Rock of stability

A Credit Union’s underlying compliance structure can be a strong foundation for efficiently managing constantly changing regulations

by Lisa Hochgraf

During a recent webinar hosted by CUES Supplier member The Members Group, De Moines, Iowa, Jeff Anderson described the recent and likely future changes in the regulatory situation for credit, debit and prepaid cards, as well as for mobile banking.

“There are a lot of unknowns out there,” said Anderson, regulatory counsel for PolicyWorks LLC. “We have potential changes in the credit card area. We don’t know what the heck is going on with interchange. How do you prepare for that when you don’t have actual proposed rules to look at?

“The important thing,” he emphasized, “is to have a good compliance management system.”

While financial institutions with less than $10 billion in assets do not have to abide by the letter of the Consumer Financial Protection Bureau’s guidance on managing compliance the agency’s compliance guide still “gives good guidance about what a solid compliance program looks like,” Anderson said. He also suggested that CUs look at the National Credit Union Administration’s Aires questionnaire from 2007, and its eight guiding questions.

“The idea behind a strong compliance management program is to address compliance efficiently,” Anderson emphasized, “so you have a structure in place, so when new products come aboard and new regulations come aboard, you address them efficiently, saving you time and money. If you’re doing that, that will, in turn, reduce your risks of potential violations.”

Anderson elaborated on CFPB’s four main components of a good compliance management system:

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