Compliance Blog

Posted by Anthony Demangone

Yesterday, I had the opportunity to take part in a panel discussion on examination issues, hosted by the Credit Union Times.  You can listen in here.  (Warning - the broadcast will start automatically. Length: roughly 30 minutes.) The discussion was lively, focusing on what credit unions are experiencing, what they can expect, and how they can prepare themselves for examinations. With that in mind, here's a link to NAFCU's "Managing Exams in Challenging Times" white paper.  It is free to NAFCU members and non-members alike. 

Here's some other "stuff."

• EEOC complaints are on the rise.  (Kaufman & Canoles.) Here's a link to the EEOC report.  And if you want to see a very detailed chart showing a historical breakdown of EEOC charges by type, go here. Why do I mention this?  This shows a general up-tick in EEOC claims, which in my mind signals a possible increased risk of an EEOC claim at your credit union. How would you tap down that increased risk?  Training.  For employees and management. 
• The NMLS, the SAFE Act registration system, has announced a series of training programs for financial institutions who will need to register MLOs.   The "how to" series breaks the process into four training programs. 
• The CFPB has a proposal out regarding how it will handle consumer complaints. As I read this, the CFPB plans to share complaint-related information with...well, just about anyone it wishes.  Check out the "routine uses" section on page 2 of their proposal.   When their system is up and running, just be aware that the CFPB will (assuming this proposal makes its way into final form in a similar form) be able to share a consumer complaint about your credit union with NCUA, a Member of Congress in some instances, or law enforcement. For this reason, it may be wise to see how your credit union currently handles member complaints.  Do you track complaints?  How are those complaints resolved?  While I have no data to back this up, it seems to me that the better you handle direct complaints, the less likely it will be that this CFPB complaint process will be problematic.