ONTARIO, Calif.-Credit unions feeling overwhelmed by the compliance burden should be looking to their respective state leagues, the league's affiliates and business partners, and even third-party vendors.
That is the message from Rita Fillingane, VP-research and collaboration for the California and Nevada CU Leagues. Fillingane oversees the research and information department, as well as CURoots Services, which offers shared compliance services, internal audit services, and CUVitality, a collective health-benefits solution.
CURoots Services was a separate entity from the CCUL/NCUL until March. Fillingane said league members from the two states have access to full-service internal audits, including reviews of several practices (such as BSA), ACH audits and the SAFE Act. Specialized project assistance also is available.
"Based on what the regulation requires, our audit team goes in and reviews policies and procedures and transaction reports to ensure the credit union is complying with all suspicious transaction requirements," she explained. "The team also checks on training to ensure the staff is trained accordingly."
Generally, those are annual audits as required by the regulations, Fillingane continued. She said some internal audits CURoots performs might not be specifically required, but they are considered necessary under safety and soundness requirements. One example would be a dormant account review that makes sure there is no inappropriate use of those funds, such as internal embezzlement fraud.
"Those are the types of things credit unions can do to check after the fact," she said. "Compliance is here to stay, it is not going away. Credit unions have recognized that and are taking compliance seriously. No matter what size, they are making sure these regulations are implemented accordingly."
If a credit union is large enough to have a compliance officer on staff that is one way of ensuring compliance, but if not, Fillingane noted, often a compliance committee is necessary to make it the responsibility of several people.
"There is no one answer to 'how big' a credit union has to be to necessitate a full-time compliance officer, because it depends on the credit union," she observed. "Even some large credit unions do not have a full-time compliance officer; it depends on the structure of the credit union and the services offered."
DIY Compliance
For credit unions attempting to address the compliance burden on their own, Fillingane recommended developing tracking systems and calendars to ensure awareness of compliance deadlines.
Other resources offered by the California and Nevada CU Leagues include TIP (technical information procedures) Bulletins, which summarize new regulations for ease of understanding.
"Regulations often can be in legalese, so the TIP Bulletins break them down and lets credit unions know what they need to do to implement. To keep up with education, the leagues also provide a number of regulatory webinars."
Another resource is a new member benefit, CU PolicyPro. Fillingane said it has more than 200 model policies related to regulations that credit unions can modify to fit their needs. CUPolicyPro also includes a policy management system that allows a CU to manage all policies with a content management system.
"The credit union can determine who has access," she said. "For example, with the new mortgage rules coming out, policies related to mortgage lending will need to be updated. The model policies are updated twice per year to capture changes, and then can be used as a guide."
Vendor Assistance
Vendors also are a source, Fillingane noted, especially forms vendors and data processors. Again referring to mortgage requirements, she noted mortgage forms will need to be updated.
"It is important to have good working relationships with vendors so they will tell the credit union what needs to be done," she said, noting some vendors guarantee performance.
"Certainly there is more the credit union has to do internally, but there are a lot of resources available," she said. "Education is a big requirement, along with tracking. CUNA also offers resources, as does the Consumer Financial Protection Bureau."
