Credit Union Exam Solutions Presents With Flying Colors

www.marktreichel.com

https://www.linkedin.com/in/mark-treichel/

In this episode, Mark Treichel walks through the full-year 2025 CAMEL code data across all four quarters, providing a comprehensive analysis of where the industry stands and what the numbers mean for credit unions at every asset tier.

The episode opens with context: in September 2024, then-National Credit Union Administration Chairman Todd Harper sounded a public alarm after the number of complex credit unions — those over $500 million in assets — coded at CAMEL four or five tripled in a single quarter. That alarm set the benchmark for evaluating 2025's results.

Mark frames the analysis around three perspectives: the glass half full (optimistic), the glass half empty (skeptical), and the base case (pragmatic). He works through the data at an industry level before breaking it down by asset tier, where a more complicated picture emerges.

Key findings include: the overall improvement in code four and five counts; a significant reduction in dollar exposure in troubled institutions; the resolution of Harper's specific alarm as the complex credit union count returned to seven at year-end; and the Q2 2025 anomaly, where the code three count fell but assets in that bucket jumped by $25 billion — illustrating how quickly the composition of a tier can shift even when the headline count moves in the right direction.

A critical section covers the mid-size tier — $100 million to $500 million in assets — where 2025 produced almost no improvement. Code fours and fives in that range actually ticked upward. Mark explains the particular pressures mid-size institutions face and why the headline numbers can obscure their reality.

The episode also addresses the National Credit Union Administration's staffing situation in depth: a 27% reduction in force, a shift in exam cycle requirements from mandates to goals, and the quiet update to the National Supervision Policy Manual extending exam cycles for larger institutions. Mark raises a pointed question: do the CAMEL code improvements reflect genuine rehabilitation, or do they partly reflect an agency adjusting to resource constraints?

The episode closes with practical guidance for what to do based on your CAMEL code, and a look ahead to 2026 — including the hiring freeze, rising delinquency trends, and potential leadership changes at the agency.

 

Topics Covered:

•        The Harper Alarm: context from September 2024 and how 2025 resolved it

•        Full-year CAMEL code trends across all five quarter-ends

•        Asset tier breakdown: $500M+, $100M–$500M, and under $100M

•        The Q2 2025 anomaly: count down, dollar exposure up

•        National Credit Union Administration staffing: 27% reduction, exam cycle changes, and the truth-in-coding question

•        Glass half full: genuine improvements and the resolution of the Harper alarm

•        Glass half empty: uneven distribution, merger effects, and delinquency trends

•        The base case: what every credit union should do based on its CAMEL code

•        What to watch in 2026