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Winter 2012
Navigation Compliance
While not an exact comparison by any means, we at CU Solutions Group have a personal appreciation of the rigor and resource investment it takes for credit unions to meet their compliance requirements. Our “compliance requirement” is the SAS 70 certification process we go through on a regular basis to help test and ensure we have solid controls in place to protect the websites, data and other important information entrusted to us.
We do it because it is the right thing to do. But we also do it because we know it helps credit unions with their own compliance efforts in the area of vendor due diligence. In addition to our SAS 70 certification, as the rest of this newsletter discusses, we are also there to provide guidance, products and services to help credit unions with their compliance needs wherever we can – along with other credit union system organizations like your league and CUNA.
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Featured Products/Services
 
Name: Extra Credit Union
State: Michigan
Assets: $196,553,957
Members: 21,136
Website: www.extracreditunion.org
Sometimes a credit union “gets it right” by paying attention to the little things – like compliance. Being prepared is half the battle and Extra Credit Union accomplishes this by ensuring all of their policies and manuals are organized and easily accessible.
They use the CU Solutions Group product CU Policy Pro to stay on top of things, “It helps with examiners when they want to see a policy on bank secrecy or identity theft. It’s all easily available,” states Jeffrey DuHadway, Extra Credit Union training coordinator.
With a single program, Extra Credit Union can quickly and easily find operation manuals, update lending policies, access and print board policy materials and select pertinent policies for new employee orientation. DuHadway explains, “Instead of pulling out a thousand-page document trying to find something, you can search for what you need and it’s readily available.”
Your 411 to the CMS
Banner Ads
The Content Management System (CMS) banner ad module allows you to create categories for your banner ads which can help your credit union to promote specific products and/or services.
To get started, create a 'Savings' category in the banner ads section of the CMS. Then, add your various banner ads that promote your CDs, IRAs, Save to Win program, etc.
Not only can you place these category-specific banner ads into that category, you can add them to any other related category you’ve created. And remember, you are able to set the speed that your banner ads rotate.
CU PolicyPro
Is your credit union getting bombarded with new regulations, products, or policies? If you’re not quite sure how to smoothly incorporate them into daily operations or to meet regulatory requirements, CU PolicyPro can help make life easier for your credit union.
The Operations Policy Manual in CU PolicyPro contains comprehensive policies and regulatory guidance – developed and written especially for credit unions by regulatory (legal and financial) experts. CU PolicyPro is designed for credit unions to customize and implement policies that are particular to the individual credit union.
The format is clear and easy-to-use so you can find the information you need when you need it. Stop worrying about regulations, inspectors or other worse case scenarios.
CU PolicyPro has it all covered with their Operations Policy Manual:
• Specific to credit unions
• Researched and written by experts
• Secure, Web-based platform with instant worldwide access
• Policy statements combined into a single, searchable volume
• Designed for federal regulatory compliance
• Supports NCUA Examiner requirements of “safety and soundness”
• Policies may be easily customized, modified, added or replaced
To learn more about CU PolicyPro please email info@cusolutionsgroup.com or call 800.262.6285 for more information.
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Protect Your Credit Union with a Social Media Policy
If your credit union is like many organizations, you’ve jumped onto the social media bandwagon enthusiastically, but without having a social media policy in place. Good news – it’s not too late to develop and implement one! All it takes is a little thought, preparation and research to create a thorough policy.
When we say social media, we’re talking about Facebook, Twitter, LinkedIn and even blogs. If your credit union is participating in any of these platforms, have you determined where they fit into your overall strategic plan and philosophy? Have you analyzed the potential risks involved? These risks might include:
• Security risk – With all of the back and forth communications, you may be at risk of system intruders
• Regulatory risk – Anything you post could be considered advertising, which may be subject to compliance issues
• Legal risk – Social media has the potential of opening your credit union up to lawsuits, compliance problems, copyright issues and even employee discrimination
• Reputational risk – An erroneous post or slapdash comment could open the door to negative feedback and a public relations nightmare
By adopting a social media policy, you can protect your credit union from these risks and even fines or expensive legal fees. Each social media platform comes with its own risks and considerations. And since all are essentially electronic forms of communication, they can be construed as advertisements.
Here are points to consider while diving into the world of social media:
Facebook
There are several informational areas on a Facebook page to add static organizational details about your credit union. These need to be reviewed and approved by management before posting. Daily status updates are considered interactive, and if you wait to get each one approved you’ll bog down the whole process. Make sure management periodically reviews the posts for content and that the person posting has a set of stringent guidelines to follow. If the information is an actual advertisement, you’ll need to meet the advertising regulatory and Facebook’s advertising guidelines.
Twitter
Just like Facebook, there are static areas to pre-approve content and the interactive element. Tweets should also be periodically reviewed and have posting guidelines in place.
LinkedIn
This is the best place to have a condensed online brochure for your credit union and to spotlight your staff. Just make sure everything is reviewed and approved by management before posting. Also, you might want to review what’s on your employee’s LinkedIn profiles to ensure it aligns with your credit union’s page.
Blogs
Any blog should go through the proper review and approval channels before being posted. You may want to consider including a disclosure or disclaimer on the main page for your blog describing your views and listing what states you’re licensed to conduct business in. Plus, always give credit for any sources you use in your blog post including quotes, articles, images or videos.
Whatever platforms your credit union utilizes, monitor incoming posts, tweets or comments from outside sources. Make sure to delete any inappropriate or misleading statements.
This overview is basically the tip of the iceberg on considerations your credit union needs to make when participating in social media. Each organization is unique with its own individual environment and context. But a solid social media plan could go a long way in illustrating to regulators or auditors that your credit union is taking this very public role seriously.
Related Services: Social Media, Online Services
Working with a Strategy Partner
The word “compliance,” when it comes to all things governmental and regulatory in nature, really has nothing to do with membership enhancement. But the true definition of compliance, “the act or process of complying to a desire, demand, proposal, or regimen,” is what member rewards programs are, or should be, all about. To a certain degree, it’s also what credit unions are all about – putting members’ needs first.
When you Google “member rewards programs,” results run the gamut from airline and credit card rewards to those for restaurants and yes, even credit union member rewards. Invest in America’s (IIA) LoveMyCreditUnion.org appears on the first page of search results, as does CU Solutions Group. What sets our membership enhancement program apart is how each and every partner is chosen with credit unions and their members in mind. Plus, each and every partner is researched and vetted to ensure they align with the Invest in America mission of helping credit unions better serve their members.
How Invest in America accomplishes this differs by partner and each partner offers its own benefits and rewards for credit unions like yours. It has a solid reputation and track record of putting credit unions and their members first in all it does and all it offers:
• IIA partner offers are chosen to tie to core services such as auto loans, credit and debit card usage and mortgages.
• The Credit Union Member Discount from GM enables credit unions to include loan links on its microsite.
• LoveMyCreditUnion.org has the Find a Credit Union search feature to match potential members with nearby credit unions.
• Credit unions participating in IIA receive weekly emails which provide them with GM authorization request activity so they can follow up with their members.
• The IIA Partner Center provides credit union scorecards and sales reporting for participating credit unions to gauge their progress.
• Professionally created free marketing materials are available including posters, statement inserts and Web banners.
• The IIA team conducts regular research for potential program improvement actions and adjusts the program accordingly.
While there are hundreds of reward programs out there, they’re not all created equal. IIA is proud to offer well-researched and vetted partners, valuable discount offers and immeasurable benefits – all wrapped up in a reputable program that does its best to “comply” to the desires and demands of its participating credit unions.
Related Services: Invest in America, Credit Union Member Discount from GM, DIRECTV
Start the New Year with a Website Compliance Review
Compliance and all its associated rules and regulations are familiar to anyone who works in the credit union industry. From opening a share account for a new member to advertising a loan to hiring staff—there’s a regulation for just about everything you do. And that includes building and maintaining your website.
Your website must comply with a variety of rules and regulations from NCUA, OFIS, and the Federal Reserve Board. At least once a year (if not quarterly), your credit union should take time to review your site to ensure that it is in compliance with a variety of consumer protection and credit union laws and regulations, including:
• Truth in Lending (Regulation Z)
• Truth in Savings (NCUA Rules & Regulation Part 707)
• Equal Credit Opportunity Act (Regulation B)
• Funds Availability Act (Regulation CC)
• EFT Act (Regulation E)
• COPPA (Children's Online Privacy Protection Act)
Consider these questions:
• What, if any, regulatory requirements your site has not met?
• What steps do you need to take to correct each case of non-compliance?
• Do you need to add any terminology or disclosures to your site to make it compliant?
With the seemingly constant changes in the regulatory landscape, you’ll want to take steps today to ensure that your website is in compliance with regulatory requirements. (Think of it as your New Year’s resolution!)
Related Services: Website Compliance Review, Website Design and Development
Conducting an HR Audit
Do you know whether your human resource practices are helping, hindering or having little impact on what your company is trying to accomplish? Organizations routinely conduct internal and external audits of their accounting function to evaluate company practices against industry standards and legal and regulatory requirements. Similar review and analysis can be applied to the human resource function. An HR audit can evaluate the effectiveness of human resources, comparing your credit union’s current practices against industry best-practices, reviewing compliance with relevant employment laws and regulations, and identifying “gaps” between what the credit union needs vs. what HR is delivering.
Why Should You Conduct an HR Audit?
Have you ever wondered whether that turnover report you supply to senior management is worth all of the time and effort? Or, have you wondered if the way you’re handling FMLA leave is technically correct, given all of the changes in the last couple of years? An HR audit can provide solid answers to these types of questions and much more.
Compliance review is another key reason to audit the HR function. We all know that the pace of change in the HR arena has been fast and furious. Are your policies, forms, and practices all compliant with current regulations? The audit process can help you focus on making sure that everything is up to date.
Has your credit union gone through a merger, consolidation or added a new branch? If so, this is a good time to take a moment to consider if the HR function has changed with these changes. Do you continue to meet its needs and to ensure that all practices are in compliance?
Determining the Scope of the Audit
Once you have committed to undertaking an audit, you will need to decide what areas the audit will cover. An all-encompassing audit would look at things like policies, forms and tools, employment records, the employment process and much more. The audit can also look at key metrics, such as turnover, cost per hire, spans of control, salary compa-ratios, etc. Just keep in mind that the scope of the audit should be centered on the current status of the business and the strategic plan.
Never Conducted an Audit?
Now that you think an HR audit sounds like a good idea for your credit union, now what? Certainly one option is to do an in-house audit. One of the primary benefits of a do-it-yourself audit is that you know your organization better than any outsider. It can save your credit union money, you can set your own schedule and you can maintain maximum control over the process.
One the other hand, audits are very time-consuming. Outsourcing your audit provides several benefits:
• You get the credibility and validity of an expert’s opinion of your HR practices.
• They can give you a fresh perspective on your processes and policies.
• Using a third party to conduct staff interviews allows for a level of confidentiality and staff may be more candid.
• It will save time for you and your HR staff.
• This third party auditor could continue to be an ongoing resource for your credit union with any questions or issues you may have going forward.
Whether conducted in-house or by an outside party, an HR audit can provide an opportunity to examine the HR function in your credit union and offer useful feedback to improve the department’s contribution to its success.
Related Services: HR Consulting Services, HR Forms and Tools
5 Tips to Jump Start Credit Union Compliance in 2012
For anyone dealing with compliance issues, the beginning of the year is a time to plan, prepare and schedule projects. There are so many regulations and changes to track that the little details can easily become lost; but those little details can cause big headaches later in the year. As you prepare for the year ahead here are a few tips to make compliance more manageable:
1. Be Proactive
Regulatory changes can be overwhelming, so tackle the issues before they tackle you. Research what the new requirements will be and how they will affect your credit union before they take effect. Determine which key employees will be able to help you implement the new requirements and let them assist you in transitioning your credit union to comply.
2. Line Up Your Resources
Find sources for information you can trust and experts to offer advice; the InfoSight website is a great start! Knowing where to obtain information on regulatory changes that are relevant to your credit union is half the battle. These sources also offer tips and guidance to make compliance easier for you.
3. Enhance Your Knowledge
Take time to read and understand regulatory issues that affect the credit union industry. In the last few years there have been so many regulatory changes that it can be difficult to keep up with everything, and once you fall behind it is difficult to get ahead again. Take time weekly to read articles and information that helps you to be prepared for the issues that your credit union will face. Be involved with your league and proactive in issues that need your representation, input and support.
4. Schedule it
Enter important compliance dates on your calendar. As the year progresses make sure you continue to add and update new events so that you have reminders and a way to follow up on the events. The calendar can help in reporting the compliance projects progress and at year end the calendar will represent what you have accomplished.
5. Prepare
Organize and arrange your documents and resources so that for reviews and audits you are prepared before the auditors pull into the parking lot. Have a game plan in place of who will be able to answer questions and provide assistance so that everything progresses smoothly. For external auditors this can save the credit union money; and for regulatory audits makes completion of your audit easier.
These tips should give you a jump start on 2012 compliance issues. This New Year brings new beginnings and new opportunities and the year ahead looks to be busy for the credit union industry. If you are feeling overwhelmed and looking for compliance assistance we can help - just contact us.
Related services: HR Consulting Services
Coming NEXT quarter:
The CU Solutions Group is changing to a quarterly format starting with out next issue.
With the New Year come new plans for the future. It’s fantastic if your credit union has its strategic plan in place for the next twelve months – but does your staff know what it is and what their roles are in it? Next quarter we’ll give you insight into the best ways optimize your credit union's online presence.
For information about our products and services,
contact your CU Solutions Group business consultant.
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