually.

Every mature industry consolidates over time. The key is leadership, strategy, and execution.

Stablecoins

Chairman Hauptman framed stablecoins as infrastructure and global dollar dominance.

The key question I raise (credit to Kiah Haslett’s framing):

What problem does stablecoin actually solve that existing rails don’t?

We already have:

• Fedwire
• ACH
• RTP
• FedNow

Is the value international? Domestic? Structural? Or hype?

Time will tell.

Final Thought

Across all three speakers, one theme connected the day:

Are we strengthening the foundation — or compensating around it?

It was a fun and informative day at GAC, and I’ll continue sharing observations as the week unfolds.

If you were there and saw something differently, let me know.

Key Topics Covered

What triggers an LUA: Understanding when NCUA escalates from informal actions to formal enforcement, and why most credit unions receiving LUAs are classified as troubled.

Published vs. unpublished: The distinction that creates reputation risk, how industry publications find published LUAs, and which state regulators require publication.

Board accountability: Why voting no or abstaining doesn't protect individual directors, and what fiduciary responsibility means when your credit union signs an LUA.

Negotiation before signing: How to approach discussions with your examiner or problem case officer, ensuring timeframes are realistic and commitments are achievable.

Root causes vs. comprehensive lists: Why LUAs should focus on fundamental problems, and what to do when you're facing a lengthy document with dozens of items.

Satisfying an LUA: The two-part test NCUA applies—completing actions AND achieving intended results—and why there's no built-in expiration date.

Notable Quotes

"The LUAs only addressed mainly what we would refer to as the root causes of the problem." — Steve Farrar

"The language in published LUAs is very draconian and very one-sided. It's intended to be serious." — Todd Miller

"If you abstain or vote no, and the board agrees to sign, you're still subject to that agreement. It was a board decision." — Mark Treichel

About the Guests

Steve Farrar spent 30+ years at NCUA, including 15 years as a problem case officer and 15 years in the central office where he authored NCUA's enforcement manual and worked on corporate resolution and risk-based capital regulations.

Todd Miller served nearly 35 years at NCUA as an examiner, problem case officer, regional capital market specialist, and Director of Special Actions supervising problem case officers and capital market specialists.

Resources

Credit Union Exam Solutions: marktreichel.com

Related Episode: Documents of Resolution and Examiner Findings

Content Warning: This episode discusses suicide. If you or someone you know is struggling, please call or text 988 (Suicide & Crisis Lifeline).

Episode Description: The death of 25-year-old Vikings wide receiver Rondale Moore this weekend brought back memories Mark has never shared publicly. In 33 years at NCUA — including 8 years as Executive Director — Mark encountered two individuals who took their own lives after embezzling from their credit unions. In this solo episode with no intro music, Mark tells those stories for the first time and delivers three messages to anyone in the credit union industry who may be carrying a secret they think will destroy their life.

In This Episode:

• How the Rondale Moore story and Hollywood Brown's tweet triggered this episode
• Mark's first encounter with suicide at age 19
• A Midwest credit union CEO whose "hunting accident" wasn't accidental
• The connection between Dead Poets Society and an examination Mark will never forget
• An East Coast treasurer who jumped from a high-rise rather than face conservatorship
• Three core messages: it's never as bad as you think, there's always a way back, and you will get caught
• What credit union leaders can do to pay attention to the people, not just the numbers

Resources:

• 988 Suicide & Crisis Lifeline — call or text 988
• American Foundation for Suicide Prevention — afsp.org

Hat tip: Matthew Coller and The Purple Insider podcast for the Rondale Moore episode that pushed Mark to finally record this.

https://www.linkedin.com/in/mark-treichel/

Episode Description: When your credit union receives an examination result you believe is wrong, what are your options? In this episode, Mark Treichel walks through NCUA's formal appeal process from start to finish — the timeline, the levels of review, what you can actually appeal, and how to think about whether it makes sense for your institution. Drawing on his experience as a former NCUA regional director and his work advising credit unions through the process, Mark breaks down the practical realities most credit union leaders don't fully understand until they're in the middle of it.

Key Topics Covered:

• Why resolving issues at the examiner level is always the best first step — and why it doesn't always work
• The fear of retaliation and when it's worth pushing back anyway
• What qualifies as a "material supervisory determination" under Part 746
• The critical phrase most credit unions overlook: "includes, but is not limited to"
• Why you can't formally appeal CAMEL components — but effectively can anyway
• Document resolutions are negotiable: pushing back on language, dates, and requirements
• The full appeal timeline: regional director, Supervisory Review Committee, and NCUA Board
• When oral hearings are available and when they're guaranteed
• Why "tie goes to the runner" at every level — and what that means for your burden of proof
• Defining victory: full reversals, partial wins, and the value of being heard
• Building your administrative record for the long term

Key Takeaways:

1. You have 30 days from the final exam to appeal to the regional director — and some argue the clock starts when you see the draft.
2. A full appeal through the NCUA Board can take eight months to a year.
3. The Supervisory Review Committee must grant an oral hearing if you request one — the only level where that's guaranteed.
4. Your odds of success generally improve as you move higher in the process.
5. Even if you don't win the appeal, you're building an administrative record NCUA must consider in any future enforcement actions.

Resources:

• NCUA Part 746, Subpart A (Appeals Regulation)
• Preamble to the final rule on appeals process
• Credit Union Exam Solutions: marktreichel.com

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The NCUA has issued a proposed rule implementing the GENIUS Act, establishing a federal licensing framework for payment stablecoin issuers.

For the first time, credit union subsidiaries could apply to become Permitted Payment Stablecoin Issuers (PPSIs) — but only under strict supervisory standards.

In this episode, Mark breaks down:

• Why credit unions cannot issue stablecoins directly
• How the subsidiary licensing model works
• The 10% “Parent Company” threshold and joint application structure
• The 1% CUSO investment cap and its impact on participation
• The 120-day statutory decision clock
• How this compares to FDIC, OCC, and Federal Reserve proposals
• Why “rewards vs. interest” could become the next regulatory battleground
• How the proposed CLARITY Act fits into the broader digital asset framework

This proposal represents one of the most significant expansions of NCUA supervisory authority in decades. While stablecoin issuance is optional, the regulatory guardrails are now taking shape.

Comments on the proposed rule are due 60 days after Federal Register publication.

If your credit union is considering digital asset innovation, payment modernization, or cooperative technology ventures, this episode outlines the strategic considerations.

Key Topics

• GENIUS Act stablecoin framework
• Subsidiary-only issuance requirement
• PPSI licensing process
• Capital and liquidity expectations
• CUSO structure implications
• Joint ownership models
• Regulatory cost recovery debate
• CLARITY Act market structure considerations

Why This Matters

Stablecoins are not insured shares.
 They are not backed by the full faith and credit of the United States.
 They cannot blur the line between payments and deposits.

Understanding these distinctions will be critical as the industry evaluates next steps.

If you found this episode helpful, share it with a colleague and subscribe to With Flying Colors for ongoing insights into NCUA policy, supervision trends, and regulatory strategy.

While regulators often emphasize capital levels, history shows that capital alone cannot offset poor risk governance. This conversation explores why concentration risk continues to challenge institutions — even those that appear well capitalized.

Drawing on decades of regulatory experience, the team walks through the core components of a modern risk management framework and discusses how boards should think about oversight in today’s environment.

What We Cover

🔹 Risk Culture Starts at the Top

• Why tone from the board and CEO matters more than policies
• How troubled institutions often trace back to cultural breakdowns
• The board’s role in defining acceptable risk

🔹 Risk Appetite: Limit or Goal?

• What a risk appetite statement actually means
• Why limits must be measurable and monitored
• The difference between qualitative intent and quantitative control

🔹 Concentration Risk in the Real World

• The taxi medallion example and what it taught the industry
• Why 15%+ capital ratios were not enough
• How concentration risk interacts with capital and stress scenarios

🔹 The Three Lines of Defense

• Frontline business units
• Risk management oversight (including the Chief Risk Officer role)
• Internal audit and supervisory committee functions

🔹 Examiner Expectations Today

• Stress testing and concentration limits
• Supporting board-approved limits with data
• What happens when limits are breached
• Why documentation and reporting matter

Key Takeaways

• Capital can absorb losses — but it cannot fix poor diversification.
• Risk appetite should reflect capital strength, strategic goals, and institutional complexity.
• Concentration limits are not aspirational targets — they are guardrails.
• Effective risk management requires culture, measurement, and accountability.

Why This Still Matters

Regulatory guidance continues to evolve, but the core principles of risk governance remain unchanged. Whether you lead a $300 million credit union or a multi-billion-dollar institution, understanding how risk culture, appetite, and oversight interact is essential.

This archive episode remains highly relevant as examiners increasingly scrutinize concentration risk and enterprise risk management practices.

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel is joined by former NCUA leaders Geoff Bacino, Alonzo Swann, and John McKechnie for a timely and candid discussion about Chairman Kyle Hauptman’s appointment to the Public Company Accounting Oversight Board (PCAOB) — and what it signals for the future of the NCUA.

While the announcement appears straightforward, the panel explains why it creates a ripple effect across the agency, including questions about leadership continuity, pending lawsuits, board vacancies, staff reductions, and the broader stability of the regulator at a critical time for credit unions.

This conversation goes beyond speculation and into how the agency actually functions when leadership is in flux — from delegation of authority to examiner operations to internal morale.

You’ll hear insider perspective on:

• Why Hauptman’s “intent to remain” language matters
• How the Slaughter/Harper lawsuits could determine the shape of the future board
• What a one-member board means in practice
• Why notation votes and lack of public discussion are becoming a concern
• The real impact of a 27% staff reduction at NCUA
• How agency expertise gaps are affecting morale and operations
• The upcoming interest rate ceiling decision and why it may be politically sensitive
• Why the agency may be “running itself” more than people realize
• What happens if the Supreme Court changes how independent boards operate
• Predictions on who may replace Hauptman and what that means for credit unions

The panel also discusses how political dynamics, Senate control, and White House strategy could shape the next NCUA board in ways credit unions haven’t seen before.

Despite the uncertainty, one theme is clear: the blocking and tackling of supervision continues, but major structural decisions are happening quietly beneath the surface.

This episode is essential listening for anyone trying to understand where NCUA is headed in 2026.

👥 Guests

• Geoff Bacino – Former NCUA Board Member
• Alonzo Swann – Former NCUA Regional Director
• John McKechnie – Washington, DC credit union advocate and consultant

https://www.linkedin.com/in/mark-treichel/

Chairman Hauptman’s Statement on Appointment to PCAOB

ALEXANDRIA, VA (January 30, 2026) – National Credit Union Administration Chairman Kyle S. Hauptman issued the following statement after being named as a member of the Public Company Accounting Oversight Board (PCAOB).

“I am grateful to President Donald J. Trump and Chairman Paul S. Atkins for their faith in me and for the appointment to the PCAOB,” said Chairman Hauptman. “I intend to remain in my role as NCUA Chairman until my successor is appointed by President Trump and confirmed by the U.S. Senate.”

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel is joined by former NCUA senior leaders Todd Miller and Steve Farrar for a deep dive into NCUA’s 2026 Supervisory Priorities Letter — and what it means in the real world for credit unions heading into the next exam cycle. 
Deep Dive on NCUA Priority Lett…

With significant staffing reductions at the agency and a shift toward more “risk-based” supervision, the group discusses whether exam programs will truly become more tailored — or whether credit unions should expect more conservative ratings, more findings, and less dialogue.

The conversation also explores what’s emphasized, what’s missing, and how operational realities inside NCUA may shape supervision more than policy statements.

Key Topics Discussed

🏛️ NCUA Operations and Staffing

• How a 27% reduction in staff could affect exam consistency and depth
• Why less-experienced exam teams may lead to more conservative CAMEL ratings
• Concerns about “CYA supervision” and addressing symptoms rather than root causes

📊 Balance Sheet Management and Credit Risk

• Why industry data does not support claims of worsening asset quality
• Continued focus on credit concentrations and underwriting practices
• What outsourcing of lending and collections may trigger in exams

💧 Liquidity and Interest Rate Risk

• Why interest rate risk is often overstated as a failure driver
• Ongoing scrutiny of liquidity forecasting models
• Growing competition for deposits from fintechs and non-banks

💵 Earnings, Capital, and Rising Expenses

• Why operating expenses are growing faster at credit unions than banks
• Technology investments, staffing costs, and post-COVID catch-up spending
• Capital planning expectations despite fewer references in the priority letter

⚙️ Operational Risk, Payments, and Technology

• Increasing complexity of payment platforms and third-party integrations
• Why internal audit functions matter more than ever
• Risks created by rapid fintech adoption

🕵️ Fraud Prevention and Member Protection

• AI-driven fraud and voice spoofing risks
• Why protecting members is now as critical as protecting institutions
• Reputation risk from scams and social media amplification

📋 Compliance and What’s Missing

• Notable reduction in consumer compliance emphasis
• BSA remains a regulatory constant
• What the absence of certain topics may signal about regulatory priorities

🎙️ Practical Exam Strategy

• Why recording exit conferences can protect credit unions
• How appeals and documentation can matter more in constrained environments

Why This Episode Matters

NCUA’s priority letters set expectations — but exam outcomes are often shaped by staffing, experience, and regional risk perceptions. As the agency continues to restructure, understanding how policy meets practice has never been more important.

This episode offers insider perspective on:

• How exam approaches may shift in 2026
• Where credit unions should expect closer scrutiny
• Why communication and documentation will matter more than ever

The proposal would allow federal credit unions to reimburse or directly pay reasonable dependent care costs for volunteer officials when those costs are incurred while attending board meetings or performing official duties — including, potentially, training and conferences.

This is a narrow but important change that reflects rising childcare and eldercare costs, declining volunteerism, and the increasing demands placed on credit union boards.

Mark also shares brief updates on the Central Liquidity Facility (CLF), NCUA’s regulatory simplification efforts, and what’s coming next on the podcast following recent discussions at a credit union conference cruise.

🔍 What the Proposed Rule Would Do

• Applies to federal credit unions only (state charters follow state law)
• Allows reimbursement or direct payment of:
  • Childcare
  • Adult dependent care (elder care, disabled dependents)
• Covers costs incurred while:
  • Attending board meetings
  • Performing official duties (which may include training and conferences)
• Applies only to volunteer officials, not paid executives

🚫 What the Rule Does Not Do

• Does not allow reimbursement for:
  • Lost wages
  • Paid leave
  • Indirect costs of volunteering
• Does not change compensation rules under the Federal Credit Union Act
• Does not require credit unions to reimburse these costs — policies remain optional and discretionary
• Does not change IRS tax treatment — consult tax professionals for reporting requirements

💡 Why This Matters

• Childcare costs have increased more than 200% since 1990
• Volunteer participation has declined significantly since pre-pandemic levels
• Federal credit union boards:
  • Must meet at least 12 times per year
  • Cannot generally be compensated
• This proposal may help:
  • Attract younger and working-age professionals
  • Support caregivers and single parents
  • Improve diversity of experience and perspective on boards

🧭 What NCUA Is Asking for Public Comment On

NCUA is inviting industry feedback on:

• Whether reimbursement should be limited to temporary or incremental costs
• Whether training and conference travel should clearly qualify as official duties
• Documentation and internal control standards
• Best practices from state-chartered credit unions

Credit unions and board members are encouraged to submit comments during the open comment period.

🔜 What’s Coming Next on the Podcast

• A follow-up episode with Mark’s team discussing:
  • NCUA’s 2025 Supervisory Priorities Letter
  • What it really means for exams and operations
• Coverage of NCUA’s upcoming webinar on supervisory priorities (February 19)
• Continued “emergency update” episodes when time-sensitive issues break

https://www.linkedin.com/in/mark-treichel/

In this special preview episode of With Flying Colors, Mark Treichel tees up an upcoming live, on-stage discussion from the Florida Q’s Cruise with team members Steve Farr and Todd Miller.

Just days before the cruise, NCUA released its 2026 Supervisory Priorities Letter, and as always, that letter gives us important clues about what examiners will be focused on in the year ahead — and just as importantly, what’s driving examiner behavior behind the scenes.

This episode serves as a primer for the deeper, post-cruise discussion, where we’ll incorporate real-time feedback and questions from credit union leaders attending the cruise.

🧭 Big Picture Theme: NCUA in Chaos

Before diving into technical priorities, Mark frames the conversation around what many credit unions are experiencing operationally:

• Leadership instability and fewer board actions
• Retirements, buyouts, and staffing losses
• Revolving and often less-experienced examiners
• Exams prioritized over approvals and strategic requests

Bottom line:

📌 What’s in the 2026 Supervisory Priorities Letter?

Mark walks through the major categories NCUA highlighted and why they matter:

🟦 Lending / Credit Risk

• Delinquencies and charge-offs at decade highs
• Focus on underwriting, concentrations, and workouts
• Continued scrutiny of commercial real estate and indirect lending

🟦 Liquidity & Interest Rate Risk

• Stress testing assumptions under closer review
• Structural liquidity constraints getting more attention
• Alignment between balance sheet strategy and risk appetite

🟦 Earnings & Capital Adequacy

• Sustainability of earnings under stress scenarios
• Capital planning tied directly to risk profiles
• More forward-looking analysis expected in exams

🟦 Payment Systems (Back as a Headline Topic)

• Real-time payments and complex integrations
• Vendor risk, data exposure, and cyber vulnerabilities
• Governance and internal controls over payments ecosystems

🟦 Fraud Prevention and Detection

• Internal controls and separation of duties
• Insider abuse explicitly called out
• Exam procedures being updated to reflect evolving fraud risks

🟦 BSA / AML Compliance Risk Management

• Shift away from broad consumer compliance narrative
• Stronger focus on risk-based AML programs
• Programs must be tailored to actual institutional risk

🔄 What’s Notably Different from Prior Years?

Mark also highlights important shifts compared to earlier supervisory letters:

• Cybersecurity is no longer a standalone headline — now embedded in Operational Risk and Payments
• Consumer financial protection is not emphasized as a top category
• Fraud and payment systems return after being absent for several years
• Governance expectations are increasingly embedded in every risk area

These changes align with what many credit unions are already experiencing in exams — more findings tied to process, oversight, and documentation, not just numbers.

🎤 What’s Coming After the Cruise

During the Florida Q’s Cruise, Mark, Steve, and Todd will be discussing:

• What credit unions are actually seeing in recent exams
• Where examiner expectations are rising fastest
• How governance findings are being framed
• What boards should be asking management right now
• How to manage regulatory uncertainty proactively

After the cruise, a full follow-up episode will bring those insights back to the broader audience.

🎯 Key Takeaway

The risks themselves haven’t changed dramatically — but NCUA’s capacity, processes, and delivery of supervision have.

Credit unions that adapt their governance, documentation, and strategic planning to that reality will be better positioned to manage both exam outcomes and approval delays in 2026 and beyond.

https://www.linkedin.com/in/mark-treichel/

The clash between President Trump and Federal Reserve Chair Jerome Powell has now expanded beyond interest rates — and into a $2.5 billion building renovation at the Fed.

Some see waste.
 Some see politics.
 Most people just see a number that’s hard to comprehend.

In this episode, I take a middle-ground look at what’s really going on:

• Why large government construction projects almost always cost more than planned
 • Why political egos inevitably get involved
 • And why $2.5 billion still deserves serious public context and scrutiny

Using real-world comparisons — from stacks of dollar bills reaching into space, to thousands of apartments, to centuries of spending at $1,000 an hour — we reset the conversation around scale, transparency, and accountability, without turning it into a partisan fight.

Because when budgets get this big, math matters more than megaphones.

Key Topics Covered

• Why billion-dollar numbers break our intuition
• Construction overruns: normal, but not meaningless
• How political power struggles complicate budget debates
• The opportunity cost of multi-billion-dollar projects
• Why public institutions owe the public real financial context

Who Should Listen

• Credit union and bank leaders
• Board members
• Policy and compliance professionals
• Anyone who wants less political theater and more financial reality

https://www.linkedin.com/in/mark-treichel/

President Trump has called for a one-year cap on credit card interest rates at 10%. It’s a headline-grabbing proposal — but can he actually do it, and what would it really mean for consumers, banks, and credit unions?

In this episode, Mark Treichel breaks down:

• Why presidents can “call for” caps but can’t impose them unilaterally
• Why credit card rates are high in the first place
• How a 10% cap could reduce access to credit, especially for lower-income borrowers
• Why rewards programs, grace periods, and credit limits could all be at risk
• How credit unions would be affected differently than large banks
• Why well-intended caps can push borrowers toward much worse alternatives like payday lending

Bottom line: It’s good politics, but it could be very bad policy — with consequences that hit the very people it’s supposed to help.

https://www.linkedin.com/in/mark-treichel/

NCUA exam reports often contain more than meets the eye.

Examiner findings, supplementary facts, and documents of resolution may look like routine supervisory language — but each serves a distinct purpose and sends a different signal to credit union boards and management.

In this episode of With Flying Colors, Mark Treichel is joined by former NCUA senior leaders Steve Farr and Todd Miller to break down how exam reports are structured, how issues escalate, and what credit unions should be paying attention to long before enforcement actions appear.

Drawing on decades of NCUA experience, the discussion explains how examiners decide where issues belong in the report, why volume matters as much as severity, and how governance and communication failures often sit at the root of repeat findings.

This is an evergreen episode for any credit union executive, board member, or compliance professional who wants to better understand what NCUA is really saying — and how to respond effectively.

In This Episode, We Discuss:

• The practical differences between examiner findings, supplementary facts, and documents of resolution
• Why a long list of “minor” findings can be a major warning sign
• How supplementary facts are used to signal emerging risk and specialist concerns
• What elevates an issue into a document of resolution
• The SMART framework examiners are expected to use — and where it breaks down
• How unresolved issues contribute to CAMEL rating pressure
• Why corporate governance increasingly appears in exam reports
• The role communication plays in preventing escalation
• What boards should ask before approving a document of resolution

Who Should Listen:

• Credit union board members
• CEOs and executive leadership teams
• Compliance, risk, and governance professionals
• Credit unions preparing for an upcoming NCUA exam
• Institutions experiencing repeat findings or growing examiner scrutiny

Key Takeaway:

NCUA exam reports are not just compliance documents — they are communication tools. Understanding how examiners signal concern helps credit unions prioritize issues, respond proportionately, and avoid unnecessary escalation.

About the Host:

Mark Treichel is a former senior NCUA executive and the founder of Credit Union Exam Solutions. With more than three decades of regulatory experience, Mark helps credit unions understand NCUA expectations and navigate examinations with confidence.

As teamwork becomes an increasingly critical theme heading into 2026, this conversation felt worth revisiting.

In this episode, Mark sits down with Joe Jacoby, an Olympic gold medalist and performance coach, to explore what high-performing teams really look like when conditions are uncertain and pressure is high.

While the setting is the Olympic Games, the lessons translate directly to leadership teams, boards, and organizations navigating complexity, change, and accountability.

This conversation isn’t about motivation—it’s about execution:

• How trust is built before it’s needed
• Why great teams communicate without noise
• How different strengths actually work together under stress
• And why teamwork isn’t soft—it’s strategic

If you lead, serve on a board, or work as part of a management team, the insights here are as relevant today as when this episode first aired.

In this episode, we discuss:

• What Olympic-level teamwork looks like in real time
• Why preparation matters more than celebration
• How unspoken communication develops inside high-trust teams
• The role of diversity of thought in performance
• Lessons leaders can apply long after the competition ends

https://www.linkedin.com/in/mark-treichel/

In this quarterly roundtable episode of With Flying Colors, Mark Treichel is joined by former NCUA executives Dennis Bauer, Steve Farrar, and Todd Miller to break down the NCUA Q3 2025 Quarterly Credit Union Data Summary.

The discussion highlights a key theme: the credit union system is gradually returning to a more normal operating environment after years of rate shocks, pandemic liquidity, and balance-sheet distortion.

Key topics include improving net interest margins, rising non-interest expenses, and why ROA gains lag margin recovery. The panel examines growing pressure in auto and credit card portfolios, increased repossessions, and what delinquency trends suggest heading into 2026. They also explore liquidity stabilization, shifts in share mix, and renewed investment risk-taking as some credit unions bet on future rate cuts.

Additional insights include CAMEL rating trends, HELOC utilization growth, differences between credit union and community bank performance, and what examiner behavior may look like amid NCUA staffing constraints.

This episode is designed for credit union executives, board members, and risk leaders looking for plain-English interpretation of regulatory data—without spin or hype.

https://www.linkedin.com/in/mark-treichel/

NCUA has launched a new Deregulation and Simplification Project, signaling a shift toward clearer, more flexible rules—without weakening safety and soundness.

In this episode of With Flying Colors, Mark Treichel breaks down the four proposed regulatory changes released by NCUA and explains what they mean in practice for credit unions, boards, and exam preparation.

Rather than a wholesale rewrite, this package focuses on clarity, structure, and regulatory housekeeping—especially around audits, corporate credit union governance, and cybersecurity guidance.

Key topics covered:

• Updates to Supervisory Committee audit rules (Part 715)
• Technical and governance clarifications for corporate credit unions
• Why cybersecurity guidance is moving out of regulation and into Letters to Credit Unions
• What’s not changing—despite the headlines
• How this project fits into broader NCUA budget and structural discussions

Mark also shares perspective on why moving guidance out of the CFR matters—and what credit unions should (and shouldn’t) do next.

More regulatory developments are coming fast, including NCUA’s upcoming board meeting and budget discussions. Stay tuned.

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel speaks with Dan Prezioso, Partner at Olden Lane, about the demographic shift reshaping credit unions and why deposit competition is entering a new era.

Dan shares data and insights from multiple national surveys, macro trends, and firsthand M&A activity, including:

• Why strategic mergers are already breaking NCUA approval records in 2025
• The shrinking role of baby boomers as depositors, borrowers, and primary financial institution users
• Why Gen Z and millennials are saving more — but choosing Robinhood, Coinbase, and SoFi over traditional credit unions
• The alarming statistic that 37% of Gen Z credit union members are likely to switch institutions in the next 12 months
• “Real” deposit growth vs. nominal growth, and why rising OPEX may force additional consolidation
• The engagement deficit: younger members don’t think of credit unions as their everyday financial partner
• What credit unions can do right now to stay relevant in the next decade

Dan also highlights examples of institutions that are getting it right — from fractional real estate investing to budgeting tools and crypto-enabled debit cards — and explains what boards should be asking their CEOs in 2026 strategic planning.

📩 Connect with Dan: dprezioso@oldenlane.com

🔗 Olden Lane: info@oldenlane.com

🎧 Listen now and subscribe for future episodes of With Flying Colors.

https://www.linkedin.com/in/mark-treichel/

Episode Summary

In this archive episode of With Flying Colors, Mark sits down with Todd Miller — longtime NCUA expert, former Director of Special Actions, and member of the CU Exam Solutions team — to break down one of the most misunderstood and under-optimized tools in credit union governance: the board package.

Boards get in trouble not because they don’t care, Todd explains, but because they are often misinformed, overwhelmed, or kept in the dark. A well-designed board package solves that — if it’s built with the right mix of clarity, consistency, and candor.

Todd explains:

• What high-performing board packages include
• Why “size and complexity” shape reporting expectations
• The danger of data dumps, inconsistent formatting, and detail overload
• How to pair dashboards with strong qualitative narratives
• The one question every executive should answer in their reports
• Why peer comparisons matter
• How risk appetite, strategic plans, and deviation explanations must tie together
• Real-world stories from troubled and well-run credit unions
• How to avoid examiner criticism by aligning reporting with actual risk

This episode is full of practical actions your board and leadership team can apply immediately.

Key Themes & Takeaways

1. Great Board Packages Balance Qualitative + Quantitative Reporting

Todd outlines a simple principle:
 Board reports should demonstrate management’s compliance with the business plan, board policies, and the credit union’s risk appetite. 

transcript Board Packages Todd …

Boards need both data and narrative to understand where the credit union is, how it got there, and where it’s going.

2. Consistency Builds Board Trust

From formatting to color-coding to dashboards, consistency helps directors quickly understand risk without getting bogged down.

Inconsistent layouts or disorganized reporting create confusion and can lead to micromanagement or oversight failures.

3. Avoid the “Data Dump” Trap

Todd highlights that many troubled credit unions had mountains of data… but no clarity.
 Board packets that keep expanding over time—without periodic pruning—bury critical insights.

Annual reviews of what stays, what goes, and how information is summarized are essential.

4. Dashboards Are Critical — But Must Be Thoughtfully Built

Dashboards should show:

• Where the CU has been
• Where it is now
• Where it’s trending next

They must also be paired with narrative analysis to flag:

• Variances
• Deviations from strategic/annual plans
• New risks
• New opportunities

5. The Biggest Blind Spot: Credit Risk Reporting

Credit risk is the No. 1 cause of failures.
 Todd explains how to reduce hundreds of pages into 2–3 meaningful pages with:

• Risk migration visuals
• LTV + credit score overlays
• Portfolio trends
• Business loan concentration & large-borrower exposure

6. Committees Create Risk — and Reporting Obligations

ALCO, lending, IT, risk committees…
 Boards need visibility but not minutiae.

Todd walks through how well-run credit unions:

• Summarize committee output
• Elevate red flags
• Keep the board focused on strategy, not operations

7. Real-World Stories—The Good, The Bad, The Ugly

Todd shares examples of:

• 39 unprofitable branches hidden in an overly detailed packet
• Boards blindsided by marijuana banking risk and resulting fines
• A $4 million depositor walking out because the board lacked context

These stories underscore the need for transparency, context, and prioritization.

Why This Matters

A strong board package:

• Improves governance
• Enhances regulator confidence
• Prevents surprises
• Supports faster, cleaner exams
• Keeps boards strategic
• Helps management demonstrate competence and control

This episode is a must-listen for CEOs, CFOs, lending executives, and directors looking to elevate their governance culture.

https://www.linkedin.com/in/mark-treichel/

Overview
In this episode, we break down the fundamentals of risk management for credit unions — what it really means, why it matters at every asset size, and how boards and executives can build a resilient framework that supports safe, sustainable growth. 

blog risk appetite

What We Cover

• The Three Pillars of Risk Management
  • Risk Culture — how tone from the top determines effectiveness.
  • Risk Appetite — defining how much risk is acceptable before strategy becomes unsafe.
  • Risk Management System — the controls, processes, and oversight that put culture and appetite into action. 

    blog risk appetite

• Why Size Matters — and Doesn’t
  • Practical guidance for smaller credit unions: clear limits, strong oversight, and effective supervisory committees.
  • What larger credit unions need: formal risk appetite statements, risk departments, and comprehensive reporting frameworks. 

    blog risk appetite

• Common Pitfalls
  • The “capital trap”—why even strong net worth can’t compensate for unmanaged concentration risk (e.g., taxi medallion credit unions).
  • Siloed risk decisions.
  • Hoping limit breaches “self-correct.” 

    blog risk appetite

• Best Practices for a Strong Framework
  • Align appetite with capital and strategy.
  • Use clear metrics to monitor risk.
  • Establish formal limit-breach processes.
  • Encourage staff to raise risk concerns without hesitation.
  • Maintain strong documentation and communication. 

    blog risk appetite

Key Takeaway
Risk management isn’t about eliminating risk — it’s about managing it in a way that protects members while enabling growth. A clear culture, aligned risk appetite, and well-designed system create the foundation for long-term success. 

https://www.linkedin.com/in/mark-treichel/

This week on With Flying Colors, I’m joined by three longtime colleagues from my days at NCUA — John McKechnie, Alonzo Swann, and Geoff Bacino — for a lively roundtable on where the agency stands today, what’s working, and what’s at risk.

Together, we revisit our shared time inside NCUA and discuss how leadership, budgets, and supervision are evolving in 2025 and beyond. From one-member boards and budget cuts to liquidity lifelines and affordable housing, this episode brings together decades of experience and unfiltered perspective.

In this episode, we discuss:

• What it means for NCUA to operate with only one sitting board member
• The implications of budget reductions and staff shortages on examinations
• How Federal Home Loan Banks have become vital liquidity partners for credit unions
• Why onsite contact and examiner familiarity still matter
• The Supreme Court and DOJ developments shaping NCUA’s legal authority
• The value of compromise and balanced governance inside NCUA
• The political landscape heading into the next election cycle — and what it may mean for credit unions

You’ll hear candid insights, historical context, and even a few friendly football rivalries — the kind of inside conversation that only veterans of the agency can have.

🎙️ Guests

• John McKechnie – Former NCUA Director of Public and Congressional Affairs; consultant to the credit union and housing industries
• Alonzo Swann – Former NCUA Regional Director; Credit Union Strategist at the Federal Home Loan Bank of Atlanta
• Geoff Bacino – Former NCUA Board Member; former Federal Housing Finance Board Member; association executive and industry advocate

🔗 Connect & Learn More

Visit MarkTreichel.com/podcast
for past episodes, transcripts, and consulting resources.

Follow Mark on LinkedIn for weekly updates: linkedin.com/in/marktreichel

Sponsored by Credit Union Exam Solutions — helping credit unions save time and money when working with NCUA.

We discuss the implications for NCUA supervision, administrative actions, and how examiners begin building a formal record. You’ll learn about the added burden of frequent exams, the role of letters of understanding and agreements, and how Code 4 status impacts liquidity options, board responsibilities, and long-term viability.

Packed with hard-earned insights from decades inside NCUA, this archive episode helps credit unions understand both the risks and the pathways to recovery when facing a Code 4 downgrade

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel sits down with David Reed of Reed & Jolly to dive deep into the NCUA’s new succession planning rule and what it means for credit unions across the country.

Too often, boards and executives focus on writing a policy—but not on the real-world practice of finding and preparing leaders for the future. David explains why succession planning can’t stop with “golden handcuffs” or executive retention packages and why the real challenge is board and volunteer succession.

Key Topics Covered

• The January 2026 effective date of the NCUA succession planning rule
• Why smaller credit unions face unique challenges when CEOs retire or leave suddenly
• The risks of relying only on the “hit by a bus” plan for executive succession
• Board succession struggles: aging volunteers, shrinking social networks, and limited recruitment pools
• The role of advisory boards, director emeritus programs, and board expansion in keeping knowledge while bringing in fresh voices
• The importance of diversity of thought—beyond demographics—to strengthen governance
• Practical tips for creating a process to identify, recruit, and onboard new volunteers
• How nominations policies and ongoing outreach can build a pipeline of future board members

David also shares stories from his work with credit unions nationwide, highlighting what works, what doesn’t, and how to avoid common pitfalls.

Why Listen?

If you’re a credit union leader, board member, or volunteer, this episode offers realistic, actionable advice on turning succession planning from a compliance checklist into a strategic advantage.

📧 To reach David Reed: david@reedandjolly.com

Vin draws on his unique experience working on all three sides of the desk—as a lender, borrower, and regulator—to explain how a strong credit culture begins with board values, flows through management, and guides every credit decision. Together, Mark and Vin unpack key takeaways including:

• The definition and purpose of credit culture within a credit union.
• How board values and management philosophy shape consistent lending practices.
• The importance of reading regulatory preambles to understand NCUA’s intent.
• Why every policy, system, and training program should reinforce a consistent credit approach.
• How examiners and credit unions can align on “the art” of evaluating risk rather than relying on “paint-by-number” regulation.
• The role of appropriate structuring, documentation, and open dialogue with examiners.

Whether you’re a CEO, board member, or senior lender, this episode provides valuable insight into balancing safe and sound lending with member-focused service.

https://www.linkedin.com/in/mark-treichel/

In this solo episode, Mark Treichel breaks down a hot topic out of Washington: a Senate proposal to raise FDIC deposit insurance coverage from $250,000 to $10 million. Backed by Treasury Secretary Scott Bessent and Senator Elizabeth Warren, the idea is gaining traction — but what would it mean for credit unions?

Mark explores:

• Why big banks are fighting the proposal — and why they might have a point
• How a $10 million FDIC cap could drain the National Credit Union Share Insurance Fund (NCUSIF)
• The political ripple effects for NCUA premiums and restoration plans
• Why credit unions risk losing business accounts if insurance coverage doesn’t keep pace with banks
• Alternatives, like inflation-based adjustments, that could make more sense than a massive jump

In the end, Mark explains why raising the cap might look like protection, but could really be lipstick on a pig for credit unions and their members.

They cover:

• How poor governance can sink an institution — and how strong governance can turn it around.
• The importance of tone at the top, ethics, and board oversight.
• Why diversity of skills, demographics, and perspectives matters for boards.
• The regulatory framework: NCUA’s limited guidance versus FDIC’s more robust tools.
• Resources for directors, including FDIC pocket guides, training, and self-assessments.
• Real-world stories from examinations, conservatorships, and boardrooms.

Whether you’re a director, executive, or examiner, this episode highlights why governance is more than compliance — it’s culture, accountability, and the foundation of credit union safety and soundness.

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, I sit down with Elizabeth Eurgubian, Partner at Atlas Advocacy and former Director of External Affairs and Communications at the NCUA. Elizabeth brings a wealth of experience spanning the Federal Reserve, CFPB, Sallie Mae, ICBA, CUNA, and her time inside the regulator’s office.

We discuss:

• Her unique career path from attorney at the Fed to trade association leadership to NCUA’s front office
• The critical role of the Office of External Affairs and Communications (OAC) in shaping policy and messaging
• Insights into working for Chairman Todd Harper and navigating political appointee roles
• The art of preparing NCUA leadership for congressional testimony (“murder boards”)
• How credit union comment letters really influence regulation
• Why relationships and follow-up are the currency of Washington advocacy
• Her current work with Atlas Advocacy and DCUC

Whether you’re a credit union leader, policy professional, or industry observer, this episode gives you an insider’s perspective on how advocacy and regulation intersect at the highest levels.

We explore how NCUA approaches Code 3 institutions, what extra exams and follow-ups to expect, the impact of documents of resolution and regional director letters, and why boards and management must act decisively to restore stability.

Packed with decades of insider perspective, this episode is a must-listen for anyone wanting to understand the practical realities of moving from a 1 or 2 to a 3.

https://www.linkedin.com/in/mark-treichel/

In this solo episode of With Flying Colors, Mark Treichel breaks down the NCUA’s proposed rule to eliminate reputation risk from its supervisory program — and the political spotlight surrounding it.

Mark explains:

• Why the N C U A is codifying the removal of reputation risk into regulation.
• How codification makes the change harder to reverse in the future.
• The subjectivity of “reputation risk” and why examiners are no longer allowed to use it.
• The proposal’s explicit ban on examiners acting “for political reasons.”
• Connections to President Trump’s Executive Order 14331 and allegations of politically motivated account closures.
• Examples of industries and groups often caught in the crossfire, from firearms to advocacy organizations.
• What this means for state regulators, joint exams, and your next exam.
• Why the NCUA claims there are no new compliance costs.
• The expected benefits for exam consistency, predictability, and objectivity.

Whether you buy into the political narrative or not, this rule is designed to keep examiners out of politically driven decisions.

I’m joined by Steve Farrar and Todd Miller, both longtime NCUA veterans and now part of my team at Credit Union Exam Solutions. Together, we break down what it means if NCUA directs your credit union to conduct an organizational review—and why this is one of the most serious signals an examiner can send.

In this episode, we cover:

• Why an organizational review is almost always tied to serious management or governance weaknesses.
• How CAMELS codes connect to “unwilling or unable” management findings.
• The difference between NCUA’s approach and how the FDIC structures its organizational review requirements.
• The role of third-party consultants, approval requirements, and pitfalls boards must avoid.
• Why humility and proactive planning are key if your credit union receives this directive.
• War stories from our years at NCUA—including conservatorship cases and tough appraisal calls—that illustrate the real-world consequences.

If you’ve ever wondered what this type of supervisory action means for a board, a CEO, or an examiner, this conversation will give you candid insight from those who have lived it.

👉 Note: This is an archive episode—we’re resurfacing it because the lessons are timeless and many credit unions will benefit from a refresher.

https://www.linkedin.com/in/mark-treichel/

 In this episode of With Flying Colors, host Mark Treichel sits down with Scott Gladden and Kenny Ray Mitchell of Innovations Credit Union to preview the CUES Florida Council Cruise happening January 16–20, 2026. This unique event combines professional development, networking, and a Caribbean getaway—all tailored for credit union leaders, board members, and supervisory committees.

What You’ll Learn in This Episode:

• The origins of the CUES Council Cruise and how it became a 20-year tradition of education and collaboration.
• Event details: sailing on Royal Caribbean’s Radiance of the Seas from Fort Lauderdale to Grand Bahama Island and Nassau.
• Why the cruise is open to all credit union professionals across the country—not just Florida.
• The speaker lineup, including:
  • John DeLoach, credit union attorney (compliance, BSA, OFAC updates)
  • Trey Rudder, Corporate America (financial training for boards and committees)
  • Mike Mola, Olden Lane (industry consolidation, subordinated debt)
  • Mark Treichel, Steve Farrar, and Todd Miller of CU Exam Solutions (strategies to pass your NCUA exam with flying colors)
• Perks of the cruise: deluxe beverage package, included Wi-Fi, networking receptions each evening, and a relaxed but focused learning environment.
• How the informal conversations—over coffee, dinner, or a glass of wine—often prove just as valuable as the sessions themselves.

Why Attend?
If you’re looking to combine professional development with a January getaway, the CUES Council Cruise is an affordable, high-impact option. You’ll return with new insights, stronger connections, and renewed energy to lead your credit union.

Event Info
📅 Dates: January 16–20, 2026 (Friday–Tuesday)
🚢 Cruise Line: Royal Caribbean Radiance of the Seas
📍 Ports: Fort Lauderdale → Grand Bahama Island → Nassau
🎓 Audience: Credit union executives, board members, and supervisory committees
📞 For questions and booking: Contact Kenny Ray Mitchell at (850) 832-3872

They break down the nuances, including:

• When it’s routine vs. when it’s unusual.
• Why NCUA may ask to meet with a board chair separately.
• Situations where examiners want to hear directly from board members.
• The role of supervisory committees and board governance accountability.
• How boards should prepare — including when to ask for an agenda, whether to bring counsel, and why you should avoid making commitments in the room.

This candid discussion highlights the importance of communication, trust, and preparedness when navigating examiner requests.

Key Takeaways

• A request to meet with a board chair is often routine and about building trust.
• A request to meet with the full board without staff is rare — usually a signal of deeper concerns.
• Boards should listen carefully, avoid agreeing to actions on the spot, and consider legal counsel if appropriate.
• Examiners are trained in conflict resolution — open, respectful dialogue goes a long way.
• Recording or documenting meetings can protect both parties and ensure clarity.

Resources

• Learn more about how Credit Union Exam Solutions supports boards and executives: marktreichel.com

• Subscribe to With Flying Colors on your favorite podcast app for more insights on navigating NCUA exams.

https://www.linkedin.com/in/mark-treichel/

Episode Overview:
In this episode of With Flying Colors, Mark unpacks NCUA’s proposed 2026–2027 budget — a spending plan that reduces staff by 23%, cuts contractors by a third, and reshapes how credit unions will be supervised.

What you’ll learn:

• Why NCUA’s staff will shrink to 967 employees — the lowest in over 20 years
• Which offices are hit hardest by the cuts
• How the hiring freeze and buyouts are creating exam disruption and turnover
• Why credit unions may see fewer exams, but bumpier interactions
• The role of technology investments and the $10 million “transformation fund”
• Why the industry is cheering now — and why the pendulum will eventually swing back

Takeaway:
The 2026 budget gives credit unions breathing room in the short term. But it also introduces risks, creates examiner churn, and sets the stage for future losses that could reverse course.

https://www.linkedin.com/in/mark-treichel/

Episode Summary
In this episode of With Flying Colors, I sit down with Mark Ritter, CEO of Member Business Financial Services (MBFS) and host of Credit Union Conversations. Mark brings decades of experience in credit union business lending, having built MBFS from a three-person startup into a nationwide CUSO serving over 60 employees and credit unions across the U.S. and Puerto Rico.

We dive into:

• The evolution of member business lending—from the early “Lewis and Clark” days to today’s robust systems and strategies.
• The current lending environment: strong demand, liquidity challenges, and why stable employment remains the backbone of a healthy business lending program.
• The opportunities ahead, including refinancing booms as interest rates decline and five-year resets approach in 2026–27.
• The Federal Credit Union Act’s unintended consequences and how the 12.25% cap on MBLs reshaped the industry.
• Shifting NCUA exam culture—from transactional reviews to portfolio management—and what credit unions must do to stay ahead.
• Why relationships and annual portfolio reviews matter more than ever in building safe, sound, and mission-driven lending programs.

Mark also shares his perspective on where credit unions should focus their energy: serving small businesses, veterans, and underserved communities, while avoiding mission drift into mega real estate deals that don’t align with cooperative values.

Whether you’re a CEO, examiner, or just curious about the future of credit union business lending, this episode delivers insight, history, and strategy from one of the industry’s most trusted voices.

Resources & Links

• Learn more about MBFS: mbfs.org

• Listen to Mark Ritter’s podcast Credit Union Conversations on all major platforms.
• Connect with Mark Ritter on LinkedIn.

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel breaks down the latest NCUA Board Meeting held on September 25, 2025. With only one agenda item—the NCUA Insurance Fund briefing—the discussion still revealed several key insights that credit union leaders need to know. From CAMELS code shifts to the impact of 27% of NCUA staff taking buyouts, Mark unpacks how these developments could shape examinations, budgets, and credit union operations in the months ahead.

🔑 Key Topics Covered

• Insurance Fund Health:
  • Slight improvement in CAMELS 4s and 5s.
  • Growth in CAMELS 3s as troubled credit unions move up a notch.
  • What this “treading water” means for the system.
• NCUA Staffing & Buyouts:
  • 27% of staff accepted buyouts and will not be replaced under the hiring freeze.
  • Why this creates short-term relief for credit unions—but possible long-term risks.
  • How staffing shortages may lead to fewer exams, faster upgrades, and less aggressive downgrades.
• Board Governance & Authority:
  • Chairman Kyle Hauptman’s nod to 2005, when a single board member issued a final rule.
  • Could today’s board act unilaterally on budgets and regulations?
• Budget Implications:
  • Early hints that credit union exam costs may drop in 2026.
  • How senior-level buyouts produce immediate salary savings.
  • The potential for reorganizations and cutbacks in areas like fair lending exams.
• Shifts in Examination Policy:
  • Risk ratings have been removed from exam reports.
  • Why this change matters for CEOs and exam management.

📌 Why It Matters

For credit unions, these updates signal both opportunity and uncertainty. On the one hand, fewer examiners and less scrutiny may provide breathing room. On the other hand, reduced oversight could carry hidden risks for the NCUSIF and credit union stability.

Mark shares his take on what credit unions should be watching—and how to prepare as NCUA adapts to a smaller workforce and shifting governance environment.

https://www.linkedin.com/in/mark-treichel/

In this episode of With Flying Colors, Mark Treichel sits down with Jason Stverak, Chief Advocacy Officer of the Defense Credit Union Council (DCUC), to discuss the pressing issues shaping the credit union movement.

Key topics covered:

• 🇺🇸 Veteran Business Lending Cap: Why credit unions should be free to fully support veterans and their families.
• 🏛️ Advocacy Strategy: DCUC’s “Green Beret” approach to being nimble, prepared, and effective on Capitol Hill.
• 💸 Credit Union Tax Status: Lessons from past fights and why vigilance is still essential.
• 🏦 Bank Purchases: Why DCUC is defending credit unions’ ability to buy banks — and why that benefits communities.
• 🔮 Looking Ahead: Budget cycles, NCUA staffing, and regulatory challenges that could reshape the industry.
• 🤝 DCUC Membership: Why every credit union — not just defense-focused ones — can join and benefit.

Jason shares how DCUC keeps credit unions ready for the next challenge, and why advocacy is less about size and more about strategy.

https://www.linkedin.com/in/mark-treichel/

Credit Unions vs. Banks: What Q2 Data Reveals

In this episode of With Flying Colors, Mark Treichel is joined by Steve Farrar, Todd Miller, and Dennis Bauer to break down the latest Q2 reports from NCUA and FDIC. Together, they unpack what the numbers really mean for credit unions, banks, and the communities they serve.

What you’ll learn in this episode:

• 📊 How credit union deposit and loan growth stacks up against banks in Q2.
• 💸 Why net interest margins and operating expenses tell two very different stories.
• 🏦 Where credit unions are taking market share — and where risks are rising.
• ⚖️ The growing gap in capital strength between credit unions and community banks.
• 🔮 Key headwinds to watch for the rest of 2025, from liquidity pressures to rising delinquencies.

Whether you’re a credit union leader, regulator, or industry observer, this episode delivers insights on who’s winning the quarter — and what challenges lie ahead.

https://www.linkedin.com/in/mark-treichel/

NCUA's Commercial Loan Rule requires a rating system.  I discuss what it requires with Vin Vieten, author of the rule.

https://www.linkedin.com/in/mark-treichel/

Former NCUA Executive Director Mark Treichel talks with Ray Ragan, CIO of Securityplus Federal Credit Union, about taking AI beyond fraud detection and call center scripts. Ray shares how credit unions can use the NIST AI Risk Management Framework to build board-approved policies, leverage AI for strategic planning, and embrace Agentic AI to stay competitive. You’ll hear why human accountability matters, how to break down organizational silos, and why waiting for AI guidance could leave your credit union behind.

https://www.linkedin.com/in/mark-treichel/

COMMERCIAL CREDIT RISKS

•  Rising commercial credit risks - Why regulators are worried
•  Work-from-home impact on commercial real estate
•  Rate shock reality: 3-4% loans resetting to 6-7%
• Minneapolis downtown real estate down 25%
•  CECL forecasting challenges and provision expenses
• NCUA's hyperfocus on annual review processes
•  Empty office buildings near NCUA headquarters

https://www.linkedin.com/in/mark-treichel/

Episode Summary

In this episode of With Flying Colors, I’m joined by two longtime friends and former NCUA colleagues — John McKechnie and Geoff Bacino — for a candid roundtable on the latest twists at the agency and across the credit union movement.

From the legal limbo over NCUA board seats to the agency’s shrinking staff and the Supreme Court case that could reshape presidential power, we dig into what it all means for your credit union. We also cover the leadership change at America’s Credit Unions, the future of CFPB oversight, and what to expect from NCUA’s upcoming strategic planning town hall.

And yes — we wrap up with some NFL predictions (with John’s Ravens, Geoff’s Bears, and my Vikings all getting their fair share of good-natured ribbing).

What You’ll Learn in This Episode

• The latest on the NCUA board shake-up: Harper, Ska, Trump, and the courts
• How the Humphrey’s Executor Supreme Court case could upend federal regulatory appointments
• What NCUA’s staff buyouts and hiring freeze mean for supervision and examinations
• Why communication between credit unions and regulators is more critical than ever
• Insights on America’s Credit Unions’ new CEO Scott Simpson and what his leadership could signal
• The future of CFPB oversight and how credit unions should prepare for the next compliance pendulum swing
• Why the upcoming NCUA strategic planning town hall is a chance for credit unions to speak up
• Some football predictions to lighten the mood — Ravens, Bears, and Vikings fans, take note

https://www.linkedin.com/in/mark-treichel/

OPERATIONAL RISKS

• Cyber incident response planning essentials
•  Communication strategies for cyber incidents
•  Legacy system conversion nightmares
• NCUA's helpful approach to cybersecurity findings
•  Core system conversion best practices

https://www.linkedin.com/in/mark-treichel/

NCUA recently posted new guidance on how to start an exam efficiently — and for many credit unions, it couldn’t come at a better time.

In this episode of With Flying Colors, Mark Treichel is joined by Todd Miller, Steve Farrar, and Dennis Bauer to break down what’s in the guidance, why it was issued, and how credit unions can put it into practice. With over 120 years of combined NCUA and credit union leadership experience, they share practical steps to streamline exam prep, avoid duplicate requests, and manage the growing number of specialists.

You’ll learn:

• Why NCUA may be tightening its exam process — and what’s driving the change
• The importance of a “gatekeeper” role to coordinate all examiner requests
• How offsite exams and specialist involvement can create inefficiencies (and how to counter them)
• The behind-the-scenes impact of staff losses and policy changes at NCUA
• Tips to avoid last-minute scrambles and make your exam go smoother

Whether you’re a CEO, CFO, risk manager, or board member, this conversation will give you actionable insights to protect your time and your team’s sanity — while keeping your next exam on track.

https://www.linkedin.com/in/mark-treichel/

INTEREST RATE ENVIRONMENT

• Fed policy uncertainty and tariff impacts
•  Yield curve normalization: -35 to +50 basis points
•  CD composition shift: 13% to 28% of deposits
• Credit unions adapting to "new normal"
•  Investment portfolios still 6-7% underwater
•  Examiner demands for enhanced stress testing
•  Cost vs. value of regulatory requests

https://www.linkedin.com/in/mark-treichel/

ETAIL CREDIT PERFORMANCE

•  Student loan payment resumption impact
• Mixed economic signals across states
• 24 vs 26 states: unemployment trends
•  Generational differences in borrowing behavior
•  Venmo revolution: 85% of users under 40, $342B in Q1 transfers

https://www.linkedin.com/in/mark-treichel/

NCUA's regulation define what can be appealed.  But you can appeal ANYTHING to the region.  We discuss how whey and when you might want to do it.

https://www.linkedin.com/in/mark-treichel/

FRAUD SCHEMES

• [00:41:00] Timeshare resale fraud targeting elderly
• [00:44:00] ATM "jackpotting" - new threat explained
• [00:45:00] Skimming device sophistication
• [00:46:00] Universal key vulnerabilities

https://www.linkedin.com/in/mark-treichel/

Home Mortgage Disclosure Act (HMDA) Basics

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NCUA in Limbo: What the Board Shakeup Means for Credit Unions

Episode Date: July 28, 2025
Host: Mark Treichel

Episode Summary

The NCUA board is in complete chaos following President Trump's firing of board members Todd Harper and Tanya Otsuka, their court-ordered reinstatement, and subsequent legal stay. Mark breaks down the dramatic week of legal battles, analyzes what happened during last Thursday's awkward board meeting, and predicts the 80% chance Harper and Otsuka won't return permanently.

Key Topics Covered

The Legal Drama Timeline

• Trump's firing of Harper and Otsuka
• Federal court ruling that Trump violated the Federal Credit Union Act
• Wednesday court decision ordering immediate reinstatement
• Weekend stay blocking their return
• Likely Supreme Court appeal ahead

Last Thursday's Board Meeting Analysis

• Harper and Otsuka's awkward return (Harper via video, Otsuka in person)
• Three "safe" briefings: AI, CLF, and the new Ombudsman office
• The "500-pound elephant in the room" that everyone avoided
• Why staff is in an impossible position

What's Next for the Board

• 80% odds Harper and Otsuka don't return permanently
• Kyle Huffman's term expires next month
• Possibility of Trump appointing 2-3 new board members before year-end
• Impact of onboarding multiple new board members simultaneously

Inspector General Report Bombshell

• Critical Infrastructure Division Director scandal exposed
• False statements on background investigations
• Sending sensitive NCUA documents to personal email
• Unauthorized outside employment while at NCUA
• Possible connection to unauthorized AI usage

Budget Implications

• Two-year budget cycle hanging in limbo
• No mid-year budget briefing despite historical precedent
• How a Republican board majority might cut costs to credit unions
• August board meeting hiatus continues tradition

Notable Quotes

"The 500 pound elephant in the room relative to the whole issue, all three sides avoided."

"I would say 80% chance that they do not come back and that the places will be filled before the end of the year."

"The professionalism of staff is well above average. And while they're going through all these things, it's chaotic."

Upcoming Content

Mark announces the OCC Risk Report series - breaking down his longer three-person discussion with Dennis, Steve, and Todd into shorter Thursday episodes throughout the summer. These will explore OCC findings and their implications for credit union examinations.

https://www.linkedin.com/in/mark-treichel/

Global Cash Flow.  What is it and why does NCUA care?

https://www.linkedin.com/in/mark-treichel/

ALCO committees are of paramount importance.  We take a deep dive into the nuances of this important committee and discuss Essential Reports Analysis and Risk Management

https://www.linkedin.com/in/mark-treichel/

Credit Union Roundtable: Mid-Year Risk Reports - Our Take on What it Means for CUs

Episode Description

In this inaugural Credit Union Roundtable episode, host Mark Treichel is joined by three industry veterans to break down the OCC's Spring 2025 risk report and what it means for credit unions. Steve Farrar, Todd Miller, and Dennis Bauer bring decades of combined NCUA and credit union experience to analyze the top risk concerns facing the industry.

Featured Guests

Steve Farrar - Former NCUA examiner and problem case officer with 30+ years of regulatory experience, including work on the risk-based capital rule and Central Liquidity Facility

Todd Miller - 34-year NCUA veteran, former Director of Special Actions in the Western Region, capital markets specialist

Dennis Bauer - Recently retired CFO of Ideal Credit Union (grew from $100M to $1B+ during his tenure), former NCUA examiner

Key Topics Covered

Commercial Credit Risk (9:00)

• Rising delinquencies in commercial real estate
• Impact of interest rate resets on variable rate loans
• Office building vacancy concerns post-COVID
• NCUA's increased focus on annual review processes
• New concentration limit requirements by property type

Retail Credit Performance (18:00)

• Student loan payment resumption impacts
• Generational differences in borrowing behavior
• Auto loan portfolio shrinkage trends
• Regional economic performance variations

Interest Rate Environment (24:00)

• Yield curve normalization effects
• CD composition changes (13% to 28% of deposits)
• Underwater investment portfolios
• Enhanced stress testing requirements from examiners

Operational Risk Challenges (33:00)

• Cybersecurity incident response planning
• Legacy system conversion risks
• Communication strategies during cyber incidents
• Cost vs. benefit analysis for security upgrades

Fraud & Payment Systems (39:00)

• Elder fraud targeting (timeshare scams example)
• ATM jackpotting and skimming schemes
• Venmo usage statistics (85% under 40, $342B in Q1 transfers)
• Third-party payment system competition

BSA/AML Compliance Burden (45:00)

• Staffing challenges for smaller credit unions
• Creating collaborative BSA offices
• Committee-based approach to compliance

Growth & Competition (46:00)

• Slow loan growth trends
• Credit unions gaining deposit market share vs. banks
• Money supply impacts on deposit availability
• Pricing strategy considerations

AI & Technology Adoption (50:00)

• Model validation requirements
• Third-party vendor risk management
• NCUA's AI policy challenges
• Competitive advantages vs. compliance risks

Key Takeaways

1. Commercial Real Estate Monitoring: Credit unions should closely watch their CRE portfolios, especially office properties and loans approaching rate resets
2. Stress Testing Expansion: Expect more detailed scenario analysis requests from NCUA examiners across interest rate and liquidity risks
3. Operational Risk Investment: Cybersecurity and system conversion planning require significant ongoing investment and expertise
4. Generational Shifts: Adapting to younger members' payment preferences and borrowing behaviors is critical for long-term growth
5. AI Adoption Strategy: Credit unions need to embrace AI while implementing proper model validation and risk management frameworks

Resources Mentioned

• OCC Spring 2025 Risk Report (link in show notes)
• Credit Union Regulatory Guidance podcast (AI-powered audio summaries)
• Attorney General scam awareness resources

Notable Quotes

"A rolling loan gathers no loss" - Professor Willie Stotts reference on commercial loan repricing challenges

"We took the approach that we're gonna have a cyber incident... so we took that approach in developing our incident response plan" - Dennis Bauer on cybersecurity preparation

"If you don't have time to do it right, you don't have time to do it over" - On system conversion planning

Contact Information

Mark Treichel - Host, With Flying Colors Podcast Consulting Services: Available for credit union risk management and regulatory guidance

Next Episode Preview

Stay tuned for more Credit Union Roundtable discussions featuring industry veterans sharing practical insights on regulatory trends and risk management strategies.

This episode provides general information and should not be considered specific regulatory or legal advice. Credit unions should consult with their own advisors and regulatory contacts for guidance on specific situations.

https://www.linkedin.com/in/mark-treichel/

Is your ALCO Committee structured optimally?  We can help you figure that out with this episode.

https://www.linkedin.com/in/mark-treichel/

Episode Summary:

In this episode of With Flying Colors, host Mark Treichel sits down with Thomas Griswold, Managing Director at ALM First, to explore the financial forces shaping credit unions in 2025 and beyond. From balance sheet risk to liquidity pressures and loan participation strategies, Thomas shares insights into how ALM First helps credit unions navigate a dynamic economic environment with capital discipline at the center.

They also dive into recent industry trends, including:

• The slowdown in consumer loan growth
• Rebalancing liquidity post-rate hikes
• Strategic use of CDs, borrowings, and non-member funding
• Pricing risk wisely (and knowing when not to chase volume)
• Mergers of equals and the evolving landscape of consolidation
• New developments in ALM First's services—including on-demand liquidity tools and talent retention strategies

Whether you're a CEO, CFO, or board member, this episode is packed with practical takeaways on managing risk and optimizing performance in uncertain times.

🔍 Topics Covered:

• Why capital is the “hub” of the strategic wheel
• How loan demand is shaping balance sheet strategy
• Risks of chasing growth versus pricing risk correctly
• Tools ALM First has built to model stress and liquidity in real-time
• The pilot program for credit union loan funds
• How credit unions can improve executive retention and benefits
• Trends in mergers, profitability, and deposit behavior

🧠 Key Quote:

🔗 Resources Mentioned:

• ALM First
• Contact Thomas: tgriswold@almfirst.com

🎧 Listen + Subscribe:

Available on Apple Podcasts, Spotify, YouTube, and everywhere you get your podcasts.

https://www.linkedin.com/in/mark-treichel/

Steve Farrar served as the VP of the CLF while at NCUA.  Nobody understands the CLF better than Steve.  In this archive episode, we deeply dive into this often misunderstood government entity.

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There is what is required to be in a board package, what you want in your board package, what your board wants, and of course what NCUA wants.  We discuss how to satisfy NCUA.

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 Did the Trump Firings Cause a Regulatory Crisis at the NCUA? Warren & Waters Demand Answers

Episode Overview

Mark Treichel breaks down the congressional response to President Trump's firing of NCUA Board members Todd Harper and Tanya Otsuka, examining letters from Senators Elizabeth Warren and Maxine Waters that question the agency's legal authority to operate with only one board member.

Key Topics Covered

The Firings and Immediate Aftermath

• April 16, 2025: Trump fires NCUA Board members Todd Harper and Tanya Otsuka
• Only Chairman Kyle Hauptman remains on the three-member board
• Questions arise about the agency's ability to function without a quorum

Congressional Response

• Elizabeth Warren & Maxine Waters demand answers about NCUA's operations
• Letters sent to both the NCUA Inspector General and Board Chairman Hauptman
• Focus on whether single-member board can legally conduct agency business

The "Essential Functions" Controversy

• NCUA relies on delegation authority allowing "essential functions" during emergencies
• Problem: No clear definition of what constitutes "essential"
• Historical context from early 2000s when similar situation occurred with Dennis Dollar

Actions Taken Under Question

The IG identified 11 Board Action Memorandums (BAMs) approved by Hauptman alone:

1. Semi-annual agenda establishment
2. Board appeal hearing approval
3. Schedule policy career petition
4. Deferred resignation program approval
5. SSP performance standards changes
6. NCA delegation revisions
7. Examination schedule policy revision
8. Share insurance rule simplification comments
9. Personnel appointments and reassignments
10. Acting Inspector General appointment
11. Board meeting transcript approval
12. Bonus controversial action: Credit union conservatorship

Legal and Political Implications

• Regulatory crisis: Agency's own regulations require two board members for action
• Political undertones: Warren designed single-director CFPB but opposes single-member NCUA
• Pending lawsuits: Harper and Otsuka challenging their firings in court
• Potential solutions: Trump could appoint new members or court could rule on legality

Expert Analysis

Mark Treichel provides insider perspective as former NCUA Deputy Executive Director who helped create the "essential functions" delegation in the early 2000s.

Key Questions Raised

• What constitutes an "essential function" of the NCUA Board?
• Can the agency issue regulations with only one board member?
• Are the actions taken since April 16th legally defensible?
• Will pending court cases resolve the authority questions?

Timeline to Watch

• July 7th: Deadline for Hauptman's response to congressional demands
• Ongoing: Court cases challenging the firings
• Future: Potential new board member appointments

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The National Credit Union Administration today placed Aldersgate Federal Credit Union in Marion, Illinois, into conservatorship. Member services will continue while the NCUA works to resolve issues affecting the credit union’s operations.

Member deposits at Aldersgate Federal Credit Union remain protected by the National Credit Union Share Insurance Fund. Administered by the NCUA, the Share Insurance Fund protects individual accounts at federally insured credit unions up to $250,000. Member’s interest in all joint accounts combined is also insured up to $250,000. The Share Insurance Fund separately protects IRA and KEOGH retirement accounts up to $250,000. The Share Insurance Fund has the backing of the full faith and credit of the United States.

Members may conduct financial transactions via phone by calling the NCUA Asset Management and Assistance Center at 512.231.7940 Monday through Thursday between 10:00AM-4:00PM Central. Those calls will be routed to the appropriate specialists. Members can continue to conduct financial transactions, such as depositing funds, making loan payments, and requesting share withdrawals during the conservatorship.

Members with questions about the conservatorship may review the Aldersgate Federal Credit Union’s frequently asked questions posted on the NCUA’s website. Members with questions about their Share Insurance Fund coverage can find more information in the Share Insurance Coverage
(Opens new window) section of NCUA’s MyCreditUnion.gov
(Opens new window)consumer website.

Aldersgate Federal Credit Union is a federally insured credit union with 811 members and reported assets of $10.6 million, according to the credit union’s most recent Call Report. Aldersgate Federal Credit Union serves the ministerial and probationary members, full time employees, local pastors, clergy persons and diaconal ministers under appointment of the bishop of the Illinois Great Rivers Conference of the United Methodist Church

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NCUA often asks what a credit union's Risk Appetite is, but doesn't provide much if any, guidance on the topic. We do.

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NCUA staff rely heavily on the examiner guide and the National Supervision Policy Manual.  We discuss these documents and what they really mean for credit unions.

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In this short and slightly offbeat solo episode, Mark shares a personal tale of dog sitting gone sideways—with two lovable pit bulls, a well-intentioned checklist, and a humbling C-minus execution grade.

But the real story is what the NCUA didn't do last week.

The agency quietly canceled its June board meeting and offered only a placeholder for July, continuing a trend that started under Chairman Todd Harper. Mark weighs in on what this says about the agency's direction, leadership, and communication strategy.

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NCUA requires some level of management review every exam before you see it.  We explain why and how that impacts you.

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Episode Summary:
In this episode, I dive into what NCUA might look like after its May 22nd downsizing — a 25% reduction in staff driven by Trump-era mandates for smaller government. Using clues from the agency’s own language, historical precedent, and my firsthand experience with past reorganizations, I lay out my predictions for NCUA’s evolving structure.

This is part three of a special podcast series unpacking the agency’s potential realignment.

Key Topics Covered:

• 📉 25% Workforce Reduction: Who’s leaving, and what that signals for the future.
• 🏛️ Trump’s Mandate for Smaller Agencies: How it shapes NCUA’s staffing and budget decisions.
• 🗂️ Reading the Tea Leaves from Slide 13: Consolidation, decentralization, and “high-impact” work.
• 🔁 Past is Prologue: Lessons from the early 2000s restructuring under Chairman Dennis Dollar.
• 📊 Who Reports to Whom?: A detailed review of the current org chart and likely changes.
• ⚖️ Legal Implications: Why some moves (like eliminating ONES) may require board votes or rule changes.
• 🧩 Likely Office Shifts:
  • OMWI, Ethics, and Board Secretary to new homes
  • Potential absorption or elimination of CURE, ONES, and AMAC
  • Field of Membership functions back to the regions
• 🔍 High-Value Work Only?: Implications for DEI, affinity groups, and central office roles.
• 📍 Draconian Possibilities: Could NCUA eventually eliminate regions or relocate HQ?
• 🧠 Machiavelli & Reorgs: Why changing a system brings both enemies and uncertainty.

Quotable Moments:

Why It Matters:
Whether you're a credit union exec, examiner, or industry observer, understanding NCUA's likely future state can help you prepare for changes that could affect regulatory oversight, staffing, and even strategic planning at your institution.

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📝 Episode Summary:

In this post-Memorial Day episode, Mark dives into NCUA’s latest insurance fund update with a sharp focus on CAMEL codes—and why they matter more than ever in today's regulatory landscape. With NCUA facing staffing cuts, hiring freezes, and leadership questions, your credit union's CAMEL rating may determine how much attention (or relief) you're about to get.

Mark walks through key takeaways from the data, trends in ratings across credit union size categories, and why being a CAMEL 1 or 2 could lead to fewer exams—while CAMEL 3, 4, and 5 credit unions face a leaner, potentially more stressed NCUA.

🔑 Key Topics Covered:

• Overview of NCUA's recent briefing and CAMEL code performance
• Declines in CAMEL 3s, 4s, and 5s—what’s real and what’s merger-driven?
• Increased risk for complex credit unions ($500M+)
• Impact of staffing reductions on supervision intensity
• Why being a CAMEL 1 or 2 may now mean more operational flexibility
• What Kyle Hauptman said—and didn’t say—about being the only board member
• Speculation on NCUA’s future organizational structure

📌 Takeaways:

• CAMEL codes improved overall, but large credit unions saw some deterioration.
• NCUA’s downsizing and hiring freeze will shift how and when exams occur.
• Your credit union’s CAMEL code now plays an even bigger role in how much NCUA interacts with you.
• Good communication and organized documentation are essential if you're a CAMEL 3–5 credit union.
• The regulatory future may hinge on ongoing lawsuits and Supreme Court decisions about agency power.

⭐ Support the Show:

If you enjoyed the episode, please rate us 5 stars and share the podcast with your credit union colleagues. It helps us get the word out!

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The NCUSIF and the DIF are similar but different.  Today we do a deep dive on that and more.

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Trump’s Workforce Cuts Hit NCUA: What’s Changing, What’s Next

Show Notes

In this episode of With Flying Colors, Mark Treichel breaks down the biggest NCUA update in years — a Trump-era Executive Order has triggered a 20% voluntary staff reduction at the agency.

This May 22 board briefing outlines how the NCUA will operate with fewer people, a tighter budget, and a restructured exam program — all while staying focused on its core mission.

1. 20% Staff Reduction by Year-End
   NCUA is cutting 250 positions — driven by Executive Order 14210.
2. No Layoffs, All Voluntary
   Staff could opt for paid leave (NDRP) or a $50K incentive (NVSIP).
3. Program Exceeded Target
   297 enrolled; around 250 will actually depart — above the 217 needed.
4. HQ Was Hit Hardest
   30% of HQ staff enrolled vs. 20% in the regions — right-sizing in progress.
5. Hiring Freeze Through July 15
   Replacements limited to 1 hire for every 4 departures, only in top-priority roles.
6. Realignment Likely
   Signals point to fewer departments, streamlined reporting, and a leaner structure.
7. Extended Exam Cycles
   Well-run credit unions get more time between exams — up to 24 months in some cases.
8. $75M in Budget Savings Expected in 2026
   Minimal 2025 savings due to admin leave; big gains next year.
9. Agency Admits: 'Less with Less'
   NCUA is trimming low-value work and asking staff for smarter, simpler workflows.
10. Tech + Targeted Hiring Ahead
    Come 2026, investments in automation and skilled examiners are planned.

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Document of Resolutions can be complex or simple.  Regardless, they usually have many steps that NCUA doesn't realize, but you need to track.  We discuss the ins and outs of DOR project management in this archive episode.