Summary: Letters to Credit Unions 20-CU-05 Offsite Examination and Supervision Approach March 2020

Letters to Credit Unions 20-CU-05 Offsite Examination and Supervision Approach

March 2020

NCUA issued LTCU 20-CU-05 to outline for credit unions the agency’s approach to examination and supervision during the COVID-19 pandemic. Through May 1, 2020 NCUA examinations will take place offsite (see Priority #3 below). NCUA will strive to limit the agency’s burden on credit unions so that credit unions “may focus on providing uninterrupted service to their members.”

During this time, NCUA will focus on the following priorities:

Priority 1 — Credit Unions Experiencing Problems – NCUA’s supervision will focus on credit unions experiencing significant financial or operational problems.

Priority 2 — Contacting All Credit Unions – Between March 30 and April 10, NCUA will contact each credit union to establish a baseline of condition. NCUA will then periodically reach out to credit unions to touch base on the credit union’s condition.

***NASCUS Note: NCUA Regional Directors should be in communication with state regulators to coordinate contacts with state credit unions.

Priority 3 — Conduct Examinations Offsite – NCUA has moved to remote examinations. Unless the NCUA Executive Director approves a specific information request, credit unions will not be required to answer requests from NCUA examiners.

NCUA’s COVID-19 pandemic supervision plan’s key elements:

  • Exceptions to remote exams must be approved by the NCUA’s Executive Director.
  • NCUA may still go onsite to deal with urgent safety & soundness matters.
  • Credit unions are not required to provide documentation or make staff available for discussions with examiners unless approved by the Executive Director.
  • NCUA staff may contact a credit union for information needed to complete offsite exams. Examiners may also schedule virtual meetings with credit unions to discuss an examination if the credit union is willing and able to do so.
  • NCUA will generally not be issuing ROEs until further notice unless an existing exam was mostly completed before 3/16/20.
  • Once ROEs begin to be issued in the future, NCUA will factor into expectations for corrective action the impact of the pandemic on the credit union’s condition.
  • A credit union should work with its examiner if it requires flexibility in meeting deadlines.


NCUA will continue to coordinate with state regulators. Throughout this crisis, NCUA will factor the extraordinary impact of the pandemic on credit union operations and balance sheets.