Compliance Blog

I really like NCUA's Records Preservation Program rule.  You'll find it at Part 749 of NCUA's rules and regulations.  I don't know who drafted it, but I agree with their view of why and how people keep records.  Here are two sections from Appendix A that I always admire:

Credit unions often look to NCUA for guidance on the appropriate length of time to retain various types operational records. NCUA does not regulate in this area, but as an aid to credit unions it is publishing this appendix of suggested guidelines for record retention. NCUA recognizes that credit unions must strike a balance between the competing demands of space, resource allocation and the desire to retain all the records that they may need to conduct their business successfully. Efficiency requires that all records that are no longer useful be discarded, just as both efficiency and safety require that useful records be preserved and kept readily available. (Emphasis added.)

D. What Are the Recommended Minimum Retention Times?

Record destruction may impact the credit union’s legal standing to collect on loans or defend itself in court. Since each state can impose its own rules, it is prudent for a credit union to consider consulting with local counsel when setting minimum retention periods. A record pertaining to a member’s account that is not considered a vital record may be destroyed once it is verified by the supervisory committee. Individual Share and Loan Ledgers should be retained permanently. Records, for a particular period, should not be destroyed until both a comprehensive annual audit by the supervisory committee and a supervisory examination by the NCUA have been made for that period. (Emphasis added.)

When it comes to recordkeeping, few records have clear-cut requirements.  Outside of those documents, credit unions have to make a business decision regarding what to keep and how long.  It isn't an easy process, but it is an important one.

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And in other news...

Regulation CC.  NCUA has released Regulatory Alert 10-RA-11to note that due to Federal Reserve restructuring, there are no longer any non-local checks. 

Seminar.  You need to register for NAFCU's Regulatory Compliance Seminar by this Friday to take advantage of the early-bird discount of $200.  Hey, it's no skin off my nose if you don't decide to attend.  We'd love to have you, but I understand that training dollars are not unlimited and that we aren't the only cowboys at this rodeo.  But by all means, if you know you will attend, please register by this Friday to save some money.  A penny saved is a penny earned, and all that jazz.

August and NCUA.  Remember, there is no monthly NCUA board meeting scheduled in August. (The board can call special meetings, though.)

NCUA and transparency.  NCUA will now create videos of board meetings, complete with a word-for-word transcript of what was said.