NCUA’s Board Member Tanya Otsuka’s Remarks at Treasury’s Roundtable for Providing Financial Access to Justice-Impacted Individuals

Credit Union Regulatory Guidance Including: NCUA, CFPB, FDIC, OCC, FFIEC

Hello, this is Samantha Shares. This episode covers N C U A’s Board Member Tanya Oatska’s Remarks at Treasury’s Roundtable for Providing Financial Access to Justice-Impacted Individuals

The following is an audio version of those remarks. This podcast is educational and is not legal advice. We are sponsored by Credit Union Exam Solutions Incorporated, whose team has over two hundred and Forty years of National Credit Union Administration experience. We assist our clients with N C U A so they save time and money. If you are worried about a recent, upcoming or in process N C U A examination, reach out to learn how they can assist at Mark Treichel DOT COM. Also check out our other podcast called With Flying Colors where we provide tips on how to achieve success with N C U A.

Before the remarks you may wonder what the definition of a Justice-impacted individuals is.

Justice impacted individuals include those who have been incarcerated or detained in a prison, immigration detention center, local jail, juvenile detention center, or any other carceral setting, those who have been convicted but not incarcerated, those who have been charged but not convicted, and those who have been arrested.

And now the remarks.

As Prepared for Delivery on April 24, twenty twenty four

Good afternoon and thank you to Deputy Secretary Adeyemo and everyone at Treasury for convening this critical and timely discussion.

The credit union system is an important and unique part of our financial system because it is centered around a cooperative business model that is driven not by a profit motive or shareholder interests, but by the needs of credit union members. Many credit unions were created to serve communities that the traditional financial system has long forgotten. So, it is fitting that the NCUA and credit unions are at the table when it comes to providing financial access to justice-impacted individuals and marginalized communities.

One of the challenges justice-impacted individuals face when looking to open a bank account is the lack of a driver’s license or other IDs typically preferred or required by banks. The NCUA previously issued an opinion indicating that it is acceptable to use an individual taxpayer identification number (ITIN) to open an account, and credit unions have led in this space.

For example, Stepping Stones Community Federal Credit Union, which is here today, serves justice-impacted individuals at three local prisons in Delaware by partnering with the Delaware Department of Corrections. They use ITINs to open accounts for members and work with the business office at the prison to gain identification information to establish the account. The prison provides documents certifying the authenticity of the members and names. As of November 2023, the program had 482 active accounts totaling more than $300,000.

Several credit unions in New York City, including the Lower East Side People’s Federal Credit Union, Neighborhood Trust Federal Credit Union, Urban Upbound, and USAlliance currently accept IDNYC, a municipal ID card that New York City started issuing in 2014. It is available to all residents of New York City, including people from some of the most vulnerable communities, such as those who are unhoused, justice-impacted individuals, immigrants, and others who may have difficulty obtaining a government-issued photo ID.

Lastly, the NCUA recently updated its policy on preserving minority depository institutions (MDIs) -- a main priority for me. As a regulator whose focus is to ensure fair, safe, and accessible banking services to credit union members, the NCUA is committed to preserving minority depository institutions, providing technical assistance and support, and encouraging new ones to form.

M D I’s have a long history of bridging the gap to underserved communities. Many of the credit unions doing the work of helping justice-impacted individuals are M D I’s. Indeed, four out of the five credit unions I mentioned today are designated MDIs.

I am encouraged by the steps the agency and credit unions have taken to address the financial gap justice-impacted individuals face. However, we know that more needs to be done, and I look forward to hearing from you all on how we can continue to expand access and economic empowerment to more people and communities. Thank you.

This concludes the remarks.

If your Credit union could use assistance with your exam, reach out to Mark Treichel on LinkedIn, or at mark Treichel dot com. This is Samantha Shares and we Thank you for listening.