Top 10 for 2010: Compliance Issues Facing CUs

HARRISBURG, Penn.-The Pennsylvania CU Association's Compliance Cavalry lists the top ten issues facing this state's credit unions and how to address them.

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1. CARD Act interpretation and implementation: Read. Read. Read. Great sources are InfoSight*, and CUNA e-Guide and CUNA Final Analysis. Review current policy and procedures and make changes accordingly.

2. Reg Z interpretation and implementation assistance: Read. Read. Read. Great sources are InfoSight, and CUNA e-Guide and CUNA Final Analysis. Review current policy and procedures and make changes accordingly.

3. Create a vendor due diligence risk assessment: List all credit union vendors. Risk rate each and document all research the credit union performed before entering into a contract with all high- and moderate risk vendors.

4. Create VDD policy: Start with a good "canned" policy from CU Policy Pro** and modify it to fit the credit union's needs.

5. Mortgage Disclosure Improvement Act interpretation and implementation assistance: Read. Read. Read. Great sources are InfoSight, and CUNA e-Guide and CUNA Final Analysis. Review current policy and procedures and make changes accordingly.

6. Review and update the information security policy: Compare the credit union's current policy to one from CU Policy Pro and modify it to include all updates and changes.

7. Review and update Loan Policies: Compare the credit union's current policy to one from CU Policy Pro and modify to include all updates and changes.

8. Mandatory policy review: Review the credit union's current policy manual to ensure all federally required policies are in place. Make a list of needed policies and supply two or three new ones to the board of directors each month for approval.

9. & 10. Training (BSA, ID theft/Red Flags): Self explanatory, and Recent NCUA Exam finding review: Self explanatory


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