The National Federation of Community Development Credit Unions worries that new NCUA examiners may not be trained in the issues particular to the CUs many will be sent to examine.

"In a number of meetings over the last ten years, agency staff has confirmed that new or less experienced examiners are often assigned to small and low-income credit unions, presumably because these are less complex institutions that represent a smaller degree of material risk to the NCUSIF," National Federation CEO Cliff Rosenthal wrote in a recent letter to NCUA.

"Because low-income credit unions and CDCUs often do not fit the mold or demonstrate the ratios and operating characteristics of other credit unions, the examination process has often been a rather rocky one," he said. "As some of our CDCUs have put it, they have needed to 'educate the examiners.'"

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While credit unions have reported that implementation has not always been uniform, Rosenthal praised the agency for its efforts to date, but stressed the need for more consistent implementation.

"We appreciate the leadership that you and your fellow board members have shown in developing the supervisory letter on examination of low-income and community development credit unions," he said.

"Given the stress in the credit union industry, and especially in view of the vulnerability of many of our smallest institutions, it is especially important that new examiners are well trained on this document [and we] hope that this training will be an integral and significant part of the orientation of new, as well as existing, NCUA examiners."

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