What is Three-Dimensional Compliance?
by Steve Van Beek
Last week, I shared two slides from my upcoming presentationHow the CFPB Impacts Your Credit Union at NAFCU’s Directors Conference in Asheville, NC. One of the key takeaways will be the idea of Three-Dimensional Compliance.
So, what is Three-Dimensional Compliance? In short, it is a new way to think about the role compliance plays in the credit union. Here is a snippet from my article in the May/June The Federal Credit Union magazine:
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“Beyond the Checklist
The creation of the CFPB means that credit unions need to review the role compliance plays in the credit union. Often the compliance officer is brought into a discussion late in the process, and her job is to approve or disapprove a particular action based on the regulatory requirements. Going forward, this “yes or no” approach to compliance will need to change. The CFPB’s focus is principle-based as well as requirement-based. Not only will credit unions need to determine if their product or service is compliant with laws, regulations and guidance, but they will also need to expend resources to document that the product or service provides a benefit to members.
When new requirements are issued, credit unions won’t be able to simply work through a checklist of new requirements and make tweaks to their products and disclosures. They will also need to undertake a three-dimensional analysis of the product or service, asking: