Dear Editor,

Mr. Fryzel is just plain wrong in his assessment of moving to an 18-month exam cycle. This is not a case of monkey see, monkey do. It is very relevant that the NCUA follow the FDIC, as appropriate. To be clear, NAFCU and Congress are not asking the NCUA to blindly follow the FDIC. NAFCU has long asked the NCUA to change its exam cycle for well-run healthy credit unions, as appropriate. The fact that the FDIC is going to do the same for banks puts credit unions at a disadvantage. Exams cost time and money, both to the credit union and to the NCUA. Those resources should be put where they are really needed.   

I am not a regulator, but I have personally read every single material loss review that the NCUA has publicly available. Failure of an institution is usually due to a whole host of factors. That is what the CAMEL system is designed to measure. The exam looks at the credit union comprehensively. Unless there is massive fraud, a credit union cannot go from a 1 to a 5 overnight or even in 18 months. And if it did, the signs would show up on the quarterly financials and the NCUA could step in, as appropriate. 

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