Compliance Blog

Posted by Anthony Demangone

NCUA issued a few items of note yesterday.  

Prohibition orders. First, NCUA issued its most recent batch of prohibition orders.  Here's my take on prohibition orders.  They are great for training purposes, as they point out to any aspiring criminals within your walls that people are watching, and some people get caught. Second, the prohibition list should be passed along to your HR peeps.  These folks are not to be hired by credit unions. If you want a more comprehensive NCUA list, you can go here.  Other regulators, such as the OCC, have separate sets of prohibition orders.  Here's the OCC's system, which looks like you could easily use to see if someone who is applying at your credit union was the subject of an OCC prohibition order.  Again, this is tedious stuff.  How tedious? Even some states apparently have their own list of people subject to a prohibition order.  Here's the Texas list, for example.   If high-powered regulators are reading, here's something I would love to see: a comprehensive list of all prohibition orders that shows the name of the individual, and the regulator that issued the prohibition order (including state-issued orders).  

Foreclosure Concerns. NCUA issued Letter to Credit Unions 11-CU-01 to urge credit unions to "perform an in-depth review of your mortgage documentation process and foreclosure management process." This guidance was issued in response to the recent foreclosure mess, in which certain mortgage lenders were foreclosing on homes when their right to do so was less than clear when push came to shove.  Things I would highlight:

• This guidance is perhaps the  most complete guidance document written regarding credit unions and foreclosures. 
• It lays expectations for credit union internal controls regarding the foreclosure process.
• In the guidance, NCUA indicates that it will expand examine procedures to include a review of foreclosure procedures in credit unions with residential mortgage programs.  If your credit union has such a program, read this guidance and be on the lookout for an AIRES exam questionnaire on the foreclosure issue.  If you don't have foreclosure procedures now, you've been warned.  Someone will be looking for them shortly. 

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On my recent visit to Penn State, I stumbled upon a nice surprise. The offices of Penn State Federal Credit Union. 

When I attended Penn State, I'm sad to say that I didn't know about this credit union.  It would have saved me some big bucks, as my bank at the time had a $1,000 checking balance requirement to evade a $10 monthly service fee.  I can tell you this: I never had $1,000 in my account for that long.  The $10 fee was a monthly ritual.   If you have kids, grand-kids, neighbors, or third cousins, twice removed, who are in college, tell them to see if their school has a credit union.

But here's my son trying to take money out of one of their ATMs.  I guess the magnetic strip on his card went bad, as he was unable to obtain cash for his cookie addiction. But when Briggs and Kate attend PSU on their respective sports scholarships, they will become members. I'll see to that.

 
Oh, and no visit to PSU would be possible without the following picture.

 Have a great weekend, everyone! Even you Jets fans.