
Credit Union Exam Solutions Presents With Flying Colors Inside a Code 4: What NCUA Doesn't Tell You
In this episode, Mark Treichel sits down with Steve Farrar and Todd Miller — both former NCUA veterans with over 60 years of combined regulatory experience — to break down exactly what a Code 4 means for your credit union, your board, and your relationships with every lender you work with.
Steve spent 15 years as a Problem Case Officer on the West Coast before moving to NCUA's Division of Risk Management in the central office, where he worked on enforcement, corporate resolution, and risk-based capital. Todd spent 34 years with NCUA, including a decade as an examiner and PCO, followed by 11 years as Director of Special Actions in the Western Region.
Together, they cover: what NCUA is actually doing when they code you a 4 (hint: building an administrative record), how often you'll see your examiner (more than you think), why the Federal Reserve, FHLB, and Fannie Mae all find out about your status, what Section 701.14 means for management and board changes, why assignment to Special Actions isn't always bad news, and what separates credit unions that recover from those that don't.
If you're a Code 4 — or worried you might become one — this episode gives you the insider perspective on what's coming and how to navigate it.
