We determined NCUA could have prevented or mitigated
the loss to the NCUSIF had they taken a more timely and
aggressive approach regarding TCCU’s concentration
risks in its MBL portfolio. We also determined NCUA
could have coordinated more effectively with the California
DFI, and that NCUA management created a lack of
continuity in the supervision of TCCU from an ever-shifting regional authority, which
may have contributed to the lack of an aggressive approach.
Supervisory Background
TCCU received a CAMEL Composite rating of 2 in the December 31, 2006
examination (Effective), an indication of strong performance. Examiners noted the
Credit Union’s deterioration beginning with the next examination, the September 30,
2007 examination (Effective), when they downgraded the Credit Union’s CAMEL
Composite to 4. Examiners kept the Credit Union’s Composite CAMEL rating at 4
until the June 30, 2011 examination (Effective), when they downgraded it to a
Composite Camel rating of 5. The Credit Union remained a Composite CAMEL 5
through liquidation in 2012. Table 6 (below) provides Composite and specific
CAMEL ratings for the applicable examinations during the scope period of our