ARLINGTON, Va. - Is a race car sponsored by a credit union required to have a deposit insurance disclaimer below the institution's name? Can a coal miners' credit union allow customers to suspend loan payments while workers strike?
For answers to such tough questions, credit unions call on Jane Pannier and John R. Zasada, the question-and-answer team at the National Association of Federal Credit Unions.
Established in 1993, the Nafcu service helps credit unions with all aspects of compliance - everything from deciphering regulations to getting ready for an exam. Mr. Zasada and Ms. Pannier, the trade group's federal regulatory counsels, are often the last resort for confused institutions.
Many questions can't be answered on the spot. But whether the issues discussed are specific to credit unions or questions that nag at all types of financial institutions, the toll-free phone lines are rarely quiet.
"There are so many different types of regulations, that sometimes the members really don't know what to do," said Mr. Zasada, previously a compliance officer at the National Institutes of Health Federal Credit Union. "And a lot of them are comforted to know that others are having the same problem."
Nafcu receives about 30 calls a day, according to Tim Pryor, the group's director of regulation and compliance. The middle of the week is busier than Monday or Friday, he said, "but there's rarely a dull moment."
The credit union group's service is not the only compliance help line, but it was the first.
The Credit Union National Association, consisting of state leagues rather than individual institutions, relies on experts at member associations to provide compliance help. The American Bankers Association this year started a toll-free hot line, which doubles as a marketing and research tool. Other trade groups encourage calls from their members, but offer no formal question-and-answer line.
Mr. Pryor said the most pressing issues on callers' minds are Truth-in- Lending and Truth-in-Savings disclosures, and organizational issues such as conflict-of-interest problems. Disclosure issues and questions about the Community Reinvestment Act have dominated the ABA's hot line, according to director of compliance Cynthia Baltierra.
The conflict-of-interest issue underscores the differences between credit unions and banks, Mr. Pryor said. He said small credit unions may have management personnel who hold other jobs outside the institution. If one of those is, for example, a car salesman working at a credit union that offers auto loans, there may be a conflict of interest.
But, no matter the issue, the answer people at any compliance hot line can help callers only up to a point.
"We can't give legal opinions," said Ms. Pannier, formerly the CEO at United Auto Workers Federal Credit Union. "Our answers take the form of pointing the member to where they need to go."
Generally, that is a fairly simple task. About half of the questions take just 15 minutes to answer. Others can require hours of research. With the more complex questions, Nafcu calls on regulators at the National Credit Union Administration, the Federal Reserve, and other agencies.
While Mr. Zasada said most calls are run-of-the-mill inquiries, he's surprised with the breadth of questions, ranging from how to deal with the Americans with Disabilities Act to whether an NCUA-chartered credit union can drop the word "federal" from its name, which it cannot.
One harried credit union employee called Nafcu to ask if deposit insurance information had to be included with an institution's name, even when painted on a race car. The credit union was sponsoring the driver, and was confused whether disclosure requirements applied.
"They needed to know," Mr. Zasada said. "The car had to be painted that day because the race was the coming weekend."
To the delight of race fans everywhere, the disclosures didn't have to be made.
Other odd situations have higher financial stakes. A manager called from a coal miners' credit union that was facing a strike.
The walkout put the institution in the precarious position of having nearly all of its customers missing paychecks for an extended period. Thus, loan payments would be tougher to make, and money would be in short supply.
Mr. Pryor told the credit union official he could suspend repayment until the strike ended.
Some of the concerns may be different, but banking trade groups have their own versions of the Nafcu help line. The American Bankers Association has a toll-free, members-only hot line that has taken about 3,000 calls since its inception in January, Ms. Baltierra said.
Other trade groups perform similar tasks, but do not have a formal hot line. Some said it would be too costly, and others said their association doesn't need one.
CUNA spokesman Mark Wolfe said having state leagues handle calls allows his group to give members more individual attention.
"The advantage of having state leagues as the front line on these issues is that the experts know both state and federal laws," Mr. Wolfe said. "They're more easily accessible, and can sometimes go to the credit union. Our role is to provide the leagues with the information that they need to stay up-to-date."
Lamar Brantley, director of technical services and programs at America's Community Bankers, said his group sends out directories listing people to contact about nearly 100 issues. The group also answers commonly asked questions in its weekly newsletter, Washington Perspective.
Mr. Brantley added that the thrift group plans to expand its services to the Internet within a year, making them available to more institutions.
"It's one thing to help one member, but the key is to leverage that for other members," he said.
Trade groups have found that answering compliance questions can help them as well. Ms. Baltierra said the hot line was "the best market research we could ever acheive," allowing the group's lobbyists to learn what is on their members' minds.
Mr. Pryor concurred. He said each ring of the phone brings Nafcu more insight into credit union issues.