Seven Compliance Rules for Non-Compliance Managers
by Anthony Demangone
Compliance. Auditors. Regulations. Examiners. These words lead to audible groans, gasps, and the shaking of heads or fists.
All too often, I’ve spoken to a credit union group only to see the air leak out of the room once they heard that I was a regulatory attorney who focused on NCUA rules and regulations. An attorney—and he’s talking on regs?
Listen, I feel your pain. But life does have rules. For those of you who are managers in a non-compliance area, let me share with you my “Seven Compliance Rules for Non-Compliance Managers.”
1: You are regulated.
Understand that your credit union, and your role within it, is regulated. NCUA, and many other regulators, have strong opinions on how you should do things. You ignore this fact of life at your own peril. The strong CEOs, executives, and managers I’ve met don’t shy from this important fact. They may not like regulations. They may argue for the loosening of restrictions. But they deal with the fact that they have to comply.
Along these lines, your specific role is regulated. I don’t care if you are in accounting, marketing, branch services, items processing, security, IT, or lending. Your role is regulated—don’t forget it.
2: NCUA writes most of this stuff down.
NCUA has a number of resources that can be very helpful. Here are a few:
- The Examiner’s Guide. This 32-chapter “manual” covers NCUA’s expectations in many, many areas. Look for chapters that touch upon your job, and start reading.
- The Federal Credit Union Handbook. This is a concise 76-page manual that tries to touch upon the major aspects of life as an FCU. If your federal credit union hires a new manager from the outside, this should be required reading.
- The AIRES Examination Questionnaires. NCUA examiners have a list of things that they go through when they visit a credit union. This grouping of questionnaires is a great way to prepare for an exam or to know what NCUA looks for in a given area.
- NCUA’s homepage also has an advanced search function. You’d be amazed what you find when you simply search. You can use this function to see, for example, whether NCUA has any thoughts on the use of Robert’s Rules of Order for board meetings. They do.