WASHINGTON—NAFCU is calling on NCUA to minimize examination burdens by not making requests for model validations, in addition to making several other requests.
The NAFCU letter was sent in response to an interagency request for information (RFI) seeking feedback on whether or not the principles included in interagency supervisory guidance on model risk management (MRMG) effectively support compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) requirements.
In addition to NCUA, the interagency RFI was issued by the Office of the Comptroller of the Currency (OCC), Federal Reserve, FDIC and Financial Crimes Enforcement Network (FinCEN).
In the letter, Senior Regulatory Affairs Counsel Kaley Schafer requested NCUA, in addition to minimizing examination burdens by not making requests for model validations, also bear in mind the difficulties in validating models when making requests to do so during examinations.
Schafer also encouraged the interagency group to consult the Federal Financial Institutions Examination Council's (FFIEC) examination reports and supervisory information through regulator information sharing to assess MRMG changes.