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NCUA Board Member Todd M. Harper Statement on the Request for Information about Strategies for Future Examination and Supervision Utilizing Digital Technology

June 2020
NCUA Board Member Todd M. Harper Statement on the Request for Information about Strategies for Future Examination and Supervision Utilizing Digital Technology

As Prepared for Delivery on June 25, 2020

Thank you, Heather and Myra, for your presentation today and for your hard work on developing a virtual examination program at the NCUA. And congratulations, Heather, on your first briefing at the NCUA Board table. You did a terrific job!

Given the subject matter we are discussing, it’s very fitting that you had to make that presentation virtually through digital technology.

The Request for Information about strategies for future examination and supervision utilizing digital technology that we are considering today is the next step in a process that began in 2016. The agency, and the credit unions that we supervise, have long contemplated alternative approaches to reducing the agency’s onsite presence during examinations.

Alas, the COVID-19 pandemic forced us to accelerate our planning from zero to sixty and move to an offsite exam posture essentially overnight. With the uncertainty that surrounds the health ramifications of the novel coronavirus, now is the right time to move the virtual exam program forward.

My policy priorities have long included cybersecurity, equity, and inclusion, consumer financial protection, the preservation of small, low-income, and minority depository institutions, as well as third-party vendor authority. I also consider the agency’s relationships and interactions with state credit union regulators of great importance to our mission.

As I reviewed the Request for Information, I did so through the lens of each of those policy priorities and with an eye towards how a virtual exam program at the NCUA would affect the work of and interactions with state regulators. I am pleased to see that several of the questions that I suggested earlier this month were added to the Request for Information.

These questions concern cybersecurity, economic inclusion, consumer financial protection, and the preservation of small, low-income, and minority depository institutions. Thank you, Heather and Myra, for incorporating those ideas.

I also greatly appreciate the question added about the impact on state supervisory programs. State regulators are our partners in credit union supervision, and we need to heed their advice and develop complementary examination programs.

I will support issuing this Request for Information, and I encourage all stakeholders to weigh in.

The more good ideas we receive, the better the final virtual exam program will be. And, because the Request for Information is about a virtual examination program, cybersecurity is key element of what we will ultimately consider and adopt. I cannot underscore enough how important it is for us to hear from experts in the cybersecurity community.

Thank you again, Heather and Myra, for your good work. Mr. Chairman, I do not have any questions or further comments.

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