Credit Unions

The Current Expected Credit Losses (CECL) accounting standard update will be required for financial reporting after December 15, 2022 and required for regulatory reporting starting March 31, 2023.  This update was finalized by the Financial Accounting Standards Board (FASB) in 2016.  Credit unions may choose to adopt this methodology sooner.

The current FASB standard requires credit unions to recognize losses when the loss is "probable" and "estimable".   The goal of the CECL standard is to recognize losses from loans and debt securities throughout the life of the loan.  This standard requires some sort of loss determination once a loan is granted.  Many industry experts believe CECL is the most significant accounting change to financial institutions in decades.  

Iowa credit unions under 10 million dollars in assets are exempt from this regulatory requirement. 

The IDCU recommends credit unions understand the CECL standard to develop an implementation strategy before the standard goes into effect. This section provides resources to help credit unions understand their responsibilities under this new standard.  We encourage credit unions to contact accounting professionals if they have additional questions about implementation strategies.  

CECL Resource Listing

• FASB Accounting Standards Update 2016-13, Topic 326, Financial Instruments - Credit Losses
• Iowa Administrative Rule Changes 
• NCUA CECL Resource Page
• NCUA Simplified CECL Tool

The NCUA has modernized the examination platform and systems utilized by the Iowa Division of Credit Unions (IDCU).  NCUA has spent the last several years developing the Modern Examination and Risk Identification Tool (MERIT) which will replace ARIES, the former platform. As part of this overarching project, NCUA developed a new secure entry point called NCUA Connect which credit unions may use to facilitate their examination and exchange information with both state and federal regulators.  

The IDCU has contracted to utilize MERIT to conduct examinations of Iowa credit unions and will fully complete the exam transition from ARIES to MERIT within the next quarter; however, full functionality may require additional transitions by the IDCU. Credit unions will be able to access final examination reports through the MERIT system, but IDCU will continue to send reports directly to the credit union.

As the IDCU transitions to and adopts the interactive functionality of MERIT, we will communicate our expectations to credit unions.  In time, we plan to use  additional functionality allowing credit unions the ability to respond to scoping requests and upload documents directly through MERIT. The IDCU is not requiring credit union enrollment in NCUA Connect and MERIT at this time, but will continue to communicate expectations for credit union engagement.

How to Request Access

If you would like to request access to NCUA Connect, the first step is to identify two individuals to become administrators for your credit union.   Administrators must request access by sending an email to the NCUA’s OneStop Help Desk at OneStop@NCUA.gov.   The request should include your name, email address, credit union name or insurance number, and list any NCUA applications you may need access to. The NCUA will verify all requests before approval.  Once authenticated, users can securely interact and share information with the NCUA and IDCU.

Additional Information

The following table provides IDCU implementation guidance and additional NCUA resources.

The following table provides all active regulatory guidance issued by the Superintendent of Credit Unions.

The following Agency Guidance Documents have been withdrawn by the Iowa Division of Credit Unions. These withdrawn Guidance Documents will no longer be updated, referred to, or relied upon by the Iowa Division of Credit Unions. Credit unions should review applicable Iowa and Federal rules and laws when referring to any guidance documents. Credit unions may direct questions and concerns to the Iowa Division of Credit Unions via email at idcu_support@iowa.gov or via phone at (515) 725-0505.

• Bondability of Credit Union Officials
• Independence in Auditor/Credit Union Relationship
• Corporate Bond and Commercial Paper
• Board of Director Borrowing from a Credit Union
• Charitable Donation Accounts
• Guidance on Indirect Lending Programs
• Overdraft “Bounce Protection” Programs
• Investments

• Any bond sold in Iowa must be approved for sale in the State of Iowa by the Iowa Insurance Commissioner; and specify in the bond, or by endorsement or addendum page, that the company will provide written notice to the Iowa Credit Union Division of any cancellation or non-renewal, change in deductible, or change or limitation of coverage, either in it entirety or individually as to a credit union director, official or employee, whether initiated by the underwriter or the insured.

The Iowa Division of Credit Unions follows the minimum coverage and deductible limits for federal credit unions which are established in the NCUA Rules and Regulations.  Iowa Code Section 533.308 provides more detailed information on the requirements of fidelity bond coverage for Iowa state-chartered credit unions.  The following listing is current as of February 2014.

No technology that’s connected to the Internet is unhackable. - Abhijit Naskar

The following resources provide guidance when addressing cybersecurity risk areas.

• CISA Shields Up
• CIS Controls
• CISA Cyber Hygiene Services
• FFIEC Handbook
• FFIEC Cybersecurity Guide for Financial Institutions
• FBI Infragard
• NCUA Cybersecurity tools (ACET & others)
• NCUA catastrophic and Incident Report Requirements
• Subscribe to receive updates on known exploitable vulnerabilities

The Iowa Division of Credit Unions recognizes that credit unions continue to operate with remote capabilities.  Credit unions that continue to support remote work should evaluate their security measures to ensure member data security meets the standards established by Iowa and Federal Law.  The below resources provide additional information specific to remote access.

• FFIEC Handbook - Remote Access 
• FFIEC Handbook - Use of Remote Devices
• Center for Internet Security (CIS) Critical Security Controls Telework Network Security Guide

Credit union board members will find valuable information to be more successful in the Board of Directors video series offered by the National Credit Union Administration (NCUA). The Board of Directors video series is designed specifically for directors of small and medium-sized credit unions. However, all directors may find the series helpful.

Viewers may take an online test to assess their understanding of the material covered and earn a certificate of completion with a passing score. In order to take the online test and print a certificate, you must create a Credit Union Learning Management Service account. The NCUA Office of Credit Union Resources and Expansion manages the Credit Union Learning Management Service.

The following videos are available:

• What Every Board Member Should Know
• Credit Union Policies and Procedures
• Mergers
• Succession Planning
• Understanding the NCUA Examination
• Strategic Planning
• Understanding Financial Statements
• Understanding Key Ratios
• Effective Board Meetings

The NCUA prohibits the following individuals from becoming an “institution affiliated party” of any federally-insured credit union.  This list includes individuals within the State of Iowa and does not include all NCUA prohibition orders. The Division recommends all credit unions verify potential affiliated parties as not being prohibited by NCUA.  Do not hesitate to contact IDCU  with any questions.  

• Lorie Kristine Bentler​
• Linda Lee Clark
• Taylor Lynnae Cole
• Henry Hill
• John Richards
• Alisa Marie Ryan
• Elizabeth S. Smith

Credit unions are required to notify the Superintendent of the intent to offer debt cancellation products at least 30 days before offering the product to the membership. The notification must contain the following information.

• Each type of GAP product that will be offered to the membership.(please include collateral types and whether or not the policies are refundable)
• A complete schedule of fees
• The name of the insurance company, contractual policy limits, deductible amounts, and limitations on coverage applicable in accordance with Iowa Administrative Code 189-5.3(3).

The rule also requires credit unions to set policies for these programs. The below listing provides aspects credit unions should include in their policies for debt cancellation products.

• Collateral Covered
• Maximum Limit of Liability
• Maximum Allowable Loan Term
• Maximum Loan to Value Ratio
• Maximum Allowable Market Value or Maximum Allowable Loan or Lease Amount
• Primary Insurance Deductible Amount covered
• Availability of Replacement Vehicle Benefits

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YEAR - NUMBER OF CREDIT UNIONS

2022 - 77

2021 - 81

2020 - 82

2019 - 86

2018 - 87

2017 - 89

2016 - 93

2015 - 95

2014 - 106

2013 - 114

2012 - 120

2011 - 129

2010 - 133

2009 - 136

2008 - 139

2007 - 142

2006 - 149

2005 - 150

2004 - 163

2003 - 168

2002 - 176

2001 - 182

2000 - 190

1994 to 1999 - 196