Compliance Center: What Compliance Support Does Your Association Offer?

The Northwest Credit Union Association (NWCUA) provides a wealth of compliance resources for our member credit unions, but do they know what is available for them to tap into?

The NWCUA guides and consults with credit unions on all matters of compliance with complex state and federal laws and regulations. Our full-time staff of compliance experts, as well as valuable online resources and solutions, are available to provide immediate assistance.

Our primary job is to answer compliance questions for our member credit unions, through these resources:

  • Compliance Hotline: 1.800.546.4465 (only department that has its own 800#), or our extensions
  • Compliance@nwcua.org or emails directly to us
  • Questions submitted through CAL

We answer around 3,000 questions for our members every year.

Resources

  • Compliance Answer Library (CAL) – Contains over 1,200 Compliance FAQs, and is continually updated with new items. All items are reviewed yearly to ensure accuracy and relevance.
  • InfoSight – Online library of compliance information and documents including treatises, compliance resources, and bulletins (Fraud alerts, RIPT).
  • Compliance Calendar – 12 month forward looking schedule of compliance deadlines.
  • CU PolicyPro – Brought this to our credit unions in November 2012. It includes nearly 300 model policies for credit unions, updated regularly to keep pace with the changing regulations.
  • Regulatory Implementation Project Toolkit (RIPT) – We created this resource for our members, taking basic project management tools and applying them to implementation of new mortgage regulations. 
  • ComplySight – New offering. Compliance Management System which will allow credit unions to measure and track the compliance process across the enterprise.

Member Education

  • Compliance Bulletins – Detailed information regarding new news.
  • Fraud Alerts – Informing our members about fraud trends, robberies, etc.
  • Anthem – Compliance articles every week, Legal Update, and Compliance Question of the Week.
  • Listservs – (Compliance and Collectors)
  • Networking Councils – (Compliance and Collectors)
  • In-Person or Web-Based Training – Compliance/Regulatory Update, BSA for Boards, Board Member duties and responsibilities.

Compliance Question of the Week

What do we need to do when contracting with a 3rd party vendor?

NCUA’s Letter to Federal Credit Union (07-CU-13) lays out a number of factors that credit unions should consider before entering into a third party relationship.  According to NCUA, credit unions should consider the following:

  • Will the third party relationship compliment the credit union’s overall mission and philosophy?
  • How critical is the activity being outsourced?
  • How will the third party relationship impact (if at all) the credit union’s strategic plans (long term goals, objectives and resource allocation)?
  • How will the risks/benefits of outsourcing the particular function compare with keeping the function in house?
  • How will the third party relationship impact (if at all) seven risk areas (credit, interest rate, liquidity, transaction, compliance, strategic, and reputation risk)?
  • Does the credit union staff have the expertise to manage and monitor a third party relationship?
  • Will the third party relationship create additional insurance responsibilities for the credit union?
  • How will the relationship impact the credit union’s membership (positive and negative)?
  • Does the credit union have an effective exit strategy?

The guidance highlights the need for credit unions to perform extensive due diligence and review the risks/benefits of outsourcing member services prior to engaging in a third party vendor relationship.

Related Links:

Legal Briefs

National Credit Union Administration (NCUA)

The NCUA’s July Board Meeting video is now available online.

The archived webinar of NCUA Chairman Matz’s July Town Hall is now available. Credit unions can access the video here.

Consumer Financial Protection Bureau (CFPB)

The CFPB has released an index that lists all of the Outlook Live webinars on the TILA-RESPA Integrated Disclosure Rule in one place. The index breaks out the webinars by topic question and provides a link to the webinar and states which segment of the webinar the information can be found in.

Federal Reserve Board (FRB)

The August edition of Fedflash is now available.

The FRB has published its final rule that establishes a risk-based capital surcharge for the largest, most interconnected U.S.-based bank holding companies. The final rule is effective on December 1, 2015, but has some sections that will not take effect until January 1, 2018.

The FRB clarified Regulation II (related to debit card interchange fees) regarding interchange transaction fees and transaction monitoring costs. The clarification comes after the Court of Appeals upheld the Board’s Final Rule.

Department of Veterans Affairs (VA)

The VA has issued a final rule to amend its regulations that govern adjustable rate mortgages made in conjunction with the Home Loan Guaranty program. The rule is designed to align the VA’s ARM disclosures with the TILA ARM disclosures. The effective date of this rule is September 11, 2015.

U.S. Department of Housing and Urban Development (HUD)

HUD announced that is has launched a resource locator app. The app will help individuals connect with local HUD Offices, provide information about commonly requested housing related resources from HUD and provide maps that interface with other applications.

Financial Crimes Enforcement Network (FinCEN)

FinCEN issued a ruling on the application of FinCEN’s regulations to persons issuing physical or digital negotiable certificates of ownership of precious metals.

Office of Foreign Assets Control (OFAC)

OFAC has updated the SDN list as of August 5, 2015. The last update prior to this was August 3, 2015.

Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance, NCUA.