CFPB and NCUA Sign MOU

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On January 14, 2021, the CFPB and NCUA signed a new Memorandum of Understanding (MOU) to improve coordination between the two agencies related to the supervision of credit unions with more than $10 billion in assets.

The MOU states that it “will not supersede the framework already in place under the existing coordination structure” between the CFPB and NCUA, including a 2012 MOU entered into by the CFPB, the NCUA, and the other federal prudential regulators. The new MOU supplements some components of the 2012 MOU, such as the examination coordination and information sharing guidelines. For example, the 2012 MOU required the agencies to consult regarding their respective examination schedules; the new MOU states that they must provide each other with their examination schedules on an annual basis. The new MOU also implements some new processes designed to promote further coordination, such as a joint training program and semi-annual joint strategy planning.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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