Two Things I Wanted You to Know before I Travel to Grandma’s House

April 13, 2017 at 8:58 am Leave a comment

I just went through my email folder containing ideas for future blog content and there are two things I would like to share with you before heading off to God’s country (i.e., Long Island to visit my family).

First, I have been remiss in failing to inform my faithful readers that the New York State Department of Financial Services recently approved a Wild Card application that will allow state chartered credit unions to limit the oath taking requirements to board members. Let me explain.

Section 468 of the New York State Banking Law requires each “director, officer and member of a committee” to own a credit union share and to take an oath of office when appointed. In recent years this requirement has become increasingly burdensome to state chartered credit unions; it has been interpreted as applying not only to board directors but also to individuals such as lending officers.

The approval of the Wild Card power, under which state chartered credit unions have no greater oath obligations than their federal counterparts, is important not only because it helps state charters operationally, but because it is another example of how Superintendent Vullo is backing up her public commitment to helping makes the state charter option as attractive as possible. Remember, all credit unions in New York State, irrespective of their charter type, have an interest in a strong dual-chartering system.

The second thing I would like you to know was that NCUA recently released a supervisory letter to examiners updating the risk factors that should be considered when evaluating credit union compliance programs. The update reinforces a guidance issued by NCUA 15 years ago when it began to implement a risk focus examination process designed to eliminate the need for annual examinations of well performing credit unions. With the NCUA once again expanding its examination timeline it makes sense to revisit the criteria once again.

On that note, I will be back on Tuesday – enjoy the weekend

 

Entry filed under: Compliance, New York State. Tags: , , .

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Authored By:

Henry Meier, Esq., General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association.

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