The plethora of recent headlines about employee-related fraud and embezzlement at credit unions is highlighting the importance of bonding, and experts in the field have a few pieces of advice for making sure there are no surprises if it becomes necessary to file a claim.
According to data from the Financial Crimes Enforcement Network, the number of reported suspicious incidents involving employees at NCUA-regulated credit unions rose by more than 10%, from 1,577 in 2013 to 1,742 in 2014. From January to May of 2015, 834 suspicious incidents were reported, putting those institutions on pace to hit 2,000 by year end — a 15% increase from last year.
Bonding, which the NCUA requires of both federal and state-chartered credit unions, typically addresses fraud and dishonesty by employees, officers, committee members and other trusted insiders.
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Understanding how that coverage works can be tricky.
Here are a few things experts say credit unions should keep in mind.
1. The minimum coverage requirements are often enough. Coverage is typically based on asset size. Credit unions can get more, and reports of employee theft and other misdeeds tend to fuel the urge. "The other part of these that almost always happens is that the bad guy says, 'I stole $300,000,' and it turns out that it's $450,000," said Scott Simmonds, an independent insurance consultant in Gulfport, Miss., who has worked with about 40 credit unions and about 360 banks. "The most common question I get is, 'Do we have enough? We've got a million. Do we need two? We've got two. Do we need three?' Most often, I find the basic limit of coverage is adequate."
2. Plenty of fish will get away. "The vast majority of internal fraudulent activities will eventually be caught for credit unions that are following the proper protocols, but the surprising part is the time it takes to discover these fraudulent activities," said Erin Doan, a senior consultant at Sollievo. Her CUSO, which is headquartered in Middletown, Penn., partners with Kansas City-based insurance brokerage firm Lockton on bonding coverage. "When a person in a high-level role is behind these activities, it is not uncommon for it to go several years before the individual is caught. If the individual knows the protocols well or has little oversight from other credit union employees, they can be very effective at covering up these activities."
Simmonds said that in his experience, for every employee who's caught, another one gets away. "Maybe not within the organization, but certainly within the economy," he added.
3. Employee dishonesty outside the credit union counts. Lisa Wedekind, who is a senior bondability underwriter at CUNA Mutual Group, said her organization's underwriting criteria sets out to determine if a person has been involved in activities that are dishonest or fraudulent in nature, and a conscious disregard of established and enforced credit union policies of some type can indicate an element of increased risk in the person's activity. But credit unions and issuers have to be clear on the particulars.
"If the credit union knew that a particular person has been dishonest in the past, the bond says there's no coverage for that person," Simmonds said. "It's an issue that I talk about all the time. Because most bonds don't really go into great detail as to what the dishonest act is, but the policy just said 'dishonest act.' What's a dishonest act? Shoplifting at Walmart? Yeah, I think that's dishonest. Okay, but what if they did it when they were 15 and they're now 48?"
4. Use a verification service. Wedekind said one of the biggest mistakes credit unions make in this area is not using a bondability verification service, which can help avoid bringing high-risk people on board. CUNA Mutual Group, for example, offers a free service to policyholders. It gets about 60,000 bondability queries a year from its insured credit unions, she said, and about 200 people turn out to be not bondable. "The goal then is to prevent them from going back into credit unions that we insure," she said. Regulators also often ask credit unions whether they use a bondability verification service, she added.
5. Ask the FBI. "In addition to utilizing any services that are available from a credit union's insurance company for verified bondability, we recommend that credit unions consider doing FBI fingerprint checks on their staff, because that's a good way to find an individual if they do have a criminal record for a dishonest or fraudulent type of activity," Wedekind said.
6. Check the sublimits. "We say a lot of time the devil's in the details, and credit unions, especially the smaller ones, can be very price sensitive. And they think, 'Okay, well, I have that coverage and I got it for a good price,' but they may not realize that sometimes there are sublimits on a particular area of their bond," Doan said. "So then if they have a claim, let's say their bond covers $1,000,000, there could be a certain area where there's not as much monetary coverage. So it's really important that they look at the overall size of their bond and those sublimits."
That's why having an impartial third-party review and vet policies can be a tremendous advantage, she said. "Unfortunately, if a credit union does have a claim, we are seeing that sometimes they're surprised, and that can sometimes can hurt their relationships with their current provider."
7. Filing several claims is unlikely, but it can cost you. "One claim doesn't cost a whole lot of problems. The second claim, the insurer's going to look at you hard. The third claim, now it'd be a real problem," Simmonds said. "Insurers are always more concerned about frequency than they are about severity."
But despite the headlines, the likelihood of having to file several claims is still pretty low. "The vast majority of my 400 clients have never had an employee dishonesty loss," he noted. "You call 10 credit unions and I would be very shocked if any one of the 10 has had a loss that exceeded $500. My evidence for that is when I have a new client, I always ask if they had any claims and the answer is almost always no."
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