Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

Hello, this is Samantha Shares.

This episode covers N C U A’s Board Member
Tanya Oatska’s Remarks at Treasury’s

Roundtable for Providing Financial
Access to Justice-Impacted Individuals

The following is an audio
version of those remarks.

This podcast is educational
and is not legal advice.

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Before the remarks you may
wonder what the definition of a

Justice-impacted individuals is.

Justice impacted individuals include those
who have been incarcerated or detained in

a prison, immigration detention center,
local jail, juvenile detention center, or

any other carceral setting, those who have
been convicted but not incarcerated, those

who have been charged but not convicted,
and those who have been arrested.

And now the remarks.

As Prepared for Delivery on
April 24, twenty twenty four

Good afternoon and thank you to
Deputy Secretary Adeyemo and everyone

at Treasury for convening this
critical and timely discussion.

The credit union system is an important
and unique part of our financial

system because it is centered around
a cooperative business model that

is driven not by a profit motive
or shareholder interests, but by

the needs of credit union members.

Many credit unions were created to
serve communities that the traditional

financial system has long forgotten.

So, it is fitting that the NCUA and
credit unions are at the table when

it comes to providing financial
access to justice-impacted individuals

and marginalized communities.

One of the challenges justice-impacted
individuals face when looking to

open a bank account is the lack of a
driver’s license or other IDs typically

preferred or required by banks.

The NCUA previously issued an opinion
indicating that it is acceptable to use

an individual taxpayer identification
number (ITIN) to open an account, and

credit unions have led in this space.

For example, Stepping Stones Community
Federal Credit Union, which is

here today, serves justice-impacted
individuals at three local prisons

in Delaware by partnering with the
Delaware Department of Corrections.

They use ITINs to open accounts for
members and work with the business office

at the prison to gain identification
information to establish the account.

The prison provides documents certifying
the authenticity of the members and names.

As of November 2023, the
program had 482 active accounts

totaling more than $300,000.

Several credit unions in New York City,
including the Lower East Side People’s

Federal Credit Union, Neighborhood
Trust Federal Credit Union, Urban

Upbound, and USAlliance currently
accept IDNYC, a municipal ID card that

New York City started issuing in 2014.

It is available to all residents of New
York City, including people from some

of the most vulnerable communities,
such as those who are unhoused,

justice-impacted individuals, immigrants,
and others who may have difficulty

obtaining a government-issued photo ID.

Lastly, the NCUA recently
updated its policy on preserving

minority depository institutions
(MDIs) -- a main priority for me.

As a regulator whose focus is to ensure
fair, safe, and accessible banking

services to credit union members, the
NCUA is committed to preserving minority

depository institutions, providing
technical assistance and support,

and encouraging new ones to form.

M D I’s have a long history of bridging
the gap to underserved communities.

Many of the credit unions doing the
work of helping justice-impacted

individuals are M D I’s.

Indeed, four out of the five credit unions
I mentioned today are designated MDIs.

I am encouraged by the steps the
agency and credit unions have

taken to address the financial gap
justice-impacted individuals face.

However, we know that more needs to
be done, and I look forward to hearing

from you all on how we can continue to
expand access and economic empowerment

to more people and communities.

Thank you.

This concludes the remarks.

If your Credit union could use assistance
with your exam, reach out to Mark Treichel

on LinkedIn, or at mark Treichel dot com.

This is Samantha Shares and
we Thank you for listening.