The National Credit Union Administration (NCUA) has a final rule on succession planning that is effective
January 1, 2026, which requires all federally insured credit unions (FICUs) to establish and adhere to a written succession plan. This rule aims to protect the National Credit Union Share Insurance Fund and ensure the safety and soundness of the credit union system.
Key Requirements of the NCUA Succession Planning Rule
The final rule places responsibility for the succession plan with the credit union’s board of directors. The board must approve a written succession plan that aligns with the credit union’s size, complexity, and operational risk. This plan needs to be reviewed and updated at least every 24 months, or more frequently as determined by the board. Additionally, new board members are required to become familiar with the plan within six months of their appointment.
Covered Positions
The rule mandates that the succession plan cover key positions, including members of the board of directors, management officials (such as the CEO and CFO), senior executive officers, and any other personnel deemed critical by the board.
Required Plan Content
For each covered position, the plan must outline the position title, any known anticipated vacancy date, the strategy for permanently filling the position, and the approach for recruiting candidates, including how diversity of skills will be considered to ensure the credit union’s safe and sound operation.
Resources and Assistance
The NCUA offers several resources to assist credit unions with compliance, including a Succession Plan Template (https://ncua.gov/files/agenda-items/succession-plan-template-20241217.pdf), support through the Small Credit Union and Minority Depository Institutions Support Program, and online training via the NCUA’s Learning Management System (https://ncua.csodfed.com/client/ncua/default.aspx).


