NEWS: The NCUA has released its 2026 Supervisory Priorities, outlining where examiners will focus their attention this year as part of a risk-based supervision approach tailored to individual credit union profiles. This year’s guidance reinforces the agency’s commitment to clarity and transparency under its No Regulation-by-Enforcement policy, while prioritizing safety and soundness.
The NCUA’s letter to credit unions outlines the Agency’s priorities for 2026 and provides information to help credit unions prepare for exams. NCUA will continue to conduct defined scope exams in most federal credit unions with assets of $50 million or less, and risk-focused exam procedures for all other credit unions.
Some of the key highlights include:
- Lending – NCUA examiners will focus on credit union lending and related risk-management practices. Specific review areas will focus on institution-specific risks and may include the sufficiency of credit administration, including loan underwriting, loss mitigation programs (including loan modifications and workouts), Allowance for Credit Loss reserves and methodologies, and charge-off practices. NCUA examiners will review portfolio monitoring, including the management of any material credit risk concentrations. When lending, servicing, or collection functions are outsourced, examiners will also assess third-party risk-management practices as appropriate.
- Sensitivity to Market Risk and Liquidity – NCUA examiners will continue to review a credit union’s ability to identify, measure, monitor, and control interest rate and liquidity risks through sound modeling practices, reasonable assumptions, and appropriately tiered scenarios. Reviews will focus on how credit unions incorporate these risks into governance frameworks, contingency funding plans, and strategic decision-making, including alignment between balance sheet structure, funding composition, and risk appetite.
- Earnings and Capital Adequacy – When evaluating a credit union’s earnings, NCUA examiners will assess whether the current and prospective sources of earnings are sufficient to support capital targets under a range of interest rate, credit, and liquidity stress scenarios. NCUA examiner reviews may focus on policies, procedures, risk limits, and capital planning practices, including how credit unions incorporate interest rate risk, funding constraints, and concentration risks into their capital adequacy assessments.
- Payment Systems – NCUA examiners will continue to assess whether credit unions have effective governance, risk assessments, vendor management, and security frameworks in place to support payment system operations, protect member data, and ensure resilience against fraud and cyber threats inherent in payment ecosystems.
- Fraud Prevention and Detection – NCUA examiners will continue to review credit union efforts to deter and detect fraud, including the adequacy of internal controls and separation of duties to guard against insider abuse.
- BSA/AML/CFT Programs – The emphasis in 2026 will be on evaluating your credit union’s risk-based approach to BSA compliance and how well the AML/CFT program is tailored to the credit union’s specific risk profile. NCUA examiners will consider whether credit unions focus their resources on the areas of greatest money laundering and terrorist financing risk and whether policies, procedures and controls are effective at mitigating illicit financial activity risks.
The letter to credit unions contains more details on each area mentioned above, along with links to resources that apply to each area.
Compliance Roundtable – February 18 (Webinar)
Join a member of The League’s compliance team as they lead a discussion on the latest changes in regulations and need to know information to keep your credit union in compliance. You can find more information or register on our website.