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In today's operating environment, ensuring that a credit union is in compliance with a growing and changing host of legal and regulatory requirements is often a full-time occupation. Responding to the need, CUcorp has introduced a new fee-based service providing credit unions with the customized training and consulting required to navigate today's challenging regulatory maze — the CUcorp Regulatory Compliance Consulting Service.
"Many credit unions may have already received a letter introducing CUcorp's Regulatory Compliance Consulting Service or may have heard about the service through their MCUL business consultant or League consultant," said MCUL Governmental Affairs Vice President Patrick La Pine. "Or, they may have picked up materials about the service at the 2006 MCUL Annual Convention & Exposition or at the MCUL Governmental Affairs Conference.
"This is an important new service, one that we're sure will fill a critical need for Michigan credit unions — and we want to make certain credit unions are aware of it."
In addition to a telephone help line and published, on-line or broadcast training programs, the new service allows credit unions to receive individualized, in-depth attention to their regulatory compliance and training needs — on site and at their convenience.
"The Regulatory Compliance Consultant will travel to credit union facilities to train individuals or to present workshops to all or a portion of a credit union's staff," said MCUL Regulatory and Legal Affairs Director Michael DeFors. "This service can provide assistance whether a credit union is preparing for an upcoming examination, responding to issues raised in an examination, seeking to develop a comprehensive compliance program, or seeking detailed assistance with identified areas of risk."
The Regulatory Compliance Service already features four specific separate areas of training: Web Site Compliance Review, Compliance Officer Training, Bank Secrecy Act/Anti-Money Laundering Act (BSA/ AML) Training; and Policy Development and Customization.
These areas were chosen based on credit union demand and the impact of certain regulatory changes in the credit union environment, DeFors said.
Serving in the newly created position of Regulatory Compliance Consultant is Stephon Johnson, who joined CUcorp staff in March (see below).
Web Site Review
MCUL General Counsel Veronica Madsen conducts the Regulatory Compliance Service's Web site reviews, a responsibility for which she is particularly well qualified. Madsen's years of experience have gained her a thorough knowledge of the various regulations governing credit union Web site presentation and usage. She has even conducted training sessions for NCUA examiners, teaching them what to look for and how to conduct a review of credit union Web sites.
"I've met with OFIR examiners as well in order to determine and advise credit unions on what those examiners will look for during an examination," Madsen said.
The CUcorp Regulatory Compliance Service can review a credit union's Web site for compliance with applicable consumer protection and credit union laws and regulations, including:
- Truth in Lending (Regulation Z);
- Truth in Savings (NCUA Rules and Regulations Part 707);
- Equal Credit Opportunity Act (Regulation B);
- Equal Housing Lender Logo Disclosure;
- Privacy Policy (NCUA Rules and Regulations Part 716);
- Funds Availability Act (Regulation CC);
- Home Mortgage Disclosure (Regulation C);
- NCUA Insurance Disclosure Requirements;
- Consumer Leasing Act (Regulation M);
- Nondeposit Investment Product Requirements;
- EFT Act (Regulation E);
- COPPA (Children's Online Privacy Protection Act);
- E-Sign Act.
"These reviews can be conducted on an annual, biannual or quarterly bases," Madsen said. "As part of this comprehensive service, a credit union will also receive an inclusive report of the findings following the review. The report will explain any regulatory requirements that the credit union's Web site has not met and provide recommendations for correcting each case of non-compliance.
"The consultant and report will provide sample terminology and disclosures to ensure the Web site is in full accord with existing laws and regulations."
Compliance Officer Training
Properly handling today's plethora of regulatory requirements requires extensive staff knowledge and training, and the CUcorp Regulatory Compliance Service is there to respond to this need.
"Upon request, we will contact your credit union and discuss the scope of the training desired," Johnson said.
"Upon agreement, I'll travel to your credit union and train individuals or conduct workshops as needed, utilizing audiovisual, hard copy and other training resources as required."
Forms for feedback and evaluation will also be provided to training participants to ensure that the service is as effective and focused as possible, he added.
"Compliance Officer Training focuses on assisting credit unions with organizing comprehensive and effective compliance programs," Johnson said. "If your credit union doesn't have a Compliance Officer, we can assist with the criteria for selecting and developing one.
"The Compliance Officer will be trained to recognize and understand the relevant regulatory issues and to implement, update and train the remaining staff on internal policies and regulatory requirements."
The program explains the need for a comprehensive compliance program and a qualified Compliance Officer; discusses applicable internal policies and procedures; equips the credit union and Compliance Officer to remain up to date with regulatory developments; provides resources for finding answers to regulatory questions, continuing training and professional development; and highlights the basics of the relevant rules and regulations.
BSA/AML Training
The CUcorp Regulatory Compliance Service can also respond to credit union requests for training in connection with the Bank Secrecy Act, the Anti-Money Laundering Act and related provisions. Johnson will contact the credit union upon request and discuss the scope of the training desired.
Upon agreement, the Regulatory Compliance Consultant will travel to a credit union and train individuals or conduct workshops as needed. Forms for feedback and evaluation will also be provided.
"BSA/AML Training focuses on assisting credit unions with organizing comprehensive, effective BSA/AML compliance programs," Johnson said. "If your credit union does not have a BSA Compliance Officer, we can assist with developing the criteria for selecting and training one."
A BSA compliance officer is trained to recognize and understand the relevant regulatory issues and implement, update and train staff on internal policies and regulatory requirements, Johnson noted.
The program explains a credit union's need for such a BSA compliance program and compliance officer; discusses the applicable content of internal policies and procedures; highlights the basics of the relevant rules and regulations; and provides information on how to prepare for a BSA/AML examination.
Policy Development, Customization
Some credit unions may have already benefited from CUCare's Operations Manual Policy offerings, including Accounting, Administrative, Asset Liability Management, Fair and Accurate Credit Transactions Act (FACTA), Investments, Lending, Operations, Other Real Estate Owned, Records Retention and Security Policies.
The CUcorp Regulatory Compliance Service can respond to individual credit union requests for new and updated policies. "We can also review and customize existing policies to make sure they adequately reflect regulatory requirements, as well as a credit union's mission, values, product offerings and operations," Johnson said.
Early response to the new CUcorp service has been strong, DeFors said.
"It's no news to our credit unions that regulatory compliance has become more complex and demanding," he said. "But individual credit unions have individual needs in the compliance area, which is why the CUcorp Regulatory Compliance Service offers a selection of services. Each credit union gets exactly what it needs and pays for only what it needs."
Credit unions may obtain more information regarding CUcorp Regulatory Compliance Consulting Services by contacting their CUcorp Business Consultant at (800) 262-6285, Ext. 534.
Meet Stephon Johnson
Stephon E. Johnson is the point man for the new Regulatory Compliance Service, joining MCUL/CUcorp staff in March in the newly created position of CUcorp Regulatory Compliance Consultant. In his duties, he works alongside MCUL Regulatory and Legal Affairs to stay abreast of current and changing regulatory compliance laws and requirements for credit unions.
A graduate of Cass Technical High School in Detroit and the University of Michigan, Johnson earned a law degree from the University of Texas. While in law school, he worked at the Texas State Sunset Advisory Commission, researching and analyzing expiring state laws for congressional review, and as a state senator's aide, responsible for constituent affairs and legislation analysis.
Johnson has also earned an M.B.A. from the University of Pennsylvania, Wharton Graduate School of Business. In business school, he dual-majored in both Public Policy Management and Finance with a concentration in Financial Regulation. Johnson interned in an international accounting firm's New York Tax Consulting Office, interpreting tax regulations affecting the insurance industry and studying the regulatory reporting requirements for foreign investment in U.S. real estate.
He comes to the CUcorp after more than 17 years of practicing law, starting his legal career with major law firms, practicing primarily in the public finance, corporate and taxation areas. Eventually forming a small law firm, he concentrated in commercial transactions and litigation, estate planning and probate areas.
He is also certified as a credit union compliance expert (CUCE) and a member in good standing of the State Bar of Michigan (Tax, Business Law Sections). Born and raised in Detroit, Johnson has resided in suburban Southfield for the past 11 years.
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Regulatory Affairs
