With Flying Colors

This week we're bringing back an archive episode of With Flying Colors that remains just as relevant today as when it was first recorded.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.

www.marktreichel.comhttps://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

In this special archive replay of With Flying Colors, Mark Treichel is joined by his colleagues Steve Farrar and Todd Miller — both former senior leaders at NCUA — to discuss why regulators sometimes ask to meet directly with a credit union's board of directors without management present.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 TakeawaysA 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.ResourcesLearn more about how Credit Union Exam Solutions supports boards and executives: marktreichel.comSubscribe to With Flying Colors on your favorite podcast app for more insights on navigating NCUA exams.

www.marktreichel.comhttps://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 yearsWhich offices are hit hardest by the cutsHow the hiring freeze and buyouts are creating exam disruption and turnoverWhy credit unions may see fewer exams, but bumpier interactionsThe role of technology investments and the $10 million “transformation fund”Why the industry is cheering now — and why the pendulum will eventually swing backTakeaway: 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.

www.marktreichel.comhttps://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 & LinksLearn more about MBFS: mbfs.orgListen to Mark Ritter's podcast Credit Union Conversations on all major platforms.Connect with Mark Ritter on LinkedIn.

www.marktreichel.comhttps://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.

www.marktreichel.comhttps://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:

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Credit Unions vs. Banks: What Q2 Data RevealsIn 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:

www.marktreichel.comhttps://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.

www.marktreichel.comhttps://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.

www.marktreichel.comhttps://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 expensesNCUA's hyperfocus on annual review processes Empty office buildings near NCUA headquarters

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Episode SummaryIn 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 EpisodeThe latest on the NCUA board shake-up: Harper, Ska, Trump, and the courtsHow the Humphrey's Executor Supreme Court case could upend federal regulatory appointmentsWhat NCUA's staff buyouts and hiring freeze mean for supervision and examinationsWhy communication between credit unions and regulators is more critical than everInsights on America's Credit Unions' new CEO Scott Simpson and what his leadership could signalThe future of CFPB oversight and how credit unions should prepare for the next compliance pendulum swingWhy the upcoming NCUA strategic planning town hall is a chance for credit unions to speak upSome football predictions to lighten the mood — Ravens, Bears, and Vikings fans, take note

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/OPERATIONAL RISKSCyber incident response planning essentials Communication strategies for cyber incidents Legacy system conversion nightmaresNCUA's helpful approach to cybersecurity findings Core system conversion best practices

www.marktreichel.comhttps://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 changeThe importance of a “gatekeeper” role to coordinate all examiner requestsHow 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 NCUATips to avoid last-minute scrambles and make your exam go smootherWhether 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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/INTEREST RATE ENVIRONMENTFed policy uncertainty and tariff impacts Yield curve normalization: -35 to +50 basis points CD composition shift: 13% to 28% of depositsCredit unions adapting to "new normal" Investment portfolios still 6-7% underwater Examiner demands for enhanced stress testing Cost vs. value of regulatory requests

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ETAIL CREDIT PERFORMANCE Student loan payment resumption impactMixed economic signals across states24 vs 26 states: unemployment trends Generational differences in borrowing behavior Venmo revolution: 85% of users under 40, $342B in Q1 transfers

www.marktreichel.comhttps://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.

www.marktreichel.comhttps://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

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Home Mortgage Disclosure Act (HMDA) Basics

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA in Limbo: What the Board Shakeup Means for Credit UnionsEpisode Date: July 28, 2025 Host: Mark Treichel Episode SummaryThe 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 CoveredThe Legal Drama TimelineTrump's firing of Harper and OtsukaFederal court ruling that Trump violated the Federal Credit Union ActWednesday court decision ordering immediate reinstatementWeekend stay blocking their returnLikely Supreme Court appeal aheadLast Thursday's Board Meeting AnalysisHarper and Otsuka's awkward return (Harper via video, Otsuka in person)Three "safe" briefings: AI, CLF, and the new Ombudsman officeThe "500-pound elephant in the room" that everyone avoidedWhy staff is in an impossible positionWhat's Next for the Board80% odds Harper and Otsuka don't return permanentlyKyle Huffman's term expires next monthPossibility of Trump appointing 2-3 new board members before year-endImpact of onboarding multiple new board members simultaneouslyInspector General Report BombshellCritical Infrastructure Division Director scandal exposedFalse statements on background investigationsSending sensitive NCUA documents to personal emailUnauthorized outside employment while at NCUAPossible connection to unauthorized AI usageBudget ImplicationsTwo-year budget cycle hanging in limboNo mid-year budget briefing despite historical precedentHow a Republican board majority might cut costs to credit unionsAugust board meeting hiatus continues traditionNotable 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 ContentMark 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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Global Cash Flow.  What is it and why does NCUA care?

www.marktreichel.comhttps://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

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Credit Union Roundtable: Mid-Year Risk Reports - Our Take on What it Means for CUsEpisode DescriptionIn 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 GuestsSteve 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 FacilityTodd Miller - 34-year NCUA veteran, former Director of Special Actions in the Western Region, capital markets specialistDennis Bauer - Recently retired CFO of Ideal Credit Union (grew from $100M to $1B+ during his tenure), former NCUA examinerKey Topics CoveredCommercial Credit Risk (9:00)Rising delinquencies in commercial real estateImpact of interest rate resets on variable rate loansOffice building vacancy concerns post-COVIDNCUA's increased focus on annual review processesNew concentration limit requirements by property typeRetail Credit Performance (18:00)Student loan payment resumption impactsGenerational differences in borrowing behaviorAuto loan portfolio shrinkage trendsRegional economic performance variationsInterest Rate Environment (24:00)Yield curve normalization effectsCD composition changes (13% to 28% of deposits)Underwater investment portfoliosEnhanced stress testing requirements from examinersOperational Risk Challenges (33:00)Cybersecurity incident response planningLegacy system conversion risksCommunication strategies during cyber incidentsCost vs. benefit analysis for security upgradesFraud & Payment Systems (39:00)Elder fraud targeting (timeshare scams example)ATM jackpotting and skimming schemesVenmo usage statistics (85% under 40, $342B in Q1 transfers)Third-party payment system competitionBSA/AML Compliance Burden (45:00)Staffing challenges for smaller credit unionsCreating collaborative BSA officesCommittee-based approach to complianceGrowth & Competition (46:00)Slow loan growth trendsCredit unions gaining deposit market share vs. banksMoney supply impacts on deposit availabilityPricing strategy considerationsAI & Technology Adoption (50:00)Model validation requirementsThird-party vendor risk managementNCUA's AI policy challengesCompetitive advantages vs. compliance risksKey TakeawaysCommercial Real Estate Monitoring: Credit unions should closely watch their CRE portfolios, especially office properties and loans approaching rate resetsStress Testing Expansion: Expect more detailed scenario analysis requests from NCUA examiners across interest rate and liquidity risksOperational Risk Investment: Cybersecurity and system conversion planning require significant ongoing investment and expertiseGenerational Shifts: Adapting to younger members' payment preferences and borrowing behaviors is critical for long-term growthAI Adoption Strategy: Credit unions need to embrace AI while implementing proper model validation and risk management frameworksResources MentionedOCC Spring 2025 Risk Report (link in show notes)Credit Union Regulatory Guidance podcast (AI-powered audio summaries)Attorney General scam awareness resourcesNotable 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 planningContact InformationMark Treichel - Host, With Flying Colors Podcast Consulting Services: Available for credit union risk management and regulatory guidanceNext Episode PreviewStay 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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Is your ALCO Committee structured optimally?  We can help you figure that out with this episode.

www.marktreichel.comhttps://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 growthRebalancing liquidity post-rate hikesStrategic use of CDs, borrowings, and non-member fundingPricing risk wisely (and knowing when not to chase volume)Mergers of equals and the evolving landscape of consolidationNew developments in ALM First's services—including on-demand liquidity tools and talent retention strategiesWhether you're a CEO, CFO, or board member, this episode is packed with practical takeaways on managing risk and optimizing performance in uncertain times.

www.marktreichel.comhttps://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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/ Did the Trump Firings Cause a Regulatory Crisis at the NCUA? Warren & Waters Demand AnswersEpisode OverviewMark 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 CoveredThe Firings and Immediate AftermathApril 16, 2025: Trump fires NCUA Board members Todd Harper and Tanya OtsukaOnly Chairman Kyle Hauptman remains on the three-member boardQuestions arise about the agency's ability to function without a quorumCongressional ResponseElizabeth Warren & Maxine Waters demand answers about NCUA's operationsLetters sent to both the NCUA Inspector General and Board Chairman HauptmanFocus on whether single-member board can legally conduct agency businessThe "Essential Functions" ControversyNCUA relies on delegation authority allowing "essential functions" during emergenciesProblem: No clear definition of what constitutes "essential"Historical context from early 2000s when similar situation occurred with Dennis DollarActions Taken Under QuestionThe IG identified 11 Board Action Memorandums (BAMs) approved by Hauptman alone:Semi-annual agenda establishmentBoard appeal hearing approvalSchedule policy career petitionDeferred resignation program approvalSSP performance standards changesNCA delegation revisionsExamination schedule policy revisionShare insurance rule simplification commentsPersonnel appointments and reassignmentsActing Inspector General appointmentBoard meeting transcript approvalBonus controversial action: Credit union conservatorshipLegal and Political ImplicationsRegulatory crisis: Agency's own regulations require two board members for actionPolitical undertones: Warren designed single-director CFPB but opposes single-member NCUAPending lawsuits: Harper and Otsuka challenging their firings in courtPotential solutions: Trump could appoint new members or court could rule on legalityExpert AnalysisMark Treichel provides insider perspective as former NCUA Deputy Executive Director who helped create the "essential functions" delegation in the early 2000s.Key Questions RaisedWhat 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 WatchJuly 7th: Deadline for Hauptman's response to congressional demandsOngoing: Court cases challenging the firingsFuture: Potential new board member appointments

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/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

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA often asks what a credit union's Risk Appetite is, but doesn't provide much if any, guidance on the topic. We do.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA requires some level of management review every exam before you see it.  We explain why and how that impacts you.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/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:

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The NCUSIF and the DIF are similar but different.  Today we do a deep dive on that and more.

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

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/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.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/In this episode of With Flying Colors, host Mark Treichel reconnects with Ryan Donovan, President and CEO of the Council of Federal Home Loan Banks (FHLB). Ryan returns to discuss the evolving role of the FHLB system, its relationship with credit unions, and how liquidity is much like oxygen—often unnoticed until it's urgently needed.Ryan and Mark explore:The history and mission of the Federal Home Loan Bank system.How FHLB provides daily liquidity to its members and why it's a critical tool—not just in times of crisis.The difference between the FHLB system and the Federal Reserve as liquidity sources.How FHLB and credit unions are "cooperative cousins" working together to strengthen communities.The system's record-breaking $1.2 billion commitment to affordable housing initiatives.Director Bill Pulte's early signals and what his leadership at FHFA could mean for FHLB and the credit union system.Why credit unions, especially smaller ones, should consider joining the FHLB system to strengthen their balance sheets and enhance loan capacity.Ryan also highlights recent research showing that FHLB membership helps credit unions grow faster, remain competitive, and support their members more effectively—all while maintaining safe and sound lending practices.Key Takeaways:FHLB isn't just a lender of last resort—it's a daily liquidity partner.Affordable housing remains a priority, with FHLB surpassing its statutory requirements.Credit unions can amplify their impact by leveraging the FHLB system.Regulatory dynamics are shifting, but FHLB's mission remains steady: Keep liquidity flowing to local lenders.Resources Mentioned:Council of Federal Home Loan BanksFHLB & Credit Union Liquidity Research by Filene Research InstituteFollow Ryan Donovan on LinkedInConnect with Mark Treichel:LinkedIn: Mark TreichelWebsite: Credit Union Exam Solutions

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA is hitting corporate governance hard.  In this episode we discuss why and what to do if it happens to you.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/This post on LinkedIn led to this podcast:  Growing this program from an idea, to an incredible technological platform is far and away the most rewarding venture of my career. The platform has allowed our company to think and dream of bigger ideas. It's functionally changed the lives of so many of us. To say I'm proud of this achievement is an understatement. A huge kudos to Alloya Corporate FCU for taking a risk on a young kid with some wild ideas and a sincere thank you for the team who made it all possible.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The dreaded organizational review Document of Resolution or worse yet LUA.  What it means and what you should do.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/NCUA has reopened the Succession Planning Rule for public comment.  In this episode JT Blau and I discuss the rule and its requirements.

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Presidential Power and Independent Agency Autonomy: The 2025 NCUA Board Removal CaseI. Legal and Constitutional FrameworkA Constitutional Showdown BeginsFrom "At Pleasure" to Independence: The 1978 RestructuringThe Humphrey's Executor Precedent: Protecting Independent AgenciesUnitary Executive vs. Congressional DesignThe Narrowing Path of Agency IndependenceSwan v. Clinton: The Precedent That Wasn't Quite50 Years of Respect for Fixed TermsII. The NCUA's Specific Structure and FunctionsThe Removed Regulators: Harper and OtsukaThe NCUA: A Core Financial RegulatorExecutive Function or Independent Regulation?The NCUSIF: Owned by Credit Unions, Not GovernmentThe Central Liquidity Facility: A Link to TreasuryOperating Without a QuorumFinancial Stability at StakeIII. Litigation Strategy and Broader ImplicationsSix Legal Theories for VictoryDavid vs. Goliath: The Legal TeamThe Long Road to the Supreme CourtBeyond NCUA: Implications for the Administrative State

Conservatorship: When NCUA Removes the Board & What You Need to KnowEpisode Summary:In this special episode, hosts Mark Treichel, Steve Farrar, and Todd Miller dive into the high-stakes world of NCUA conservatorships—when the agency steps in to remove a credit union's board and take control. Drawing from their extensive experience handling some of the largest conservatorships in NCUA history, they provide insider insights on:What conservatorship means and when it happensThe role of the NCUA as both regulator and conservatorWhy NCUA often opts for conservatorship over cease-and-desist actionsThe challenges of managing a conservatorship from both a regulator's and a credit union's perspectiveSuccess stories and lessons learned from past conservatorshipsThe hosts reflect on the intensity, challenges, and rewards of the conservatorship process, including the balance between protecting the NCUSIF (National Credit Union Share Insurance Fund) and serving credit union members. Whether you're a credit union executive, regulator, or industry observer, this episode delivers valuable insights into one of the NCUA's most powerful enforcement tools.Key Quotes:

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/The NCUA's boardroom has been rocked. Two board members fired. DOGE staff roaming the halls. Rumors of a regulatory consolidation swirl. In this must-hear episode, Mark Treichel is joined by former NCUA Board Member Geoff Bacino and former NCUA Congressional Affairs Director John McKechnie to unpack one of the most chaotic weeks in recent credit union regulatory history.From unprecedented dismissals to the looming question of NCUA's independence, we cover:

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/White House press secretary Karoline Leavitt defended the firings, saying, “President Trump is the chief executive of the executive branch and reserves the right to fire anyone he wants.”Warren:“President Trump just fired two Board Members at the National Credit Union Administration in his continued attack on American consumers. This is the latest attempt by Trump to skirt the rule of law, undermine independent agencies, and illegally purge the government of those who work for the American people.”

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/Episode Overview:In this episode of With Flying Colors, Mark Treichel tackles two hot topics ahead of the upcoming NCUA Board meeting:The Staff Buyout Program: With 145 FTEs already accepting voluntary separation packages—roughly 12% of NCUA's workforce—Mark explores the deeper implications. Could the agency be targeting a symbolic sub-1,000 FTE threshold? Poll results and inside intel help paint the picture.The Wildfire Relief Briefing: Mark offers context for why the interagency appraisal relief rule—issued in January—is now being briefed to the NCUA Board in April.Plus, a timely listener tip leads to a discussion of Treasury Secretary Scott Bessant's recent remarks about reshaping regulatory culture—calling for more transparency, better tailored supervision, and a possible redefinition of "safety and soundness."

Episode Summary: In this episode of With Flying Colors, host Mark Treichel is joined by former NCUA capital markets expert Todd Miller to discuss the latest updates to NCUA's Interest Rate Risk (IRR) Supervisory Framework. Following NCUA's recent stakeholder webinar, we break down key takeaways, including changes to risk categorization, the elimination of the extreme risk rating, and how these updates impact credit unions navigating today's economic landscape.What You'll Learn in This Episode: ✅ The history and evolution of NCUA's NEV framework ✅ Why NCUA eliminated the “extreme risk” category and what it means for credit unions ✅ The role of examiner judgment in assessing interest rate risk under the new guidance ✅ How credit unions can mitigate risk and avoid a Document of Resolution (DOR) ✅ The growing importance of liquidity management and how credit unions should prepare ✅ Why examiner scrutiny of IRR is increasing, despite the removal of automatic DORsKey Takeaways from the NCUA Webinar:

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/A quick-hit episode this week! Mark shares thoughts on Duke's March Madness collapse, the rise of Rodney Hood at OCC, Jim Nussle's pending retirement, and NCUA's buyout offers. Plus, a few takes on market volatility, sub debt approvals, and the ever-shifting dynamics at the NCUA Board.Topics Covered:Duke's tourney loss and dynasty hateRodney Hood's possible FDIC moveJim Nussle's retirement newsNCUA staff buyouts and exam slowdownsThe case for sub debtMarket drops and flight to quality

Episode Title:NCUA: Can You Put That in an Examiner Finding, Not a DOR?Episode Summary:In this episode of With Flying Colors, host Mark Treichel is joined by Steve Farrar and Todd Miller to unpack the complexities of NCUA examinations, examiner findings, and documents of resolution (DOORS). They dive into what makes an issue rise to a DOOR, how credit unions can negotiate findings, and why corporate governance is becoming a focal point in exams.With their decades of experience inside NCUA, Mark, Steve, and Todd share insights on how credit unions can better navigate the regulatory process, avoid unnecessary compliance burdens, and strengthen their governance structures. If you've ever wondered why something lands in a DOOR rather than an examiner finding, this episode is for you!Key Topics Covered:✔️ What qualifies as an examiner finding vs. a DOOR? ✔️ How credit unions can respond to and negotiate with NCUA ✔️ The rising focus on corporate governance in examinations ✔️ How unresolved examiner findings escalate over time ✔️ The role of supplementary facts in the examination process ✔️ Understanding regional director letters and enforcement trendsGuest Information: