Compliance Blog

In support of the idea that one should refrain from reinventing the wheel whenever possible, NAFCU has updated its Book of Answers.  NAFCU members can access it here. (Log-in information needed.)  For you non-NAFCUers, here's a taste of what's inside.

Question: We are aware that credit unions may pay for the travel costs incurred by volunteers and their guest. Is there a limitation on how many trips the credit union may cover in a given year?

Answer: No. The Federal Credit Union Act allows credit unions to compensate one board official for his or her duties. Credit unions may not compensate any other credit union volunteer. NCUA regulations, however, define "compensation" in a way that allows credit unions to benefit volunteers in certain situations without violating the general prohibition against compensation. See 12 C.F.R. § 701.33. As you noted in your question, the definition of compensation excludes the payment or reimbursement of certain travel expenses incurred by a credit union volunteer and his or her guest. 12 C.F.R. § 701.33(b)(2)(i). The regulatory exclusion covers "reasonable and proper" travel-related costs "incurred by an official in carrying out the responsibilities of the position to which that person has been elected or appointed, if the payment is determined by the board of directors to be necessary or appropriate in order to carry out the official business of the credit union, and is in accordance with written policies and procedures, including documentation requirements, established by the board of directors." Id. The regulation contains no explicit limitations on the number of trips or the dollar amount of travel-related costs that credit unions may cover. Instead, the regulation permits each credit union's board of directors to determine what is reasonable and proper, as outlined above.

(Appeared in the November 2006 NAFCU Regulatory Compliance Newsletter.)

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March Madness has arrived!  I'm sure quite a few folks in your offices caught the flu today.  Well, NAFCU has quite a few tournament connections.  Here's who we're rooting for.

• Dr. Tun Wai, NAFCU's Economics Guru is a graduate of Georgetown.  All other things being equal, and assuming that there are no major injuries, he believes Georgetown should do well.
• The George Mason Mafia (which includes Steve, Tessema, Sarah, Pamela, et moi) is looking for another Cinderella run from the Patriots.
• Our very own Kristina Kennedy is a proud graduate (and former cheerleader) for the Mount Saint Mary's Mountaineers.  They play North Carolina first.  Ouch.
• Brad Thaler has his Michigan State shirts all ironed in preparation for a Spartan run to the final four.
• Many of our lobbyists (Jenn, Amanda and Eddie) all love Da Burgh.  They'll be rooting for Pitt.  I'd make fun of Pitt, but seeing how Penn State seemingly has given up playing men's basketball, I have very little ground to stand on.
• Our Regulatory Intern Josh hails from American University's School of Law.  He's proud, but indicated in a meek voice that they are a 14 seed.  But with a name like American, how can you not root for them?  Rooting against them is almost....un-American.