A low-tech armed robbery prompted a Houston credit union todeploy some high-tech policy monitoring to help prevent future suchoccurrences while keeping within the limits of the law itself.

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First Service CU responded to the June 2009 holdup by deployingan automated compliance package designed to guarantee that controlssuch as alarm testing and inventory of bait money are in place ateach of the credit union's 10 locations around Harris County.

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“Together with our senior vice president of IT, I worked on acredit union-wide assessment of our security and compliancepolicies, which showed a definite need for FSCU to automateprocedures, organize our control policies and create consistencyamong all branches,” said Sid Zahn, vice president of complianceand internal audit at the Texas credit union.

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The solution they chose is being delivered assoftware-as-a-service from Continuity Control in New Haven, Conn.,and is one of 37 choices in the “control apps” list in thecompany's store at its website at www.continuity.net, coveringcategories such as accounting and finance, human resources,lending, operations, human resources and information technology aswell as compliance.

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The apps are regularly updated as compliance rules change andinput comes in from the company's customers and partners, and Zahnsaid he simply inputs e-mail addresses of branch managers and otherkey employees to distribute and track compliance tasks withoutrequiring the help of IT staff.

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“Now everyone is on track, on the same page and moving forward.The system makes it easy for everyone to work as a team,” Zahnsaid.

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Teamwork takes place back at company headquarters, too, saidAndy Greenawalt, the former CEO and founder of ePerimeter Securitywho led the creation of Continuity Control in 2008.

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He said a dozen different partners are now building theapplications for the Control Apps platform. “We're really creatinga marketplace for these control packs, if you will, that all lookand work the same,” Greenawalt said. “There's no learning curve. Ifyou can use one, you can use them all.”

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The applications are delivered for a fixed subscriptio

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n price, some starting as low as $99 a month, the company said.They eliminate the uncertainty of consultants or trainingsolutions, the company said, although it also offers the personalhelp of its “compliance directors.”

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Consultants also played a role in creating the apps, includingTroy Evans, the bank robber turned branch security expert andmotivational speaker who helped with the physical securityapplication.

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“We go to the best experts possible and let them define whatneeds to be in those policies and procedures,” Greenawalt said.Continuity Control also maintains a compliance operations center incharge of updates, he said.

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“As guidance comes down from NCUA and other parties and we learnof things through the examination process, we update our appscontinuously,” Greenawalt said. “Just one example is on the bankingside of things, where we saw guidance last Wednesday at 9 a.m. onthe handling of hard drives within copiers and fax machines. Weissued our update by noon.”

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Continuity Control is focusing on credit unions and communitybanks, institutions engaged in the fight against fraud but “whichdon't have the wherewithal typically to keep up with all thedifferent things they have to do now,” Greenawalt said.

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He pointed to Bank of America as an example of scale. “Here's abank with $2.3 trillion in assets. A new requirement from FFIECmight cost them, let's say, $10,000. That's nothing to them. But toa $10 million credit union, that's a massive impact.”

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Mickey Goldwasser, who was at the time senior vice president ofmarketing, added, “We hear over and over again, just tell me what Ineed to do and help me through it. That's exactly what we're doingwith these apps. And we guarantee that the responsibility forkeeping up with each of these changes is borne by us. We attack theproblems of compliance with technology.”

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