NWCUA Unveils New Disaster Preparedness Program RecoveryPro

It pays to prepare for the worst. RecoveryPro can help!

Your members look to you to protect their assets in case an unforeseen disaster occurs, so it’s critical for credit unions to have a blueprint for emergency preparedness.

Disruption or loss of access to core business functions can have severe consequences for credit unions and their members. RecoveryPro guides credit unions through the creation, maintenance, and testing of robust Business Continuity Plans (BCPs).

From Template to Preparedness

Templates and sample content lead the credit union through the collection and presentation of data, and a full content management system provides a secure online platform for management and staff to access the BCP for review and testing, or in the event of a disaster or work stoppage event.

Planning guides provide direction and support to your team and make the content development process user-friendly, maximizing the benefits of RecoveryPro’s subject matter expertise. The program walks credit unions though a complete business impact analysis to identify and prioritize key business processes, the creation of a business continuity plan for use in recovering from a disaster, and an incident management plan for use in responding to a developing event. From there, credit unions have the option to add more elements, such as risk assessment and comprehensive policies.

Modular publishing options in RecoveryPro allow you to separate action content from audit content, getting you to the information you need quickly in a disaster while also providing the deeper program, policy, and process information required by auditors.

You need RecoveryPro.

Let us help you navigate through the complexities of disaster preparedness. Take advantage of all RecoveryPro has to offer so your credit union stands ready for the unexpected and your members assets are protected.

KEY FEATURES:

  • Guidance on key information needed to develop planning objectives
  • Incident Response identifies what is needed to manage developing incidents
  • Business Impact Analyses identify and prioritize critical business functions
  • Actionable Business Continuity Plan components for any event type
  • Validation & maintenance to ensure your BCP is effective and up to date

Click here to learn more.

Question of the Week

Q. Do we have to perform CIP on a POD Beneficiary?

A. The Customer Identification Program (CIP) regulations define a customer as a person that opens a new account; and an individual that opens a new account for another individual that lacks legal capacity, such as minor; or an entity that is not a legal person, such as a civic club. By this definition, a POD beneficiary would not be considered a customer since they are not the individual opening the account. Since a beneficiary is not covered under the definition of a customer, they would not need to be included in the credit union’s CIP procedures.

However, the credit union is not prohibited from obtaining CIP information on a beneficiary and some do include it in their procedures as a requirement. Credit unions should take note that it might be difficult to obtain all identifying information on an individual that is not present at account opening (which is often the case for a POD beneficiary), but it is not impossible. Also, obtaining at least some of the information in addition to the beneficiary’s name, such as their date of birth and address, might prove helpful in identifying the beneficiary in the event that they collect the funds from the account.

Related Link

31 CFR 1020.100

Compliance Alerts

National Credit Union Administration

Submission of 2021 HMDA Data: The NCUA released Regulatory Alert 22-RA-02 to remind credit unions subject to the HDMA reporting requirements for calendar year 2021 that the deadline to submit the LAR data is March 1.

HMDA Data Collection Requirements for Calendar Year 2022: The NCUA release Regulatory Alert 22-RA-01 to remind credit unions of threshold requirements that would subject a credit union to collecting HMDA data for the calendar year 2022.

Consumer Financial Protection Bureau

CFPB Publishes 2022 Reportable HMDA Data Reference Chart: The CFPB published Reportable HMDA Data: a Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2022. The chart is intended to be used as a reference tool for data points required to be collected, recorded, and reporting under the Home Mortgage Disclosure Act.

Office of Foreign Assets Control

OFAC has updated the SDN list as of Feb. 3. The last update prior to this was Jan. 31.

Posted in Compliance News, Compliance News, Compliance Question.