Hello! I am new to the credit union space, and we are currently working on associate account (insider) testing. In the past our team has looked at member accounts for every board members and related parties, C-suite, SVPs, and VPs, and then once that is complete sample a small number of employees. We are around $6 billion in assets so our VP pool is over 50 employees, so a lot of work. The staff believes we've always tested all VPs because of some previous regulatory scrutiny, but I don't have any documentation of that, and don't see clear language within the NCUA Exam Guide that indicates all VPs should be tested. We do test insiders annually and VPs take up the majority of the work each year.
I am curious to what level on the org chart others do their insider testing, and specifically whether or not others could verify if they've seen regulatory scrutiny for not testing all VPs. I would like to take a risk-based approach and still perform insider testing each year on SVPs and above, but test all VPs on a rotating basis over a 2 or 3 year period (test half one year, half the next, etc).
Thank you so much for your help. I look forward to networking with this group.
