Proposed Succession Planning Rule: July NCUA Board Meeting
Samantha: Hello, this is Samantha Shares.
This episode covers N C U Aâs new
proposed rule on Succession Planning
voted on at the July 18th Board Meeting.
The proposed rule passed
by a vote of 2 to 1.
The following is a word for
word real audio of that item.
This podcast is educational
and is not legal advice.
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And now the N C U A Board.
Our first item of business, we will
consider proposed rules, succession
planning, 12, uh, CFR parts 701 and 741.
Staff presenting are John
Berry, Policy Officer, Office
of Examination and Insurance.
And Ariel Pereira, Senior Staff
Attorney, Office of General Counsel.
Good morning, John, and
good morning, Ariel.
Always good to see you.
And, John, welcome to the
board table for the first time.
Thank you.
I understand that you're
going to do double duty today.
Uh, I am looking forward
to your presentation.
Please begin whenever you are settled.
Thank you.
Staff 1: Uh, good morning
Chairman Harper, Vice Chair
Hoffman, and Board Member Otzka.
My colleague John Berry and I are here to
present for your consideration a proposed
rule entitled Succession Planning.
Today's proposed rule is the
second NCOA proposal on this topic.
At its January 27, 2022 meeting,
the Board approved the proposed rule
to establish succession planning
requirements for federal credit unions.
This new proposed rule modifies the
earlier proposal based on the public
comments received and upon further
consideration of the issues involved.
The changes are designed to further
strengthen succession planning
efforts for both consumer federal
credit unions and consumer federally
insured state chartered credit unions.
Failure by a credit union board to plan
for vacancies in elected and appointed
positions as well as the transition of
its management can come with high costs.
The FIQ runs the risk of
creating a leadership vacuum.
It can disrupt operations, potentially
jeopardizing the credit union's
ability to adequately manage liquidity
risk, address cybersecurity threats,
or ensure continued compliance with
consumer protection, bank secrecy,
and other critical responsibilities.
The failure of FICUs to adequately
plan for succession poses a risk,
not only to individual credit unions
and their member owners, but to
the credit union system as a whole.
and to the National Credit
Union Share Insurance Fund.
Two factors have increased the relevance
of succession planning for credit unions.
First is the ongoing trend
of industry consolidation.
The number of FIQs has declined
steadily for several decades.
This decline is largely due to the
long running trend of consolidation
across all depository institutions.
In some instances, voluntary mergers
can be used to create economies
of scale to offer more or better
products and services to members.
However, an NCOA analysis found that
poor succession planning was either
a primary or a secondary cause for
almost a third of FICU consolidations.
Another reason for a heightened
focus on succession planning is the
ongoing, uh, the ongoing retirements
of the Baby Boom generation.
According to some sources, Approximately
10 percent of credit union chief
executive officers were expected
to retire between 2019 and 2021.
The NCOA does assess succession
planning as part of the
CAMEL's management component.
However, there is no NCOA regulation
requiring FICUs to implement a
formal written succession plan.
As a result, the NCOA lacks a full
complement of regulatory tools to
help address deficiencies in a credit
union's succession planning process.
Thank you.
The proposed regulatory changes are
designed to mitigate these risks, and
we believe are consistent with the
Board's statutory authority to ensure
a safe and sound system of cooperative
credit unions for its member owners.
To be clear, the proposed requirements
would not supplant the vital role
that credit union member owners and
their elected boards have in selecting
directors and other officials.
Neither would it dictate
management hiring processes.
The proposal focuses
on continuous planning.
and development to prepare credit
unions to handle vacancies and
transitions successfully and
in a safe and sound manner.
I'll now turn it over to John, who will
provide an overview of the proposed rule.
Thank you, Ariel.
Good morning, Chairman Harper, Vice
Chairman Hoffman, and Board Member Otsuka.
I would like to briefly summarize
the contents of the proposed rule.
As Ariel noted, the proposal
would apply to all consumer
federally insured credit unions.
including federally insured
state charter credit.
However, to the extent that a federally
insured state charter credit union
is subject to a state statutory or
regulatory requirement that conflicts
with the proposed rule, the NCA
will defer to the state requirement.
The proposed rule would require
the board of directors of the
federally insured credit union to
establish a written succession plan
that addresses specific positions.
At a minimum, the succession plan would
be required to cover members of the board
of directors, members of the supervisory
committee, management officials,
and assistant management officials.
Thank you The Federal Insured Credit
Union's Senior Executive Officers and any
other credit union personnel the Board
of Directors deems critical given the
size, complexity, and risk of operations.
The succession plan would also be
required to address the members
of the credit committee and loan
officers where such officials are
involved in the daily review of loans.
In addition, the succession plan
would be required to address the
Federal Insured Credit Union's
strategy for recruiting candidates,
The potential to assume each
of the covered positions.
The strategy must consider how
the selection of diversity among
the employees covered by the
succession plan collectively and
individually promotes the safe and
sound operation of the credit union.
The Board of Directors would be
required to review the succession plan
in accordance with the schedule it
establishes, but no less than annually.
The NCOA recognizes that circumstances
might require changes to the planning,
um, filling specific positions.
The proposed regulation text accommodates
this situation, but as with significant
deviations in budgets and in strategic
plans, it would be expected that the
board would be informed of changes
and the rationale for the changes.
And document them in its meeting minutes.
The proposed rule would also
amend NCA Regulation 701.
4b3, which contains education requirements
for federal credit union directors.
The proposed rule would require that
directors have a working familiarity
with the succession plan no later
than six months after appointment.
The expectation is for a federally
insured credit union to develop a
succession plan that is consistent
with its size and its complexity.
As an aid, the proposed rule includes
a sample template for a succession
plan that may be appropriate for some
smaller federally insured credit unions.
So, all federally insured credit
unions would benefit from it.
This concludes our presentation.
We would be happy to address
any questions that you have.
Chairman Todd Harper: John, deeply
impressed that you delivered
that with just one breath.
Um, and Ariel, thank you for your
presentation on the revised proposed
succession planning rulemaking.
This new proposal would require
federally insured credit union boards
of directors to establish succession
planning process for key positions.
This latest proposal also
builds on our prior efforts
to issue a rule in this area.
And as one of the commenters in our
prior rulemaking, uh, noted, the costs
associated with this rulemaking are,
quote, a burden worth bearing, unquote.
I could not agree more and
strongly support this rulemaking.
One of the NCUA's supervisory
priorities for 2023 was a review
of the credit union's approach to
succession planning for senior leaders,
including any written succession
plan the credit union established.
In a broader analysis of this exam
priority for a large subset of
examined credit unions, we found that
roughly one in four credit unions
either lacked Uh, succession plan or
had an inadequate succession plan.
That finding demonstrates
our need to act now.
Without a rule, we can only encourage
credit unions to adopt effective
succession plans through exam findings.
A rule would allow us to require such
planning through a document of resolution.
The continued health and success
and diversity of the credit union
system requires foresight by all.
That includes the NCUA and the
credit union leaders who serve as
the stewards of their member owned.
Uh, their members, owners,
financial security.
After all, as Benjamin Franklin
once reportedly said, if you
fail to plan, you plan to fail.
Therefore, it isn't surprising
that the term succession planning
includes the word success in the
first seven letters of the phrase.
Regardless of the economic environment,
the consolidation of credit unions has
been a constant over several decades.
One reason why, and Ariel, you noted
this, so many mergers are occurring is the
absence of effective succession planning,
especially in smaller credit unions.
We see that factor frequently
cited as a reason for a merger.
With this new proposal, the NCUA
has revised its 2022 succession
planning proposal to account for
the public comments we received.
Several commenters have asked for greater
details and specifics in the proposal.
This proposal provides those specifics.
What's more, the revised proposal
the Board is considering today would
strengthen succession planning efforts of
both Federal Credit Unions and Federally
Insured State Chartered Credit Unions.
Generally, the proposed rule would
require all Federally Insured Credit
Unions to have a succession plan that
covers the Board of Directors, the
Supervisory Committee, and And in any
other personnel, the Board of Directors
deems critical given the credit union's
size, complexity, or risk of operations.
The succession plan would also
address the members of the credit
union, uh, credit committee and loan
offices where such officials are
involved in the daily review of loans.
And the Credit Union's Board of Directors
would be required to review the succession
plan no less than annually, as noted.
it.
In a prior role before joining the NCUA
board, I served as a board member and
officer for a small non profit with a
budget of approximately 600, 000 a year.
Without any contractors or money
spent, that board was able to research,
develop, and approve an effective
succession plan within just a few months.
And that succession plan proved
effective a short time later when
the executive director departed.
All credit unions would
benefit from having effective
succession plans in place.
As part of this latest proposal, the
NCUA has developed a draft template.
This is an important piece for
use by smaller credit unions.
The NCUA Board would like to
receive comments from credit union
stakeholders on the template as well.
While the proposed rule would not
make it mandatory for credit unions
to use the NCUA template, the NCUA
Board recognizes that this Some
credit unions may experience a
cost if they don't already have a
succession planning process in place.
This template is intended to
reduce the time and effort
to develop a succession plan.
Any feedback from stakeholders to improve
the template would be very helpful.
The NCOA expects a credit union would
develop a succession plan that is
consistent with its size and complexity.
Therefore, smaller institutions may
have a simple succession plan that
addresses a few key leadership positions.
more complex institutions would
have more extensive plans for
a variety of critical roles.
In either instance, the succession
plan must consider how the selection,
skill, experience, and diversity of
the covered employees collectively
and individually promote the safe and
sound operation of the credit union.
And I can't say this enough.
Succession planning is vital
to the long term success of any
institution, including credit unions.
A credit union board's failure To plan
for the transition of its management
and key decision makers could come with
high costs, including the potential
for an unanticipated merger of the
credit union if key personnel depart.
In my view, it's better to maintain
many small credit unions serving a wide
variety of purposes and niche markets
than continuing to consolidate credit
unions into ever larger institutions.
What's more, a credit union's failure
to adequately plan for its succession
can pose risks to the system as a
whole and the share insurance fund,
which the NCUA is tasked to protect.
For these reasons, this revised succession
planning proposal is an important
step to ensuring credit unions plan
for and are successful in the future.
One last thing that I do
want to add, um, uh, before I
recognize the Vice Chairman, Mr.
Chairman.
Please know that we are very
open to changes in this.
We first proposed a rule
that was relatively easy,
relatively non prescriptive.
This rule is a little
bit more prescriptive.
If we need to move it back one way or
the other, dial it up, dial it down,
I am certainly open to working with
my fellow board members on that point.
This proposal will be open
for a 60 day comment period.
And I encourage all interested
stakeholders to provide
substantive comments.
That concludes my remarks, and I
now recognize the Vice Chairman.
Vice Chairman Kyle Hauptman:
Thank you, sir.
And thank you for your
presentation, Ariel and John.
I appreciate the hard work staff has put
into this proposed rule and, uh, updating
from the one we did two years ago.
Uh, I also agree, successor planning
is important and recognize it's
a real challenge for some credit
units, especially smaller ones,
uh, and I appreciate the intent
to assist small credit units.
I'm not convinced this
rulemaking is the best approach.
In fact, I'm concerned regulation in this
area could make things more difficult.
In January 2022, I voted in favor of a
proposed rule on succession planning,
partly because I was genuinely interested
in hearing from the stakeholders.
I appreciate the 26 commenters who
shared their thoughts and ideas, although
the proposed rule we're talking about
today is not the same one as 2022.
Stakeholder comments from then have
helped shape my decision on this new rule.
Today's rule is almost twice
the size of the previous one.
It now includes state chartered.
This is one reason why most of the
comments have been negative, both
on the old one and, and through more
informal channels, um, on this new one.
This plan also includes a
comprehensive template intended to
make things easier for credit unions.
I appreciate the effort put in.
I fear it may be daunting for many.
Additional data was included to justify
the need for a rule, but many of the
commenters pointed out the data on murders
went back 10 years and lacked the rigor
necessary to draw accurate conclusions.
Succession planning was included in
the 2023 Supervisory Priorities and
in the 2022 CAMELS Letter, and I'm not
sure if we've measured those results.
How many more credit unions added
or improved their succession
plans because of that guidance?
Do you have a handle on that?
We don't have the analysis.
Without measuring that impact, we can't
claim the guidance was ineffective.
Nor can we assume that new
guidance will be more effective.
We
certainly can't conclude that this
much longer rule of more paperwork
would be more effective than the
guidance which we haven't even
looked at to see if it did anything.
I'm inclined to agree with my former
colleague, Rodney Hood, who, in
voting against that proposal in
2021, said guidance is a better
way to address succession planning.
I recall a small credit union CEO, I
believe from one of the southern states,
telling me that if we passed a succession
planning rule, they would immediately
look to merge with another credit union.
That would reduce the
number of credit unions.
Not keep it higher because they felt
unable to satisfy the NCUA's requirements.
They would promote
murders, not reduce them.
We also heard from credit unions
that have successfully managed
leadership transitions but were
still against the 2022 proposed rule.
Their reasoning was twofold.
One, the rule would just be
another burden during exams.
And two, their prior successions that
went very well didn't necessarily
follow what they would have written
if NCUA had had a rule back then.
They'd feel pressured to follow
their plan that they wrote.
Or be penalized for not taking
their plan seriously, because they
would have on the record a plan they
gave to their regulator insurer.
The data didn't follow at all, so
what's the point of the next one?
Examiners already have the authority to
question the sufficiency of a federally
insured credit union's plan to manage
vacancies and executive positions.
This authority is valid in connection
to safety and soundness and
should be considered during exams.
However, mandating a prescribed succession
plan and the paperwork and process,
it goes beyond safety and soundness.
We're not talking about succession
planning, we're talking about fulfilling
NCUA's paperwork requirements.
The people who are very good at succession
planning still object to our rule.
I agree with commenters that
regulatory authority should not
substitute for sound board governance.
It should not replace or infringe upon the
fiduciary duty of the board of directors.
Simply requiring a succession plan
documentation will not address
the root cause of difficulties
in finding qualified candidates.
Ultimately, succession planning is
a key responsibility of management.
Credit union leadership must
address successional planning,
even if it is difficult.
The cooperative business model is meant to
give individual members a greater choice
regarding their credit union's direction.
When members are forced to vote for a
merger due to the lack of CEO succession
plan, they lose that choice and ultimately
they lose that native credit union.
There's nothing inherently
wrong with mergers, even as
part of a succession plan.
However, mergers should be deliberate,
intentional, and supported by membership.
The FDIC and the OCC have issued guidance
on succession planning, with the OCC
suggesting that it be a regular topic of
discussion among the Board of Directors.
When considering any proposed
rule, I'm concerned about the
needless burdens it may place on
already stressed credit unions.
So, today's vote is not about whether
succession planning is important.
Today's vote is not about whether some
credit unions out there really ought to
think more about succession planning.
It's about whether this rule, as
written We'll do more good than harm.
I don't feel it passes that test,
thus I'll be voting against it.
Thank you, Mr.
Chairman.
That concludes my remarks.
Chairman Todd Harper: I,
as always, I appreciate the
thoughtfulness of the gentleman.
Board Member Otsuka.
Board Member Tanya Otsuka: Thank you.
And thanks, John and Ariel,
for your presentation on the
NPR and succession planning.
Appreciate the work that you guys put in.
Um.
I also want to thank Chair Harper for
re proposing this rule and creating
the opportunity for us, uh, to
see comments on the most effective
version, um, which I, I do support.
So bear with me with this anecdote.
It does mention a bank.
Um, back in 2019, I recall a conversation
at a community bank conference
with the CEO of a very small bank.
He explained that the biggest
problem facing his institution was
attracting talent and training staff
to prepare for a change in leadership.
He and his board were approaching
retirement and he wanted to be
sure he could ensure the long term
viability of the institution with
the right people taking the reins.
And since that time, I mean, that, I
remember that conference, I remember
that conversation very vividly.
It really resonated with me because since
that time, I have had so many similar
conversations with credit union executives
and, and other credit union leaders
who are facing this same challenge.
Um, Transcripts As Chair Harper
mentioned, one of the goals of
the rule is to help ensure the
continuity of small credit unions.
Small credit unions are often left with
little choice but to merge when their
leadership retires or leaves because
of the difficulties associated with
finding new talent on short notice.
Or worse, and I think this is where
this rule can play a role, the
lack of leadership and the lack of
thoughtfulness results in serious
financial and operational problems, which
hurts members and puts the viability
of the entire institution at risk.
And that is what can also put
the Share Insurance Fund at risk.
You know, I know it's been discussed,
but yes, there are many credit unions
who are taking succession planning
seriously, who are doing that, who are
thinking ahead, but unfortunately there
are some that are not and we've seen that.
Um, and so I think that, that is where
our responsibility really comes into play.
And while of course our examiners
already look at management as part
of the supervisory process, a rule
provides clearer guidance to both
examiners and credit unions, um, on
what is expected and how to assess that.
for those sound managerial practices,
ensuring that credit unions don't fail
due to lack of leadership squarely
within, um, our responsibility of
ensuring a safe and sound system.
Um, you know, I, I know that we often, we
are concerned about, you know, You know,
more paperwork, nobody likes paperwork.
Um, I also don't like paperwork.
But I think we have a responsibility
as regulators to make sure that
our share insurance fund is safe.
And that's ultimately
where the buck stops.
The proposed rule would require federal
credit unions to establish and adhere
to processes for succession planning.
This is a gap in our regulatory framework
and one this proposal begins to fill.
And again, this Chair Harper's point,
you know, I am interested in seeking
comments on this revised version.
It would require credit unions to
be proactive in thinking through
how to maintain critical leadership
positions such as officers of the
board and senior management officials
to ensure continuity of operations.
This rule is not extremely prospective.
Prescriptive, excuse me, but instead
provides basic standards for developing
an effective succession plan.
And again, the NCUA understands the
differing needs of credit unions,
especially small and low income
designated credit unions, um, and
I, I understand that the staff wrote
the rule in mind, with that in mind,
uh, to provide enough flexibility.
And in that vein, I would like to
highlight that although it is not part
of the regulatory text, you know, I
think it is important for MDIs to account
for retaining their MDI status as they
think about succession planning, as the
composition of their leadership team is
a criteria to being designated as an MDI.
Um, I mentioned this at the top, the
board recently reaffirmed our commitment
to preserving MDIs and this is another
avenue through which we can execute this
goal and think about, um, you know, the
preservation of MDIs because I think they
are so important to so many communities.
So just, um, a couple questions for staff.
Um, many times we focus on how
our rules, including this one,
will, um, uh, sorry, excuse me.
Many times we focus on how our rules
will affect credit unions based on cost.
How much will this cost credit unions?
Um, which I think is an important.
However, can you speak to the potential
savings and benefits of this rule, um,
and ways that they can, it can provide
credit unions, uh, long term benefits?
How might this outweigh the
costs associated with developing
these plans, or at least at
the initial, uh, at the outset?
Staff 1: for your question.
Creating succession plans helps
credit unions prepare for key,
Managerial changes, whether
they're expected or unexpected.
Some potential benefits of succession
planning include maintaining business
continuity, reducing disruptions
in operations and member services,
knowledge transfer amongst employees,
cross training, and employee retention.
These benefits can provide a more
seamless transition following the loss
of a key employee, both internally
and for credit union membership.
As you know, the proposed succession plan
requirements will impose some compliance
costs on federally insured credit unions.
However, we believe the benefits
of a strengthened planning
process outweigh the costs.
While the benefits of the regulatory
changes are difficult to quantify at
present, should the rule be finalized,
we believe that its cost effectiveness
will be demonstrated over time.
We also know that the rule contains
several elements that mitigate the
potential costs on credit unions.
For example, the rule provides a
sample template that may be used by
credients in developing their plans.
The NCOA also offers training and
other resources to aid credients in
developing their succession plans.
For example, the NCOA has posted a
video series on succession planning
on its learning management system.
Board Member Tanya Otsuka: Great.
Thank you for that.
Um, I appreciate that.
Um, so I also think it's important
for credit unions to understand
what the expectations are when it
comes to how we evaluate management.
during the examination and
supervisory process, and that
includes succession planning.
Um, can you explain how this proposed rule
would provide clarity for credit unions
and examiners who are examining them?
Staff 1: Thank you for the question.
Currently, Letter to Credit Unions
22 CU 05 provides that succession
planning is a factor to consider when
assessing the management of a credit
union under the CAMELS rating system.
Accordingly, the N2A currently assesses
succession planning under the CAMELS
management component as part of the
overall safety and soundness evaluation
of the credit union's operations.
However, there is no regulation requiring
federally insured credeans to implement
a formal written succession plan and
as a result, a credean's failure to
establish a plan or the inadequacy of its
succession planning process will not in
and of itself, uh, warrant an examiner
finding or a document and resolution item.
Uh, the, the absence,
the absence of the specific regulation
on this topic also means that there
are no requirements as to the,
what constitutes an acceptable
succession plan and the regulation
would therefore establish a needed.
Clearly articulated and
consistently enforceable set of
succession planning standards.
Board Member Tanya Otsuka: Gotcha.
Thank you for that.
Thank you for your responses and
adding further context as to, uh,
why we are proposing this rule, um,
and why it's needed to help preserve
our system of cooperative credit.
Um, thanks again.
I turn it back over to Chair
Chairman Todd Harper: Harper.
Thank you so much.
Um, one question I want to build on
off of, uh, the questions that you had.
Um, oftentimes I hear with small
credit unions, the manager of 30
years announces she's going to retire.
Her salary has remained relatively flat
and isn't keeping up with market rates.
Could a benefit of this proposal
be benchmarking and helping to the
credit union to ensure that it's,
it's growing and building itself
in a way and its budget that it can
attract talent at a later point?
Staff 1: Absolutely.
Understanding the cost
of replacing the skills.
It's unnecessary to meet the, the
roles that that person, that key
employee fills is, is absolutely.
Um, necessary for credit unions to
be forward looking and, and not be
looking at that when the time comes.
Chairman Todd Harper: Yeah.
I, I also know that there was an
initiative a few years ago, um, to
bring in young NBAs who had recently
completed their training into the,
uh, the credit union, uh, system.
Uh, small credit unions are a perfect
place for a young, uh, person with
executive training to, to cut their
teeth and, and, and to grow overall.
Five minutes.
Okay.
Yeah, of course.
Vice Chairman Kyle Hauptman:
Uh, only because you jumped in.
Yeah, no, absolutely.
Um, the FDIC has no similar
rule, is that correct?
Okay.
Tanya, you were with the FDIC for years.
Do you know why they don't have
a rule like this forcing banks to
fill out this kind of paperwork?
Board Member Tanya Otsuka: Not off the top
of my head, but there are a lot of rules
that the FDIC doesn't have that we have
and that we have that they don't have.
And so, you know, I think that given
some of the things that we've seen,
you know, Um, with credit unions, I do
think that this proposal makes sense for
us to again solicit more feedback on.
But yeah.
But yeah.
Vice Chairman Kyle Hauptman: We don't
have to copy the FDIC by any means.
I'm actually trying to figure
out if it's a good idea.
When you were at the FDIC, did
you advocate for such a rule?
Board Member Tanya Otsuka: Um,
at the, while I was at the FDIC,
I was a staff attorney and, uh,
Vice Chairman Kyle Hauptman: no, I did not
Board Member Tanya Otsuka:
advocate for such a rule.
Vice Chairman Kyle Hauptman: Okay.
But Congress can put a rule
like this any time they wish.
When you worked for the Chairman
of the Senate Bank Committee,
did you suggest that they put
forth legislation to do this?
Board Member Tanya Otsuka: I don't
know how my work on the Senate
Banking Committee and whether I
advocated for something like this
or not has any bearing on whether
I support the proposal right now.
Vice Chairman Kyle Hauptman: It
doesn't have any bearing on it,
but good ideas are good ideas.
And one regulatory body forcing
them, or Congress can do it.
We wouldn't even be talking
about it if Congress mandated it.
Uh, we have to do what Congress wants.
So, I'm just saying if it was a good idea.
Uh, at another agency, it seems
like it would be a good idea here.
If it was a good idea here, it would
be a good idea for Congress to do it.
Who probably should be making
most of these decisions anyway.
That's what I wanted to mention.
But, in terms of attracting talent,
small credit unions, it is hard.
One great way to do it is
make the job less of a pain.
A lot of these are labors of love.
You mentioned a person whose
pay hasn't risen in years.
Hey, would you like to run a credit union?
How's the pay?
Not very good.
What do you do?
Well, I spent an enormous amount of time
filling out paperwork for my regulator
and rushing to meet their deadlines.
That's not a job that attracts a lot.
Why, uh, is it because you're risky?
No, we have 800, 000 in assets.
We're a microscopic risk to the
fund, but still we are forced
to do all this paperwork.
So if we really want to attract talent,
we can make the job more attractive and
it's UA has some role to play in that.
I'm done now.
Chairman Todd Harper: Fair enough and,
um, just one, uh, two final points.
One is, Just, just because one
agency hasn't acted first doesn't
mean that we can't act first.
Absolutely.
Um, uh, and second, I do want to
reiterate this, um, to the Vice Chairman.
This is an open, fluid process, um, I,
you know, at the end of the day where we
ultimately land with something in final.
Uh, I, I want to share the
commitment that, you know, we will
continue to have the discussions
and where we might be able to land.
The intent here is, is a good one.
Um, the execution is what
I'm hearing, um, uh, overall.
Board Member Otsuka, is there a motion?
Board Member Tanya Otsuka: I move
that the board proposed proposed rules
succession planning 12 C FFR part 7 0 1
and 7 41 for a 60 day comment period as
attached to the board action memorandum.
Chairman Todd Harper: Is
there a second to the motion?
Hearing none.
I second the motion.
All those in favor say aye.
Aye.
Aye.
All those opposed say nay.
Aye.
The ayes have it and let the record
show that the motion passes two to one.
Thank you both.
Samantha: This concludes this item.
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.
