Complaints and Regional Appeals of Examination Issues What You Need to Know

Credit Union Exam Solutions Presents With Flying Colors

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# With Flying Colors Podcast: Exam Appeals at the Regional Level

## Guest: Todd Miller
- Former NCUA employee with nearly 34 years of experience
- Roles included examiner, problem case officer, regional capital market specialist, and director of special actions in the western region
- Served on NCUA's supervisory review committee

## Key Points:

1. Recent changes in NCUA's exam report process:
- Reports now reviewed at higher levels before issuance
- Credit unions no longer see draft reports, only draft exam findings and DORs
- Camel codes not discussed during exams

2. Avoiding appeals:
- Communicate openly with exam staff throughout the process
- Understand risk ratings and proposed DORs/exam findings during the exam
- Negotiate corrective actions during the exam when possible

3. Appeal process steps:
- Start with the examiner, then supervisory examiner, then regional director
- Adhere to timeframes for formal appeals (within 30 days)
- Gather documentation to prove your point

4. Considerations for appealing:
- Weigh the cost-benefit of appealing vs. implementing changes
- Don't fear retaliation; appeals can be successful at the regional director level
- Start with the supervisory examiner, even for complex issues involving specialists

5. Handling personality conflicts:
- Can be addressed as part of the appeal process
- Supervisors may reassign examiners depending on the situation

## Takeaways:
- Communication is key to avoiding surprises and potential appeals
- Don't be afraid to appeal if there's a material disagreement
- Appeals at higher levels (beyond regional director) can be more costly

## Contact Information:
- Email: [e-mail]
- Website: www.marktreichel.com

Here's a draft of show notes for the podcast episode. These notes summarize the key points discussed, including information about the guest, changes in NCUA's exam process, steps for avoiding and handling appeals, and important considerations for credit unions. I've also included the contact information provided at the end of the episode.

Let me know if you'd like me to modify or expand on any part of these show notes.