Meeting regulatory compliance requirements is a complex endeavor. One of the best ways a credit union’s leadership can successfully achieve compliance goals is to develop strong relationships with state and federal regulators. This requires planning and open engagement at all times.
When Should Credit Unions Engage with Regulators?
Harvard Law School points to four main opportunities for relationship building.
- Times of Inactivity – Keep regulators informed about current and upcoming industry needs. Ask about regulatory developments and show how the credit union is working to comply.
- Rule Creation Process – This is the time to offer feedback on rules and point out problems the regulator may not have considered.
- Examination Time – Help regulators become better informed about the credit union’s purpose, practices, and compliance program.
- Investigation Process – A helpful attitude and sustained conversation are the keys to addressing concerns that led to investigation.
Times of Urgency
Unexpected situations like the COVID-19 pandemic create the need for fast action and added communication. For this reason, the Illinois Credit Union League (ICUL) has facilitated virtual townhall meetings to provide credit unions opportunities for open communication with legislators and regulators.
Well-developed relationships with regulators and continuous communication can make a positive difference. For instance, few Illinois credit unions were initially ready to lend via the Paycheck Protection Program (PPP). ICUL asked state regulators to permit member referrals to other credit unions offering these loans, irrespective of field of membership. In just a few days of back and forth, they agreed.
A Good Internal Structure Helps Build Outside Relationships.
A prepared team fosters clear discussion. A few organization tips from MetricStream Insights are below.
- Form guidelines for when and how to communicate with regulators and apply their feedback.
- Create a communication calendar with exam dates to stay on top of sharing opportunities and exam preparations.
- A well-structured shared folder system helps teams collaborate on responses to regulators.
- Plan for meetings by going over a list of the documents needed, topics to cover, who will be involved, and what information each person will be expected to know and share.
Focus on Team Integration
An effective team works well together and according to Harvard Law School, regulators expect to see compliance leadership working with all departments to identify areas where regulations apply. Therefore, well-informed, collaborative leadership teams help credit unions gain good standing with regulators.
Teamwork is crucial during uncertain times. Recently, it helped address the broad nature of an authorization by the Secretary of the Department of Financial & Professional Regulation that exempts field of membership as a requirement to participate in any government program (including PPP) based on a referral from another credit union. ICUL ‘s internal team worked to craft guidelines and a few types of agreements around it, creating a structure to accompany the authorization and reaching out to credit unions. Now, a large number of credit unions are ready to be lenders and refer members!
Credit unions with sound internal structures and regular communication practices are ready to build positive relationships with federal and state regulators. These relationships will go a long way towards helping credit unions achieve their compliance goals.