In Case You Missed It – 2018 So Far
Friday, April 20, 2018 7:50 AM

With a lot going on since the beginning of the year – and it doesn't appear to be slowing down – here are a few NCUA items that might be of interest.   First up, is ACET.  Well, what the heck is it?  It is NCUA's new cyber exam tool called the Automated Cybersecurity Examination Tool (ACET).  It's currently being used by NCUA examiners in cybersecurity exams of credit unions with assets over $1 billion – but will be used eventually in cybersecurity exams of all credit unions.   

ACET is mirrored after the FFIEC's cyber assessment tool called CAT, so it is probably a good idea (it is) to use the CAT tool for your internal credit union's assessment as well as following the FFIEC's best practices in its Info Tech Handbook and NIST's (National Institute of Standards and Technology) cybersecurity framework. Click here to read more about the ACET tool in the NCUA Report.

Second up, are NCUA legal opinion letters.  NCUA has released three legal opinions so far this year on the following topics:

  • Share insurance coverage for escrow type accounts: The letter on share insurance coverage for escrow type accounts is fact specific to New York law and involves lease security accounts –which are accounts set up by landlords for security deposits. In a nutshell, the letter clarifies that NY lease security accounts are eligible for share insurance coverage.
  • Field of membership and associational groups: The letter on field of membership looks at whether individuals that share core doctrinal religious beliefs and related set practices to those religious beliefs share a valid associational common bond to the related religious groups.
  • Loan Participations: In this letter, NCUA opines that a credit union must have continued and documented involvement in the loan participation throughout the life of the loan.  The agency also highlighted the need for each loan to be treated separately and documented as such - even when a number of participations are sold to the same credit union.