NCUA compliance is broader than a checklist. It connects governance, risk, and day‑to‑day operations to the agency's rules and supervisory expectations. The core anchor is 12 CFR Part 748, which requires a written security program and specific incident reporting. Examiners also evaluate consumer protection, BSA/AML, third‑party oversight, and alignment to FFIEC‑informed practices.

• Security program fundamentals (Part 748.0): Protect facilities and member information, prevent insider crime, and establish incident response and record retention. Include administrative, technical, and physical safeguards appropriate to size and complexity, with board oversight.
• Mandatory reporting (Part 748.1): Keep annual compliance certifications current and meet timelines for catastrophic acts (five business days), suspicious activity per applicable rules, and reportable cyber incidents within 72 hours of reasonable belief or third‑party notice.
• BSA/AML program (Part 748.2): Board‑approved and documented. Include internal controls, independent testing, a designated BSA officer, training, and a CIP consistent with federal requirements.
• Safeguarding and response (Appendix A/B to Part 748): Risk assessments, layered controls, vendor oversight, and a written response program for unauthorized access, including member notice when warranted.
• Third‑party risk: Contracts and monitoring must ensure service providers meet your security and BSA/AML obligations, including incident notice back to you so you can meet NCUA timelines.

A strong Compliance Management System (CMS) translates regulatory requirements into reliable execution. Structure it so it is explainable to your board and examiners, and scalable as you grow.

• Governance and accountability: Define board and committee oversight. Keep minutes reflecting policy approvals and periodic reporting on risks, incidents, audit results, and remediation status.
• Risk assessment cadence: Perform enterprise and control‑specific assessments covering information security, BSA/AML, fraud, operations, and third parties. Rate inherent risk, control design, and residual risk; drive testing plans off the results.
• Policies and standards: Maintain a single source of truth for Part 748 security, BSA/AML, incident response, vendor risk management, access controls, data retention, and disposal. Map each control to the applicable citation and owner.
• Training that sticks: Role‑based training for front line, operations, IT, and the board. Include cyber incident recognition and escalation paths to ensure the 72‑hour clock is met.
• Monitoring and QA: First‑line self‑tests on key controls (user access, alerts, SAR/CTR timeliness, patching, backups, vendor due diligence). Track exceptions and age of issues.
• Independent testing and audit: Risk‑based scope covering Part 748, BSA/AML, and safeguarding guidelines. Validate that incident response playbooks, member notice, and reporting workflows are functional.
• Vendor oversight: Due diligence, contractual clauses for security and breach notice, ongoing monitoring, and documented reviews. Ensure providers enable you to comply with reporting and safeguarding requirements.
• Issue management: Centralize findings, assign owners and due dates, verify remediation, and keep management and the board updated.

Translate requirements into examiner‑ready evidence and timely actions.

• Key artifacts examiners expect:
  • Board‑approved security and BSA/AML programs, with minutes
  • Risk assessments and asset inventories tied to controls
  • Incident response plan with cyber, insider threat, and member notice workflows
  • Vendor risk files: due diligence, contracts, monitoring results
  • Training logs, testing plans, audit reports, and remediation trackers
• Control checkpoints aligned to Part 748:
  • Access management, segregation of duties, and change control
  • Data protection at rest and in transit; secure disposal
  • Logging, alerting, and incident triage with defined severity
  • Business continuity for vital records and critical services
• Non‑negotiable reporting timeframes:
  • Cyber incidents: notify NCUA as soon as possible and no later than 72 hours after reasonable belief or third‑party notice
  • Catastrophic acts: notify the regional director within five business days
  • Suspicious activity: follow applicable timeframes for detection, decisioning, and filing
• Practical readiness tips:
  • Run tabletop exercises for cyber and unauthorized access scenarios, including vendor‑driven incidents
  • Pre‑stage notification templates and contact lists so the 72‑hour clock does not slip
  • Automate evidence collection where possible, and version policies with clear ownership and dates
  • Document management's rationale when accepting residual risk, and report it to the board