JACKSON, Mich.-Credit unions cannot procrastinate when it comes to training staff on current and new regulations, one person is cautioning.
Chrissy Siders wears dual hats as VP of risk management and governmental affairs for CP Federal Credit Union, and VP of operations for CU Rx, the name for the risk management review process that is owned by CP Financial Services LLC, a CUSO owned by the $346-million credit union.
CU Rx offers risk management and compliance training and audits, with an ongoing training focus on regulatory compliance.
"There is a volatile regulatory environment that includes a significant number of agencies that are full of expectations for credit union employees," Siders said, noting the list includes NCUA, the Federal Reserve, the new Consumer Financial Protection Bureau and an increasing number of state agencies. "It does not matter what title a person holds within a credit union, there is a regulation that touches that person."
As a result, Siders said the CUSO is seeing increasing interest from credit unions seeking to train their employees on compliance with a laundry list of topics, including Bank Secrecy Act, identity theft red flags, financial exploitation of the elderly, Reg E and Reg CC. CU Rx also trains credit union boards of directors on BSA.
"Our staff that performs the training is certified in compliance," she said. "We make sure we stay well-educated on the regulatory process to ensure we are communicating everything we know. We use face-to-face training, and sometimes we train over the phone. We train early in the morning or later in the evening-whatever the need is for the credit union."
Siders acknowledged the time demands on many CUs mean training is often on the "back burner," and that the challenge is only magnified for CEOs of small CUs. "There just is not enough time or money to do training, leaving the credit union scrambling to get training right before the regulation goes into effect," she observed.
A "best practice" credit union would follow two tracks for compliance training, Siders recommended. First, when dealing with the many regulations that are already in place, CUs should set up a training calendar each year.
"That way everyone at the credit union knows that every June is BSA training. A calendar is very helpful," she advised.
Second, for new regulations, Siders counseled CUs to watch out for all the possible impacts on operations, including the need for signage on ATMs or in lobbies, new disclosures and new statements.
"Prioritize these changes on the existing compliance calendar to plan ahead as much as possible," she offered.
A Word Of Caution
Siders emphasized that CUs should not be lulled into a false sense of security just because new regulations are not grabbing headlines on a weekly basis. She warned the CFPB is running three campaigns concurrently, from mortgage disclosures to payday lending.
"The pace of new regulations has not slowed down," she declared. "The fact the CFPB is looking at these things means new regulations will be coming down. The states are coming out with new things. There are a lot of what-ifs out there, including key issues we are fighting for on the federal level such as member business lending. There is not the controversy as we saw from Dodd-Frank, but part of that is pragmatism-credit unions are figuring out that they have to comply and they are getting down to it."
