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WASHINGTON-No more teachers, no more books.or so credit union officials thought. Now many are opting to return for the NAFCU Certified Compliance Officer (NCCO) program. In offering the program, NAFCU attorneys are making even more work for themselves. Aside from teaching at the week-long Compliance School, NAFCU’s compliance experts are being tapped for increasingly complex problems. According to NAFCU Director of Regulatory Compliance Linda Dent, her department used to receive about 30 calls a day with questions from the membership. While the numbers are somewhat down, which she attributed to the school, the substance of the questions requires more digging than before. “Now there are fewer questions but the questions we get are very seldom the basic questions, the fundamental questions,” Dent commented. Members now know where to look for the basics, but have more detailed questions or are looking for another credit union that recently faced a similar situation. NAFCU’s Compliance Department was started in 1993, but demand required additional staff and reconfiguration of the department and, thus, the education program was born in1996 with the first compliance school held in 1997. Eight schools have been held so far. While the plan was to hold annual schools, NAFCU actually held two courses in two of the years because the demand was so high, even after stopping marketing early. Each year, NAFCU sets a capacity of 65 students, which is always stretched. Eighty-two students attended the most recent school, according to Associate Director for Compliance Education Programs Ron Goode. NAFCU has discussed some options for expanding the program, such as having separate East Coast and West Coast schools or distance learning over the Internet, but logistics are currently inhibiting those options. Students are permitted to do a self-study program where they request exams from NAFCU when they are ready and are proctored by another credit union employee with some supervisory capacity over them. Both proctor and pupil must sign an affidavit that everything went by the book “to preserve the integrity of the program,” Goode explained. He estimated about 75% of students actually attend the school in Washington and the remainder are in self-study programs. Many smaller credit unions do not have the resources to send some one to the school. Not only does the credit union need the staffer on site, but the course costs NAFCU member credit union delegates $1,150, non-NAFCU member credit union delegates $1783, and non-credit union representatives $1909 for the week. The price includes one-year subscriptions to the Learning Manual and Compliance Guide. According to program graduates, the education from the school is well worth it. “There were so many things I learned that I did not know were required. The Learning Manual provided a lot of valuable information that I still refer to when I have a question,” Pan Am Horizons Federal Credit Union Internal Auditor Kussilla Khemraj, an NCCO, commented in the school’s brochure. NCCO candidates must score 80% on the five exams administered to receive their NCCO designation. To maintain certification, NCCOs must take 24 hours of classes, seminars, or audioconferences over two years or retake the course and examinations. Goode noted, “So once they’re certified, it’s not an end of something.” Goode and Dent agreed, students usually enjoy the materials covered, but hate the examinations each morning. So far there have been about 280 pupils certified from the school and many more students have attended. Some credit unions choose to send staff just for the particular session related to their jobs. While all of NAFCU’s regulatory and compliance staff members are attorneys-six total – they are also required to specialize in certain subject areas and become NCCOs themselves. Students from the program tend to be compliance officers, internal auditors, and compliance counsel, mixed in with some CEOs, volunteers, and vendors. “For some people that are new to compliance, it’s actually better for them,” Goode remarked. He clarified that attorneys and others who are familiar with compliance often know what’s being done in the industry, but when you start with a blank canvas, it is easier to learn how things should be done. Goode explained that the Compliance School teaches from a “holistic perspective.” “We spend a day to just focus in on one or two topics,” he said. Subjects from the last school in April included two days of lending, a full day on discrimination issues, and a day covering share accounts. Financial privacy, Bank Secrecy Act, and Americans with Disabilities Act were touched on the final day. The school’s curriculum and administration is determined by the Compliance Commission, which consists of one NCCO from each region plus three noncredit union entities. One newer topic that is sure to be included in the next school is the USA PATRIOT Act and its implementing regulations. “What we try to do is we try to identify what do our members need,” Dent said. “What is going to help our members?” Legislative changes also account for ideas for future courses. “Things that happened over he course of the year, still in legislative form, are things we need to start thinking about,” she added. NAFCU’s Compliance School boasts high quality speakers from various groups including its own staff, NCCOs from previous schools, NCUA, the Federal Trade Commission (FTC), the Financial Crimes Enforcement Network (FinCEN), and well-known Washington, D.C. lawyers. Goode said NCUA has been very supportive of the program and sends two staff members from the Office of General Counsel to teach sessions. But learning works both ways. “I can understand the legal side.but explain to me exactly how this works,” Dent said of the operational perspective credit union officials give them. Students also keep staff in tip-top form. “What’s interesting is our members are a wealth of information in terms of letting us know what we need to be up to speed on,” she said. [email protected]

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