Compliance Blog

This week, NCUA issued two pieces of guidance concerning third party relationships.

NCUA issued a legal opinion that clarifies an issue surrounding contract reviews.  As you may recall, NCUA recently issued Letter to Credit Union 07-CU-13, which provides guidance regarding third party relationships.  In the guidance, NCUA recommended that credit unions have “qualified external legal counsel review prospective third-party arrangements and contracts.”

In NCUA Letter to Credit Unions 08-0147 (April 18, 2008), NCUA clarified that in-house counsel (an attorney working on the credit union's payroll) can perform the review if they are qualified.

Yes, in-house counsel may perform the recommended review, assuming, of course, that counsel has the experience for this purpose. In-house counsel, by definition, will focus on protecting the interests of the credit union and, thus, presumably will have the independence 07-CU-13 recommends.

Yesterday, NCUA also released Letter to Credit Union 08-CU-09, the purpose of which is to provide credit unions with the questionnaire that NCUA examiners will use to complete their evaluation of credit union third party relationships.

I have three words of advice:  READ THAT GUIDANCE.  I love the fact that NCUA releases their exam questionnaires.  This is the equivalent of your history teacher giving you her exam questions before the big test.  I remember my Towanda High School history teachers well.  Mr. Victory.  Mr. Fox.  Mr. Sexton.  Believe you me, they wouldn't have done this.

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The Compliance Guy worked on the wedding seating chart last evening.   Holy cow!  By the end of the evening, I proposed to Mandy that we simply give everyone their own table to make things easier.  She laughed.

I wasn't kidding.