Trust Is Not an Internal Control: David Reed on Fraud and the Supervisory Committee

www.marktreichel.comhttps://www.linkedin.com/in/mark-treichel/In this episode of With Flying Colors, host Mark Treichel welcomes back David Reed of Reed & Jolly, PLLC — a longtime credit union attorney, former general counsel, and self-described “recovering supervisory committee member” who served a decade on a supervisory committee, including six or seven years as chair. David reached out after listening to Mark’s earlier coverage of the Jackson Area Federal Credit Union case, just as he was kicking off a two-day national supervisory committee school, and the timing made for a rich conversation.The heart of the discussion is fraud prevention through the lens of the supervisory committee. Using the Jackson Area allegations as a teaching tool — and stressing repeatedly that everything is alleged, drawn from NCUA’s amended lawsuit — David walks through why trust is not an internal control, why insider accounts are the single greatest fraud risk at smaller credit unions, and why occasional reviews of senior executives’ own accounts (even just by volume) should be routine and done independently. He and Mark unpack the “clipboard audit” problem, the limits of pop teller audits, and the difference between a full CPA opinion audit, agreed-upon procedures, and a supervisory committee doing the work itself.David makes a direct case that the $500 million CPA opinion-audit threshold is outdated — arguing it should drop to $250 million — because technology has erased the product-and-service gap between small and large credit unions while leaving the same fraud exposure. He notes that many of his sub-$500 million clients already choose to get CPA audits because they add accountability and assurance, and that scope can be added to any audit like a cafeteria plan, including a targeted review of senior-executive and insider accounts.The conversation then broadens. On the NCUA board, David explores the implications of changes to Humphrey’s Executor — the prospect of removable board members, a possible “clean sweep” every administration, the chilling effect on recruiting qualified people to serve partial terms, and the resulting shift of power toward the permanent bureaucracy. On succession planning, he champions a “junior varsity governance” model with associate board and committee members, and reframes every incumbent nomination as a re-selection that deserves real evaluation. On collections, he urges credit unions to turn the same predictive analytics they use to find lending opportunities inward — reaching members before they fall two or three payments behind and stop answering the phone.Throughout, David returns to one theme: most credit unions already have the tools, processes, and even the results they need — the question is whether anyone is actually activating and reviewing them. Reach David Reed at [email protected].