In NCUA’s 2022 Supervisory Priorities letter, NCUA Chairman Harper indicated that examiners will be focusing on reviewing policies covering loan workout strategies, risk-management practices, BSA and AML/CFT, ALLL, fair lending, and overdraft, among other priorities. Examiners are looking to ensure your governing business processes include effective written programs that are preventing or reducing regulatory violations and risk.
Policies set the parameters for decision-making but should also leave room for flexibility. They show the “why” behind an action. Procedures, on the other hand, explain the “how.” Policies and procedures should specifically address the impact on the credit union’s operation and should be reviewed by the board of directors and adjusted annually at minimum, or more often as necessary.
Balancing the need for helpful details within a policy while also being broad enough to not require revisions every time there is a minor change internally concerning risk controls, operations, or staff titles within the credit union enables employees to better manage their work.
“Mapping” or connecting, your policies with procedures and the corresponding internal risk controls ensures that, when relevant components of your credit union’s operating environment are affected by regulatory requirements or changes, every component impacted is uniformly addressed across business units.
For many credit unions, policy management is a very manual/labor intensive process built on spreadsheets and email reminders. Having a technology that allows you to simplify that process of connecting/mapping everything together will help your credit union demonstrate to your examiners the thoroughness of your compliance program, will bring efficiency and consistency to your work, and will help increase compliance confidence by mitigating risk of error or omission.
Credit Union Compliance Management System PLUS (CU CMS+) policy and document management feature allow a credit union to formalize the process of creating and maintaining its internal policies and procedures with a six-stage, life-cycle process. In addition, the system brings “mapping” within the workflow process. This means when the regulator walks in and asks to see how you’ve addressed the latest regulatory change, how it has impacted your credit union, and how you’ve changed your policies, procedures and related risk controls to match the requirements, the regulatory change is reflected in one effective, documented location.
CU CMS+ users will soon have exclusive access to new sample policies being added to the system library including those with board approval requirements such as:
- Records Preservation
- Interest Rate Risk
- Liquidity and Contingency Funding
- Loans and Lines of Credit
- Loan Participations
- Loan Workout
Operational checklists are also being developed for CU CMS+ users to help ensure all business lines are within compliance. Users can expect to see these added to the system in the near future.
- Member business loans
- Truth in Lending including:
- Real Estate Loan Estimate
- Real Estate Closing Disclosure
- Credit Cards, Account Opening and Management
- RESPA including:
- Mortgage Servicing Disclosure, Transfer, Error Resolution, Requests for Information
- Special Information Booklet and List of Homeownership Counseling
- NCUA’s Accounts
- Money Market
- Certificate Disclosures
- NCUA’s Records Preservation Program
To learn more about CU CMS+, please visit cuna.org/cucmsplus.