CUNA Comment Letter
NCUA Examination Survey
September 10, 2003
Mr. Neil McNamara
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3428
Dear Mr. McNamara:
The Credit Union National Association (CUNA) appreciates this opportunity to comment on the Examination Survey, which NCUA is submitting to the Office of Management and Budget for review and clearance under the Paperwork Reduction Act of 1995. CUNA, a national trade association, represents more than 90 percent of the nations 10,000 state and federal credit unions.
This Survey, which NCUA furnishes to credit unions following the completion of an examination of their credit union, is important because it allows the credit union the opportunity to provide opinions, comments, and suggestions concerning the examination process. NCUA uses the information to evaluate and improve the examination process.
We commend NCUA for updating the Examination Survey in January 2003 to center on the agencys new risk-focused examination process. We also commend NCUA for revising the form to include a focus on communication between the examiner and the management and officials of the credit union throughout the examination process.
We offer the following two suggestions that we believe will further improve the Survey:
- The Survey requests an assessment as to whether the examination provided management with sufficient direction for improving risk management at the credit union. We suggest that this request be subdivided to request an assessment on this subject specifically with regard to loans, investments, and deposits. This should elicit more precise information for NCUA.
- The Survey should specifically request an assessment as to whether the examiner was sufficiently prepared, specifically whether he or she knew the credit unions financial position before commencing the exam.
Thank you for the opportunity to share our comments. If you have questions about this letter, please feel free to contact me at (202) 508-6736.
Mary Mitchell Dunn
Associate General Counsel
and Senior Vice President