Earning a profit while complying with regulations is an ongoing challenge for credit unions. But the $116 million, Fairlawn, Ohio-based Towpath Credit Union recently discovered new tools that help it address compliance roadblocks while continuing to grow its lending program.

The credit union collaborated with regulatory compliance firm PolicyWorks, which is wholly-owned by the Iowa Credit Union League, Ohio Credit Union League, and California and Nevada Credit Union Leagues. It also began using ComplySight, a web-based compliance management and tracking tool developed by League InfoSight – an initiative developed by several leagues, including PolicyWorks' three league-owners, to provide useful compliance resources to member credit unions.

PolicyWorks incorporates a management consulting component into ComplySight, making it more powerful for credit unions. The technology, along with PolicyWorks' staff members, reviews documents and files in key areas of risk, allowing Towpath to manage compliance requirements responsibly.

ComplySight's system pushes out regulatory alerts to inform credit unions about new or upcoming credit union compliance requirements. The tool also explains credit union regulations and other requirements in a language that is easy to understand and offers a tracking mechanism for in-process compliance actions.

“The beauty of the system is it allows for an automatic tracking of certain items that need to be accomplished,” PolicyWorks Manager of Compliance Solutions Jason Skemp said.

When Towpath set out to build and manage a comprehensive regulatory compliance department, its staff understood the challenges ahead of them.

“I wanted to become the kind of compliance leader who didn't just provide a copy of the regulation to a manager, but rather helped and supported our management team with creating or updating policies and understanding how policies impacted procedures,” Towpath Director of Compliance and Risk Management Veronica Cromer said in a case study with PolicyWorks. “I wanted managers to be able to come to me with questions and get answers quickly in everyday language.”

Prior to bringing on PolicyWorks, the credit union used spreadsheets to keep track of its compliance management. Today, the credit union uses both the online system and PolicyWorks' regulatory expertise to complete a variety of strategic compliance tasks, including managing ongoing compliance, integrating compliance into product development, reviewing marketing materials, completing critical compliance projects and keeping up with changing regulations.

Skemp explained his firm offers a consultative element of compliance management, as well as training on how to utilize ComplySight.

“We'll request specific document disclosures, notices, policies and procedures,” he said. “We'll go through and review those pieces for them and provide our findings and recommendations based upon the key areas of compliance within the tool.”

PolicyWorks also works with the credit union on correcting deficiencies.

compliance and credit unions“Credit unions now have that ability for follow-up without having to prepare multiple spreadsheets,” Skemp noted. (Click dashboard to expand image.)

The tool tracks the credit union's progress in key of areas compliance and reports that progress – all on one dashboard. Cromer shared this very dashboard with examiners, who seemed to appreciate the grading system, Skemp explained.

PolicyWorks also helps the credit union stay on top of compliance by identifying and filling gaps, providing monthly reviews and sharing findings with staff.

Managing compliance this has allowed the credit union to brainstorm new and innovative financial products without the usual hesitation that sometimes stymies development and the creative process.

Towpath staff reported the process opened their minds because they knew they could achieve their lending growth goals by settling any outstanding regulatory concerns early in the product development phase. For example, the working partnership ensured documents accurately disclosed the appropriate fees, Skemp pointed out.

In addition, the credit union's compliance department no longer has to touch every item. Instead, Towpath's marketing manager can submit an item directly to PolicyWorks for review and watch its progress in ComplySight, which also has the ability to track projects and archive related documents.

ComplySight allows the credit union's staff to focus on larger compliance initiatives rather than put out daily fires. Soon after the credit union began using the compliance management tool, it extinguished one potential fire when it discovered a missing, important policy document – Unfair, Deceptive or Abusive Acts and Practices – even though staff members followed their usual compliance process.

Towpath's ComplySight administrator receives an alert each time a manager submits a question or requests a document review from PolicyWorks. The administrator can also assign compliance review tasks to managers within the tool.

PolicyWorks reviews documents for compliance issues, and if it recommends changes, it sends an email notification to the administrator and assigns the task to the manager. An email also confirms that the changes have been successfully made.

keeping up with compliance at credit unions“Not only are we finding issues, we are helping to correct them and creating follow-up to make sure they get corrected,” Skemp emphasized.

When Towpath performs annual audits, the administrator can request the required documents from a specific manager through the tracking tool. The manager then receives an email requesting the document, which they can upload and archive into ComplySight. If the manager does not respond, an email informs the administrator of the overdue task.

All compliance projects appear on the main dashboard as in progress, overdue or completed. Various reports are also available. ComplySight keeps a record of projects from start to finish and maintains a direct line to PolicyWorks' staff for all questions.

Towpath uses a variety of resources to keep up with changing regulations. However, the credit union said ComplySight is its most reliable resource because it keeps everything in one area.

If a new rule applies to the credit union, Cromer can assign it as part of an internal audit or policy revision and notify the specific department manager of the change. The administrator can also upload any regulatory compliance document and/or question in ComplySight and receive an answer from PolicyWorks within 24 hours.

Among the services PolicyWorks offers is a full-scale compliance audit review for all applicable federal laws and regulations, including: Appraisals, the Bank Secrecy Act, the Children's Online Privacy Protection Act, the Credit Card Act of 2009, the Electronic Funds Transfer Act, the Electronic Signature Act, the Equal Credit Opportunity Act, the Expedited Funds Availability Act, the Fair Credit Reporting Act, the Fair Housing Act, the Home Mortgage Disclosure Act, NCUA Rules and Regulations, OFAC, the Privacy Act, the Real Estate Settlement Procedures Act, Reserve Requirements, the SAFE Act, the Service Members Civil Relief Act, Truth in Lending and Truth in Savings.

There are dozens of regulations and hundreds of pages of new rules that affect credit unions – even if a credit union has staff dedicated to compliance, third-party assistance can prove extremely valuable.

“No one can go it alone in today's regulatory environment,” Cromer said.

Skemp said credit unions often ask how PolicyWorks can make compliance easier.

“It is not getting any easier when there are new rules coming out seemingly every day or every month that need to be complied with,” Skemp said.

PolicyWorks puts all the regulatory compliance elements together and tells credit unions what they need to do – something Skemp said examiners love to see.

“It allows [credit unions] to be proactive toward compliance,” he said. “Sometimes credit unions do not deal with compliance issues until there is a real issue.”

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Roy Urrico

Roy W. Urrico specializes in articles about financial technology and services for Credit Union Times, as well as ghostwriting, copywriting, and case studies. Also: writer/editor of a semi-annual newsletter for Association for Financial Technology since 1997 and history projects funded by the U.S Interior Department, National Park Service and Warren County (N.Y.).