High Tech, Human Touch Balance Helps Long-Term Planning
Satisfying compliance demands as well as demands from examiners are a focus of much strategic discussions at credit unions these days.
Automating regulatory compliance and risk management has long been touted as a way to help, but even as it extends in to the mobile channel, it hasn't replaced the human touch, some credit union managers and consultants say.
In fact, the marriage of high tech and high touch has made for some perhaps ironic tasks, such as at the $79 million Northern Hills Federal Credit Union in Sturgis, S.D., where compliance officer Jill Westendorf finds herself using software to prep the forms that she then prints out and piles into a box for when NCUA examiners visit.
Westendorf uses the AuditLink solution from her 9,100-member credit union's core processing provider, CU*Answers in Grand Rapids, Mich., for daily reports and tracking of accounts and cash flow aberrations that could trigger alerts and actions required by the Bank Security Act, the Patriot Act, the NCUA and accounting and business practices.
“It's so nice. I take 10 minutes a day now on this instead of spending my entire day sifting through these reports looking for potential problems,” Westendorf said.
Automation has also helped alert her to sudden activity in accounts that had been dormant for a year or longer.
“When that happens, we have to take a look at what's going on there and make sure we can positively identify who's doing what in there,” Westendorf said. “And what's also really helpful is that when the NCUA does come in and look at dormancy and things like that, I can pull out the big, old box I have all those reports in and let them cherry pick what they want to see.”
Examiners and auditors, internal and external, are people, after all, and the human factor cannot be eliminated by automation completely. Andrea Stritzke sees that every day in her role as vice president of regulatory compliance for PolicyWorks, a Des Moines, Iowa-based provider of regulatory compliance, government and public affairs consulting, training and other services to credit unions.
“Compliance takes a lot of different pieces and one of those pieces can be technology, but at the end of the day, you’re going to always need people involved with it,” Stritzke said.
Each credit union has its own field of membership, its own way of doing things, and add in interpretation and the flood of new regulations, and the need for human intervention is pretty much ensured.
Stritzke said new rules, particularly the CFPB’ Qualified Mortgage regs, will actually mandate some forms of automation as it joins the list of agencies requiring use of electronic documents in some form or another, but the human element will remain.
“It would be awesome if you could have like a Suri of compliance, something that could just interpret a rule for you and spit it out, but it doesn't work that way,” Stritzke said, adding numerous companies, including PolicyWorks, have rolled out or are in the process of developing compliance automation solutions.
“They all operate in kind of the same way, with a front-end document management system and the ability to upload documents and create an audit trail,” Stritzke said. “But it still takes some expertise to use them and interpret the information you get from them.”
Stritzke is an attorney by training. Compliance vendors typically have regulatory attorneys and former examiners on staff who are experienced in keeping up with the changes coming from agencies overseeing consumer protection and growing threats such as the dangers of identity theft, terrorism and money laundering. They’re also key to providing the human element the technology needs to be effective.
“Risk can be calculated by machine but there's always going to be something the machine hasn't seen before. That's also why you can't just self-diagnose illnesses by going to WebMD,” said Ken Wolff, CEO of AffirmX, a Frederick, Md.-based provider of risk intelligence solutions, which recently changed its name from NeighborBench, has more than 50 credit unions on its cloud-based platform and has an operations center in Provo, Utah, where most of its analysts are, Wolff said. Its sister firm, AdvisX, is a CUSO that also provides consulting services and claims expertise in HMDA, Fair Lending and BSA system validations.
The latter provides an example of the strong interest credit unions have in the topic of regulatory risk and compliance. Wolff said nearly 3,000 credit unions signed up for BSA risk training the NCUA provided using curriculum his company built for the agency. More than 50 credit unions now use AffirmX's cloud-based Risk Intel Center platform including $71 million Department of Labor Federal Credit Union in Washington, D.C., said its president/CEO, Joan Moran.
Her 6,100-member credit union was able to upload everything it needed for an upcoming BSA audit in an hour, a huge time savings for a credit union with two people working in accounting, she noted.
“Our supervisory committee loved the fact we were saving money on audits,” Moran said. “We also split up the work between our lending and operations department and our CFO, and we’ve found that when you get compliance work down to the people who are actually working with members, it really helps everyone get a better understanding of how important these strategies are to our credit union as a whole.”
While most compliance work presumably still takes place at the desktop level, credit unions can increasingly keep up with changes on mobile devices. Wolff said his clients can access the AffirmX system through iPads or smartphones because it's cloud-based and an SaaS solution.
NextLOGik in Columbia, Md., is now offering mobile-ready, online compliance help of its own. The CompWALK solution is now in beta use at potential credit union clients, said NextLOGik CEO Kirk Couser, himself a former technologist and executive at the $455 million NRL Federal Credit Union in Oxon Hill, Md., and the $160 million Heritage South Community Credit Union, in Shelbyville, Tenn.
Using technology and techniques his parent company, COLA Inc., developed in working with health care accreditation, Couser said, the NextLOGik software adds anywhere mobility to the delivery of templates and checklists that credit union staff can use to keep up with regulatory paperwork.
For instance, CompWALK functions include templates from the Automated Integrated Regulatory Examination System used by the NCUA.
“We take that very long questionnaire and pre-populate templates that break it down into components and deliver it in a mobile or web-based environment that you can then use to prepare for an audit,” Couser said.
CompWALK can also be used to ensure branding is consistent across the branch network and can accommodate any other type of document or image file needed, providing real-time data transfer between managers and locations, which also speeds up the ability to provide, for instance, regulatory alerts, he added.
NextLOGik is offering more of a pure solution play.
“We’re not compliance consultants and we don't plan to be to the credit union industry. What we do is provide a platform so that they can manage their own compliance much more efficiently,” Couser said.