Compliance Blog

Written by Steve Van Beek

Yesterday, we looked at the CFPB's consumer stories - especially Greg from Michigan - and how it is very difficult to get a firm grasp on a particular consumer's story when only part of the story is told.  

One story that the CFPB hasn't focused on is how their actions impact credit unions - and especially compliance officers.  The CFPB hasn't reached out to compliance officers to learn their story.  The CFPB hasn't made it easy for compliance officers to find the latest information from the CFPB (we are still waiting for that search bar on the CFPB's website).  Additionally, the CFPB's announcements come in the form of press releases, blog posts, or speeches.  

Meet Sally.  If the CFPB is serious about protecting members it needs to "Meet Sally."  Here is an outstanding comment from Anthony Demangone on the "Meet Greg" blog post:

"CFPB - I'd like you to meet Sally, from one of my favorite credit unions.  She's a compliance officer, and she does her best to keep her credit union in compliance with the astounding amount of rules and guidance documents that credit unions face.  She cares about her credit union, and she cares about the credit union's members.  She's a bit busy now, seeing as she has to sift through 1,400 pages of mortgage proposals that recently arrived at her doorstep.  

Sally will tell you that even at her credit union, they'll only reach out to the address or phone number on file.  So if an account is in arrears, they'll do their best to contact the member.  But Sally will also tell you how maddening it can be to find out how many members don't keep their account information up to date.   There's only so much Sally can do.  Especially with those 1,400 pages on her desk.  Oh, and she's also responsible for BSA compliance as well.  But that's probably not your concern, as it flows from a different agency. 

I wonder how hard you are working to get to know Sally, and why you never write about her, or her peers, on this blog?- Anthony Demangone, COO, The National Association of Federal Credit Unions"

Bravo Anthony!  Well said.  If the CFPB reached out and met Sally, it would realize that Sally is in charge of compliance for almost every product or service her credit union offers.  So, when the CFPB is simultaneously changing mortgage disclosures, overdraft protection practices, remittances disclosures, protections for prepaid cards, and the list goes on - is the CFPB talking to Sally and other compliance officers?