Compliance Blog

Posted by Anthony Demangone

Here are some things of possible interest.

BCP planning.  As you know, NCUA expects credit unions to conduct business continuity planning. (For a good resource, look at the FFIEC's BCP Booklet.)  Part of the BCP process is testing.  You build a plan, and then you try to poke holes in it.  But I think another way of testing is to look back at real-world events and see if you can learn from them and build those lessons into your BCP plan.  As I noted yesterday, DC had some nasty traffic issues recently due to winter weather.   One major part of the problem was that everyone left work in the DC region at the same time.  This created huge log-jams of traffic.  Couple the log-jam with weather, and you had quite a few people getting stuck.  (Try going up an icy hill in your car.  Hit the brakes, and then try to start moving again.  Good luck with that.) So, let's add this up: bad weather, lots of traffic, lots of cars that were stuck. Guess what happened?  People ran out of gas in the middle of the highway and simply abandoned their car.  Or people didn't have the necessary stuff in their car (sand, shovels, etc.) to get their car out of a jam, so they simply walked away.  Many of those folks did not come into work today, I guarantee that. Here's some possible take-away points that could have helped many.

• As soon as bad weather is predicted, fill your car's gas tank.
• If bad weather is predicted, plan a route to your home that doesn't involve hills. Or at least avoids the bad ones.
• If bad weather is predicted, make sure you have what you need in your car, including warm clothes, water, etc. 

This could be accomplished with a simple email to your staff once bad weather is on the horizon.  That won't solve every problem, but it will increase the likelihood that your staff makes it home safely.  Which means they'll be back at work sooner.

Current Issues in Credit Unions.  The latest issue of the podcast is now available.

Foreclosures.  Deutsche Bank made The New York Times for all the wrong reasons.   They foreclosed a mortgage in violation of the SCRA when a serviceman was away at war.  This article is a fantastic reminder of how important it is to understand the SCRA's protections, and the immeasurable reputation risks that can occur when you simply run blind to the SCRA's requirements. 

CFPB.  Treasury has announced the CFPB's legal eagle implementation team.   The group looks very impressive. (And I do detect a good deal of litigation experience.)

Have a great weekend, everyone.