2011.03.22+SAS+Workshop+Exam+Rights

LSCU Small LSCU Small Credit Union Credit Union WorkshopsWorkshops

March 22 and 23, 2011March 22 and 23, 2011

LSCU Regulatory LSCU Regulatory ComplianceCompliance

Examination Bill of RightsExamination Bill of Rights

Regulatory AffairsRegulatory AffairsContact InformationContact Information

Bill Berg Bill Berg Vice President of Regulatory AffairsVice President of Regulatory Affairs 866.231.0545, ext. 1028866.231.0545, ext. 1028 [email protected]@lscu.coop

Scott MorrisScott Morris Director of ComplianceDirector of Compliance 866.231.0545, ext. 2165866.231.0545, ext. 2165 [email protected]@lscu.coop

mailto:[email protected]


Examination Bill of Rights Examination Bill of Rights

SUPERVISORY ISSUES AND EXAMINATIONS

The regulatory environment for credit unions has changed dramatically since 2008 due to:

Real Estate / Economic crisis Subsequent Weak / Tepid Recovery Regulators Emphasis on Credit Union Performance Increased Attention to Safety and Soundness Issues

Examination Bill of Rights Examination Bill of Rights SUPERVISORY ISSUES AND EXAMINATIONS

Credit unions benefit from strong, reasonable safety and soundnesssupervision. Leagues across the country support a review process that:

Allows regulators to perform oversight duties efficiently and effectively.

Permit credit union officials to exercise sound business judgment and operate in the best interest of members.

Provide a reasonable balance between regulator and credit unions official working together yet independent of the other for the benefit of the institution.

Examination Bill of Rights Examination Bill of Rights

SUPERVISORY ISSUES AND EXAMINATIONS

Based on directives from the NCUA Examiner’s Guide, the list of rights available to credit unions includes the types of processes, procedures and professionalism credit unions should expect during examinations.

Section I - General duties of Examiners.

Section II - Responsibilities of CU officials

Section III - Resolving disagreements with examiners and regulators

Examination Rights SummaryExamination Rights Summary

Section I: General Duties of Examiners

The NCUA and state credit union regulatorsfollows a risk-focused examination program inwhich examiners evaluate a credit union’sperformance based on its financial condition andmanagement’s ability to identify, measure, monitor,and control current and potential risks.

Examination Rights SummaryExamination Rights Summary General Duties of Examiners / Risk

Examiners review policies, practices, personnel,and control procedures for managing risks in sevenkey areas:

Credit risk – Are credit union loans and investments performing well?

Interest rate risk – Are changes in interest rates affecting credit union products and investments?

Examination Rights SummaryExamination Rights Summary

General Duties of Examiners / Risk

Liquidity risk – Can the credit union meet its current obligations when due and could it quickly liquidate assets if necessary without sizeable losses?

Transaction (or operational) risk – Does the credit union maintain adequate internal controls and can it process transactions, deliver products and services, and manage information flows well?

Examination Rights SummaryExamination Rights Summary General Duties of Examiners / Risk Considered

Compliance risk – Is the credit union meeting its compliance responsibilities and preparing for future requirements, and arecredit union officials meeting their fiduciary duties?

Strategic risk – Are the credit union’s strategic goals appropriateand reasonable; do the credit union’s business decisions line upwith its goals?

Reputation risk – Has the credit union avoided negative publicityor minimized the impact of negative publicity, given the currenteconomic circumstances?

Examination Rights SummaryExamination Rights Summary Role of Credit Union Officials

The priorities, expertise, and commitment of credit unionmanagement and board are essential to effective risk management.

Well-defined policies and CU procedures, including monitoringsystems, are characteristics of well managed credit unions.

Credit union’s should always cooperate with examiners toprovide requested data and materials and access to personnel.CU and examiner cooperation, including in the development ofsolutions to problem areas, will help ensure the credit unionbenefits from the examination.

Examination Bill of Rights Examination Bill of Rights Credit Union Examination Rights

“Credit unions have the right to manage risk without beingdirected by examiners to eliminate it.”

NCUA Examiner’s Guide (NEG) page 1-3.

Commentary: Examiners should not ―insist that a creditunion eliminate risk but, instead, should ensure thatcredit unions identify and manage their risks. Thedesired reward for taking risk is stable profitability andincreased net worth. Credit unions must balance riskand reward responsibly.


“Credit unions have the right to respectful conduct fromthe examiner.”

NCUA Examiner’s Guide (NEG) pages 21-3/4

Commentary: Credit unions expect examiners to always actprofessionally— which they do most of the time, according to creditunions. However, if a credit union feels that an examiner hasstepped over the line in terms of conduct, the credit union shouldreport the incident to the supervisory examiner or regional office,without fear of retaliation.


“Credit union officials have the right to question and seek corrections to examiner findings, conclusions, and directives.“

NCUA Examiner’s Guide (NEG) page 1-15

Commentary: Accuracy is essential to a strong safety and soundnessregulation. Examiners are human and humans make mistakes. It isimportant and appropriate that credit unions work with examiners toensure all reports and directives are as accurate and timely aspossible.


“Credit union officials have the right to know the specificauthority or legal basis for an examiner’s directive, and this authority should be provided by the examiner in the exam report or directive.”


Commentary: NCUA examiners must be willing and able to provide tocredit union officials the legal authority for the action they are suggesting ordirecting the credit union to take. In addition, examiners do not haveflexibility to insist on actions or policies that are counter to or inconsistentwith statutes, agency policy, or GAAP.


“Credit union officials have the right to receive clearly written examination reports in a timely manner. Any other directives and notices from the examiner should also be clearly communicated in writing.”


Commentary: Credit unions should not be expected to comply withdirectives that are not in writing. In order for the credit union’srecord of performance, including efforts to address problem areas,to be as accurate as possible, directives should be provided inwriting to the credit union and included in the credit union’sexamination history.


“Credit union officials have the right to have examination reports, findings, directives and administrative actions that are based on all relevant facts, including current data.”


Commentary: The examination report should present a current,factual picture of the credit union’s financial performance and riskmanagement. When material problems arise that the examinerexpects the credit union to correct, the record must include acomplete and well-documented accounting of the problems and theefforts by the credit union and the examiner to address them fully.


“Credit union officials have the right to be evaluated on their ownstrengths and weaknesses and not solely on the basis of regulatorconcerns about trends or general problems in the credit unionsystem or within their peer group.”


Commentary: While examiners must be mindful of problems andconditions in their regions and even across the country, it isessential for the accuracy of each credit union’s examination reportthat the examiner’s assessment reflects an accurate depiction ofthe performance and operations of the credit union under review.


“Credit unions have the right for their examination findings and directives to be risk prioritized.”

NCUA Examiner’s Guide (NEG) pages 1-1 & 20-1

Commentary: Examiners are directed to focus their reviews andreports on applicable risks, and those activities that present thegreatest risk receive the most attention. A standard procedure thatthe examination findings and directives must be listed in order oftheir importance based on the amount of risk presented is fullyconsistent with the risk-focused exam process.


“Credit union officials have the right to appeal examiner findings, conclusions, or directives without fear of retaliation from their regulator.”

NCUA, Interpretive Ruling and Policy Statement (IRPS) 02-1

Commentary: The FCU Act states credit unions have the right to appealsupervisory determinations to the NCUA Board. Appeals can include ceaseand desist, removal of officials, and conservatorships. Material examinationreport findings, conclusions, and directives from the examiner may also beappealed. DORs and LUAs are not generally eligible because they aretechnically considered voluntary agreements, but the credit union should beable to appeal to the regional director as part of the DoR or LUA process.


“Instructions on how to appeal examiner findings, conclusions, or directives should be detailed on every examination report form that is provided to credit unions.”


Commentary: NCUA’s process for allowing an appeal is not clear. NCUA, ACUA, and OFR regulators should ensure that all examination reportforms which examiners provide to credit unions include sufficientlydetailed information as to which issues may be appealed/challengedand the process for making such an appeal.


“Credit unions have the right to have any published orders—at leastconsent orders—address only facts and not conjecture or speculationby the examiner.”

NCUA Examiner’s Guide (NEG) pages 20-1, 20-6, and 30-3

Commentary: Published orders must be based on facts in an examreport reviewed by the credit union. The Examiner’s Guide states the examination report must reflect documentation to support anexaminer’s findings and conclusions. For the confidential section ofthe report, examiners should only cover pertinent matters that arebased on fact, and not statements based on gossip or hearsay.


“Credit unions have the right to develop and use high-level policies, which should be separate and distinct fromdetailed procedures.”


Commentary: Examiners should not dictate broader credit unionpolicies, but rather should lead and persuade officials to properaction. Credit union management and officials have the right to use business judgment in developing their policies.


“State credit unions have the right to a lead examiner thatis a state regulator, consistent with the credit union’scharter type.”

NCUA Examiner’s Guide (NEG) page 22 B-3

Commentary: NCUA staff often accompanies state regulators during the examination of state-chartered credit unions, particularly on federal hotbutton issues such as MBL and indirect lending. Thus, it is important that thelead examiner be comparable to the credit union’s charter type. It is also important that the state regulator—not NCUA— be responsible for assigningthe credit union’s CAMEL rating during an examination.


“Credit union officials have the right to know the timing of when their regulators, such as NCUA, will publish anLUA.”


Commentary: The NCUA should provide notification to a credit unionof the date a pending LUA will be published. Currently, credit unionsare learning about publication by either checking NCUA’s website or,more likely, via NCUA’s mass emails—which can be unintentionallyinflammatory. NCUA should follow the lead of a number of stateregulators that inform the credit union on when publication will occur.


“Credit union officials have the right to defer to their certified public accountant (CPA) in a disagreement between the officials and their regulator regarding issues related to U.S. generally accepted accounting principles.”

NCUA Examiner’s Guide (NEG) pages 5A-4 and 7-28

Commentary: CUs over $10 million in assets are required to follow GAAPwith a CUs CPA responsible for ensuring that the activities and financialstatements are in compliance with GAAP. Therefore, to avoid becominginvolved in specific accounting issues, an examiner should not seek tooverride the CU’s CPA when disagreements on accounting issues arise.Such practice will benefit not only the credit union but also the examiner byfreeing up its resources.


“Credit union officials have the right to communication (i.e., draft findings) with their examiner prior to final issuance of the examination report.”


Commentary: Examiners should set aside ―time periodically todiscuss with management and officials developments in theexamination. In addition, an examiner should provide ―credit unionofficials and management sufficient time to review it before the jointconference or exit interview.


“Credit unions have the right to expect directives from examiners (including verbal & written comments) to be consistent with agency policy, such as NCUA’s letters to credit unions.”

NCUA Examiner’s Guide (NEG) pages 3-1, 6-15, 6-16,

6- 20, 7-35, 9A-18, and 10-1 – 10-14

Commentary: NCUA examiners must follow the guidelines in the Lettersto Credit Unions. For example, the Examiner’s Guide states that creditunions must follow Letters to Credit Unions in areas such as CAMEL ratings, risk-based lending, and risk management.

Examination Bill of Rights Examination Bill of Rights Examination Appeals Process

Informal Examination Appeals• Appeal of Material Operating Exceptions

Violation of Law or Regulation Unsound Policy Unsafe Procedure or Practice

Timing of Informal Examination Appeals• CU can submit written appeal to Regional Director w/in 30

days of receipt of Exam Report.• Within 60 days of receipt, Regional Director will send

written response and take corrective action, if necessary.• If Regional Director fails to respond or credit union wishes

to appeal Director’s decision, a written appeal (with CU Board approval) can be submitted to the Supervisory Review Committee (SRC).


Informal Examination Appeals (SRC)• SRC is made up of 3 NCUA staff members serving in

independent appellate role for review of material.• A credit union personal appearance before the SRC

is permitted with a decision rendered within 30 days. • SRC determinations are limited to:

Composite CAMEL ratings of 3, 4, and 5 and allcomponent ratings of those composite ratings;

Adequacy of loan loss reserve provisions; andloan classifications for ―significant loans as determinedby the appellant.


Supervisory Review Committee - Timeline

• If the SRC fails to respond favorably, the credit union may appeal to the NCUA Board w/in 30 days of the SRC’s response.

1. Credit Union Disagrees with Final Examination Report2. CU appeals to Regional Director w/in 30 days of report3. CU appeals “material determinations” to SRC w/in 60 days

of Regional Director’s response4. CU appeals to NCUA Board w/in 30 days of SRC’s decision


Prompt Corrective Action Enforcement

• Within 45 days of becoming undercapitalized (less than 6% net worth) credit unions must submit a net worth restoration plan(NWRP) to NCUA. A state credit union must submit a NWRP toits state regulator (ACUA or OFR) as well. The plan is required unless the net worth category was downgraded on the basis of other safety and soundness issues. The director may extend the filing deadline.

• The NCUA regional director (and ACUA Administrator or OFR Bureau Chief) will review the plan and approve, reject, or request modifications.

• Credit unions should make every effort to work out its NWRPwith the NCUA, ACUA, or OFR. While there is no formal processfor appealing requirements of a NWRP, a credit union mayraise concerns during the process.


Prompt Corrective Action Enforcement

• NCUA has authority to take supervisory actions under PCA.

Mandatory supervisory actions include:

• Requiring an earnings transfer for credit unions with less than 7% net worth;

• Limiting asset growth and specifically limiting member business loan growth,

• Submission of an Net Worth Replenishment Plan. • NCUA may liquidate or conserve a critically

undercapitalized credit union within 90 days of its classification

• NCUA can take other action if it is determined to be appropriate.


Prompt Corrective Action Enforcement - Appeals

• NCUA has an independent appeals process under which credit unions may appeal Prompt Corrective Action supervisory actions.

The NCUA Board will provide advance notice and an opportunity for a credit union to have a hearing before a PCA discretionary supervisory action is taken, unless NCUA feels the action is necessary to further PCA purposes.

The credit union may also challenge the discretionary supervisoryaction in writing and request the action be modified or withdrawn.

The credit union is not entitled to a hearing before the NCUA Board.Upon review, the Board, or its independent designee, may decide not toinitiate the action or modify.

The credit union may request the NCUA Ombudsman to review aproposed discretionary supervisory action.


NCUA Administrative Actions Other Than PCA

• NCUA may take ―administrative actions that are separate fromPCA supervisory actions. These separate measures are amongthe most serious supervisory steps NCUA may take against a creditunion or its officials. These actions can include:

Letters of Understanding and Agreement; Cease and desist orders; Civil money penalties; Removal of officials; Termination of insurance; Conservatorship; Revocation of charter; and Liquidation

.


NCUA Administrative Action and Credit UnionsChallenge - LUAs

• Credit unions have the right to challenge a number of administrative actions. The appeals process may varydepending on the action. It is important to note that there areonly limited appeals associated with Letter of Understandingand Agreement (LUAs). Once an LUA is signed, it is at thatpoint when it becomes an enforceable agreement betweenthe credit union and the regulator. Issues related to thesigned LUA are not eligible for appeal to NCUA but may besubject to review by the courts. Credit unions should discussissues related to LUAs with a competent legal representativeand, as appropriate, LSCU representatives.


NCUA Administrative Action and Credit Unions Challenge – Cease & Desist

Appeals for Cease and Desist Orders

The FCU Act empowers the NCUA to issue a Notice of Charges and to arrange for an administrative hearing to enforce a cease and desist order. When the notice is provided to the credit union, the examiner must make officials aware of:

• The timeframe in which they must answer all changes

• Filing of a written notice of appearance with the administrativelaw judge. A credit union has the right to challenge a temporarycease and desist order in federal court within ten days.

• A 30-day period between when the notice is provided to thecredit union and the date of the hearing.


NCUA Administrative Action and Credit Unions Challenge – Cease & Desist

The credit union may agree without contesting the order, and it will become final. If there is no agreement however, a hearing is held before an administrative law judge and the following process will occur:

• The judge sends a recommendation and the hearing record to NCUA Board.

• In 90 days, the Board makes a decision using evidence supporting the action.

• The CU may appeal to the U.S. Court of Appeals w/in 30 days of final notice.

• The court may overturn the Board’s action if it determines the action is arbitrary.


Credit Unions Challenge – Cease & Desist

• The final order remains in place during appeal unless removed or modified by the court.

• The order is effective 30 days after the credit union has been notified.

• A final cease and desist order becomes effective 30 days after notice to the credit union and remains in effect unless modified or set aside by a reviewing court.

If the credit union violates the terms of a cease and desist order,NCUA may enforce it in U.S. district court or by imposing civil moneypenalties (fines).


Credit Unions Challenge – Civil Money Penalties

NCUA may assess fines against a credit union for violations of laws, orders, rules, or other violations. The size of the penalty depends on the seriousness of the violation, and is based on the following:

• First tier - Any credit union or affiliated party that violates a law or regulation may receive a fine of not more than $5,000 for each day of the violation.

• Second tier - If the credit union commits a ―first tier violation and exhibits reckless conduct or does not carry out its duties properly, and the violation is part of a pattern of misconduct, causes more than a minimal loss, or results in a monetary gain or other benefit to the party involved, the NCUA Board may assess a fine not more than $25,000 a day for each day of the violation.



NCUA may assess fines against a credit union for violations of laws, orders, rules, or other violations. The size of the penaltydepends on the seriousness of the violation, and is based on thefollowing:

• Third tier – A CU that knowingly commits violations, engages inunsafe/unsound practices, breaches any fiduciary duty, orrecklessly causes a substantial loss to the credit union or asubstantial monetary gain or other benefit to an involved partymay receive a fine of not more than $1,000,000 per day for each day of the violation, or 1 percent of assets, whichever is less.



The procedure for the issuance of a CMP involves the following timeline:

The NCUA Board issues a Notice of Assessment, which addresses thelaw and the facts on which it based.

The CU has 90 days to make payment, but may request a hearing within20 days.

An administrative law judge holds a formal hearing if requested by a CU.

After the administrative hearing, the judge submits a recommended decision to the NCUA Board.

The NCUA Board issues a final order, but the order may be appealed bythe CU to a U.S. court of appeals w/in 20 days of receipt of the final order.


Credit Unions Challenge – Official Removal or Suspension

NCUA may remove directors, officers, or committee members as aninitial course of action or as a continuation of a cease and desistorder if the officials refuse to comply as directed.

NCUA may also suspend or remove institution-affiliated parties forcertain criminal offenses pursuant to legal authority provided by TheFCU Act. Removal can occur only if NCUA has issued a Notice ofIntent to Remove or a Notice of Suspension and Intent to Removeand after completion of the appropriate administrative procedures.


Credit Unions Challenge – Official Removal or Suspension

The notice to remove an official will contain a statement of factsfor removal and establishes the time and place for holding ahearing before an administrative law judge; this is usually between30 and 60 days after serving the notice.

The examiner informs the official when the notice is delivered thatunless the official personally or an authorized representative, appears at the hearing, the judge will assume the official hasconsented to the removal.

A party who has been removed or suspended from office is alsoautomatically removed, suspended, and prohibited from participating inthe affairs of any federally insured financial institution unless the creditunion’s regulator provides express written consent.


Credit Unions Challenge – Termination of Insurance

The termination of insurance is the most severeaction NCUA can initiate for federally insured statecredit unions.

The following are the administrative procedures for termination of insurance:

• The NCUA Board issues a Notice of Charges, requesting correctiveaction. The CU has 120 days to make corrections, although the Boardmay reduce this time to not less than 20 days if the risk is sufficient.


Credit Unions Challenge – Termination of Insurance

• If the credit union does not take corrective action, then the NCUA Board may issue a Notice of Intent to Terminate Insured Status. This sets out a statement of the facts justifying termination, and establishes a time and place for an administrative hearing within 30 to 60 days.

• An administrative law judge holds an administrative hearing. The administrative law judge files a recommended decision with the NCUA Board.

• The NCUA Board issues its final order.

• The credit union may appeal to the U.S. Court of Appeals, but theorder is effective unless modified or lifted by the Board or the court.

• NCUSIF insurance continues for one year from the date of terminationon current shares; however, the NCUSIF does not insure new shares.


Credit Union Challenge - Revocation of Charter

NCUA may place a solvent federal credit union into involuntary liquidation for PCA or safety and soundness reasons. This is the mostsevere enforcement action NCUA can take against a solvent federalcredit union.

• NCUA issues a Notice of Intent to Revoke Charter and Place into Involuntary Liquidation or a Notice of Suspension of Charter and Intent to Place into Involuntary Liquidation. *If a Notice of Suspension is issued, operational control of the credit union is immediately transferred to NCUA. All subsequent administrative steps are the same for both a Notice of Intent and a Notice of Suspension.



Once initiated, the credit union has 40 days in which to:

File a written statement stating why it should not be liquidated;

Request an oral hearing; or consent to liquidation by a board of directors’ resolution.

If the credit union files a written statement, the NCUA Boardwill render a decision within 45 days. A Notice of Revocationof Charter and Involuntary Liquidation will be issued where thegrounds for liquidation are found to exist.



If the credit union files a written statement, the NCUA Board will render a decision within 45 days. A Notice of Revocation of Charter and Involuntary Liquidation will be issued where the grounds for liquidation exist.

If the credit union requests a hearing, it will be held before an administrativelaw judge. The judge submits the recommendation to the NCUA Board.

The NCUA Board issues a final order.

Revocation of Charter & Involuntary Liquidation of Insolvent CU

NCUA must appoint itself liquidating agent of an insolvent federal creditunion upon ―finding that it is insolvent. The credit union may challenge theliquidation in court

Examination Bill of RightsExamination Bill of RightsLeague of Southeastern Credit Unions (LSCU)

1-866-231-0545

Alabama Office Florida Office22 Inverness Parkway, Suite 200 3773 Commonwealth Blvd.Birmingham, AL 35242 Tallahassee, FL 32303Fax: (205) 991-2576 Fax: (850) 574-6374

Will McCarty, Senior Vice President, Governmental Affairs866-231-0545, ext. 2137 (Birmingham)[email protected]

Bill Berg, Vice President, Regulatory Affairs866-231-0545, ext. 1028 (Tallahassee)[email protected]

Scott Morris, Director of Compliance866-231-0545, ext. 2165 (Birmingham)[email protected]..

Examination Bill of RightsExamination Bill of RightsACUA – Alabama Credit Union Administration

Alabama Credit Union Administration – Montgomery, AL1789 Cong Wm L Dickinson Dr.Montgomery, Alabama 36109Tel: (334) 271-2381Fax: (334) 409-9635

Larry Morgan, AdministratorLloyd Moore, Assistant Administrator

Peter C. Ukeje, Exam Coordinator James M. Arndt Jr, Exam Coordinator

Robert J. Russell, Exam Coordinator Keith Shepherd Lowery, CU Exam Specialist

Keith C. Edwards, Exam Specialist Marie H. Steele, BSA Examiner

Cindy J. Davis, Executive Secretary Christy Ealum, Administrative Assistant

Examination Bill of RightsExamination Bill of RightsFlorida OFR – Florida Office of Financial Regulation

Florida Office of Financial Regulation – Tallahassee, FL200 E. Gaines StreetTallahassee, FL 32399-0371Tel: (850) 410-9800Fax: (850) 410-9548E-mail the Florida Office of Financial Regulation at: [email protected]

Linda B. Charity, Director – Office of Financial Regulation (850) [email protected]

Bruce Ricca, Bureau Chief - Bureau of Credit Unions(850) [email protected]

Examination Bill of RightsExamination Bill of RightsCUNA - Credit Union National Association

CUNA -Washington, DC CUNA - Madison, WI601 Pennsylvania, Avenue, NW 5710 Mineral Point RoadSouth Bldg., Suite 600 Madison, WI 53705Washington, DC 20004-2601Tel: (202) 638-5777 Tel: (800) 356-9655Fax: (202) 638-7734 Fax: (608) 231-1869

Kathleen Thompson Mike McLainAssociate General Counsel Assistant General Counsel202-638-5777, ext. 6740 (Washington, DC) 800-356-9655, ext. 4185 (Madison, WI)[email protected] [email protected]

Valerie Moss Nichole SeabronDirector of Compliance Information Federal Compliance Counsel202-638-5777, ext. 6741 (Washington, DC) 202-638-5777, ext. 6739 (Washington, DC)[email protected] [email protected]

Paulette YoungRegulatory Affairs Specialist202-638-5777, ext. 6737 (Washington, DC)[email protected]


Examination Bill of RightsExamination Bill of RightsNCUA – National Credit Union AdministrationNCUA Region III – Atlanta, GA7000 Central Parkway, Suite 1600Atlanta, GA 30328

Tel: (678) 443-3000Fax: (678) 443-3020

E-mail NCUA at: [email protected]

Herb Yolles, Director, NCUA Region III

Joe Ostrowidzki David HibshmanAssociate Regional Director, Operations Associate Regional Director, Programs

Donna Woods, Director Larry Maynard, DirectorDivision of Supervision Division of Insurance

Mark Skaggs, Director TBD, Director Division of Special Actions Division of Management Services

Small Asset Size Small Asset Size Credit Union Credit Union ConferenceConference

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2011.03.22+SAS+Workshop+Exam+Rights

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