NEW YORK-All the attention may go to new regulations, but one person is reminding that CUs must continue to monitor some older threats associated with Reg E.
"It seems like in the feedback we're receiving form a lot of our client base, the anti-money-laundering and BSA has become a very stringent audit," said Jason Moses, manager, implementation services at FI Compliance Solutions.
Moses noted that because Reg E covers so much-including EFT, information security, bank secrecy and more-CUs must have sound enterprise risk management programs in place "to make sure that they are proactively monitoring all of the potential risks that come about within the organization."
"One key strategy is the due-diligence process and the member ID programs that are implemented within credit unions, because that goes hand-in-hand with making sure that we have sound programs in place where we're doing our due diligence, we're keeping updated on potential high-risk clients," he said. "We don't want to have a high-volume influx of clients where there can be potential fraud and make us even more exposed than we want." Moses stressed the importance of aligning ERM programs with member ID, while linking both to anti-money-laundering and Reg E.
Moses also reminded about the reputational risk that can come from non-compliance. "When credit unions get a specific fine through an audit and they're not compliant, members tend to find out about that more so than at a bank, because there's more visibility there. SO they have to be very careful about how they go about their business."
