What does it take to get our attention?
Did any of you notice the damning NCUA Inspector General report released on March 14 addressing the audit of NCUA’s Comprehensive Records Management Process? I dare say that any federally chartered or insured credit union that chose to ignore NCUA regulations to the degree that the NCUA staff did with the Federal Records Act of 1950 and the regulations of both the National Archives and Record Administration and the Office of Management and Budget would be facing serious censure. Any credit union executive would probably lose their job if they further knew about these shortcomings for over a five year period and not only failed to take corrective action but also seemed to be less than forthcoming about these failures to the agency board over a similar period of time.
The IG audit covered a period of 2012 to 2016. It was mid-year 2017 before the NCUA Board approved development of a full-time division within the Office of General Counsel (OGC) to manage day-to-day activities of records management and January 2018 before management issued a records management policy that addressed current federal laws and regulations. The prior six years, under the authority of the Office of the Chief Information Officer (OCIO), the audit is a story of misplaced priorities, ignorance of federal laws and regulations, obfuscation of the failure to act, and ineptitude in system development. Can you imagine an agency email system which is required to retain emails but lacks the capability to easily search, identify or retain those emails? Here is an especially descriptive quote from the IG audit:
“As shown throughout our report, decisions made by NCUA management to address records management requirements negatively affected the agency’s implementation of sound records management program.” (“Audit of NCUA’s Comprehensive Records Management Process”, pg. 8)
Here’s another addressing intra-departmental communication:
“Specifically, we found that executive management did not timely or accurately update the NCUA Board on records management, offices did not effectively communicate with each other, and management gave limited guidance to staff on how to handle records in the conduct of their day-to-day duties.” (Audit of NCUA’s Comprehensive Records Management Process”, pg. 10)
So that you can place this limited sampling in the proper context of the total report, I suggest you go to the NCUA website for the full report. One warning, you will not find this report prominently highlighted on the front page of the web site.
There’s an APB out for CUNA and NAFCU
Every bit as concerning as this audit should be to all of us, I am just as shocked by the lack of attention to the audit paid by our well-staffed and well-funded functionaries at our advocates CUNA and NAFCU. Try a search of “2018 NCUA IG Reports” on the websites of both and you’ll come up empty. Not a word of concern from the guys who are supposed to be paying attention to the goings on at NCUA on our behalf. Must not have been a big deal to them that the same agency that just stuck their federal finger in our eye and grabbed billions of credit union capital in the distribution of the TCCUSIF, all in order to grow the pot of funds available to pay for the ineffective management highlighted by the IG. Do we really expect that the same OCIO that couldn’t keep track of emails should be trusted with the $25 + million budgeted for the ESM (Enterprise Solutions Management) initiative? Who’s keeping an eye on our federal agency and holding them accountable? Tell me why I’m wrong.