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A problem becomes a Document of Resolution (DOR) when the examiner concludes they'd recommend escalating to the next level of enforcement if you failed to correct it. Everything below that line is supposed to be an Examiner's Finding. The escalation test The National Credit Union Administration (NCUA) puts it plainly in the "Document of Resolution" section of its National Superv...

A Document of Resolution (DOR) cannot cost a chief executive officer (CEO) their job by itself, because the National Credit Union Administration (NCUA) has no authority to decide who a credit union employs. What a DOR does is build a written record of who owed a correction and whether they delivered it, and boards make employment decisions off records like that. What NCUA can ac...

You don't apply for release from a Document of Resolution (DOR). Your examiner closes the item, and under the National Credit Union Administration's (NCUA) National Supervision Policy Manual (NSPM) 26.0, the examiner must close it once you've implemented the corrective action you agreed to, whether or not your financial trends have caught up. What actually closes a DOR The gover...

The last four people to hold or be nominated for the credit union seat on the NCUA board all came out of the Senate Banking Committee orbit. Kyle Hauptman. Todd Harper. Tanya Otsuka. Now John Crews. That's not a coincidence. H. Lenwood Brooks, V predicted this pattern on my podcast more than two years ago, and his explanation stuck with me. A president who nominates from Senate ...

Three things follow, and none of them are discretionary for the examiner. Your examiner will require a written response, weigh the failure in the management component of your CAMELS rating and in your composite, and recommend elevated enforcement: a Regional Director Letter (RDL), a Letter of Understanding and Agreement (LUA), or a Preliminary Warning Letter (PWL). A Document of...