To Really Comply, Surround Yourself with Experts
We all know that ignorance is no excuse for failing to obey the law. Yet maintaining razor-sharp knowledge of the rules governing financial services is a fulltime job. To really do it right, credit unions need a person -- sometimes many people -- to create and follow a calendar of proposed and final rules, train staff on the ins and outs of compliance, and make all the program and operational changes necessary to follow the rules.
But for many credit unions, a staff person to do that fulltime job just isn’t viable. Those of us at the league level have witnessed first-hand the struggles faced by credit union executives who want to play by the rules, but aren’t entirely confident they know what the rules are.
To date, our members have relied on these experts for the answers to questions like: “My examiner made a finding regarding the use of a tax assessment. What are the new appraisal rules, and why can’t I use a tax assessment?”
Or, “we understand that the risk-based pricing rule has changed. What form do we need to provide our members and when is that change effective?” And, “what if a credit score was not the main reason we denied a loan? Do we still have to include the credit score on the adverse action?”