NCUA Prohibits Two Individuals from Participating in the Affairs of Any Federally Insured Depository Institution

Prohibition is the regulator's remedy for conduct so severe that future participation poses unacceptable risk, yet every prohibited individual once held legitimate authority—granted by someone, at some moment, for some reason. The institution that appointed or permitted participation should have produced a decision record identifying the granting officer, the scope and term of authority, the business rationale, and the review schedule that would surface red flags before misconduct escalated to enforcement. When prohibition arrives, it reveals not only individual wrongdoing but also the absence of a structured access-governance artifact that made timely revocation impossible. Every decision, on the record—especially the decision to grant institutional authority.