Navigating Dodd-Frank’s Murky Waters

Watch for a special report from CUNA Councils on Dodd-Frank Act compliance.

March 22, 2012

Traversign the ever-changing regulatory environment of yesterday seems like child’s play compared with the “new normal” of today.

Encroaching financial reforms under the Dodd-Frank Wall Street Reform and Consumer Protection Act include 243 rules to be proposed, reviewed, and written.

With about 71 expected to affect credit unions, it might seem like an endless and daunting job to digest the rules, let alone comply.

Many resources can help you navigate the murky waters of Dodd-Frank. Depending on your credit union’s size and complexity, some resources will fit your needs better than others.

Here are a few to explore:

  • CUNA’s credit union summary is contextual and applies universally to credit unions (cuna.org/reg_advocacy/member/hot_topic; select “financial regulatory reform”).
  • The Senate Banking Committee’s Dodd-Frank Summary is a great resource for the early summarizing of Dodd-Frank, but this is information without context (banking.senate.gov/public; select “Dodd-Frank Wall Street Reform”).
  • The Knowledge Mosaic website (subscription required) provides an excellent “Dodd-Frank Tracker,” which displays proposed and final rules as they are issued. The tracker allows you to sort by agency, type of rule, and other parameters (knowledgemosaic.com).
  • Booz, Allen, Hamilton offers a Dodd-Frank database that, while offered at no cost, isn’t as robust as that of Knowledge Mosaic (boozallen.com; enter “Dodd-Frank” in the search box).
  • Several professional groups also can assist or provide expertise, including the CUNA Councils—CFO; HR/Training & Development; Lending, Marketing & Business Development; Operations, Sales & Service; and Technology.

Knowing the resources are available is important, but what’s most critical is how you organize for Dodd-Frank compliance. Create a process at your credit union to handle the influx and volume of what’s coming.

To get organized:

  • Be clear on the effects of Dodd-Frank, particularly those expected to affect credit unions. This is where your resources can be invaluable.
  • Assess areas that might affect your credit union and make a list of “rule proposals” you want to review and possibly comment on. You’ll have a better idea of NCUA’s perspective, and changes your credit union might face as a result.
  • Consider aspects of Dodd-Frank that might affect competitors but won’t affect your credit union. Then you can develop strategies to gain advantages in your marketplace to improve members’ lives and your credit union’s performance.
  • Keep track of the proposed rules and how they affect your credit union. Compare the final rules to your tracking to quickly determine what you need to do to comply.
  • Identify knowledgeable employees in your credit union who can perform the review, and external people and resources who also can provide expertise if needed (including CUNA Councils).
  • Create an internal committee of knowledgeable employees who can debate issues and impacts on your credit union and the larger movement. The size of this committee isn’t important; staff expertise is. Remember, things that don’t affect you today might tomorrow.
  • Review CUNA’s comments on proposals. If they align with your perspectives, you can use some of the language drafted by CUNA in your response.
  • Keep track of final rules and requirements and their effective and implementation dates. Determine the changes you need to make and the changes your system partner/vendor will be making. Create task lists for implementing both.

If all this seems overwhelming, remember your credit union belongs to a larger movement—founded on the principles of cooperation and collaboration. There’s help available. At press time, the CUNA Councils were preparing to release a special report on Dodd-Frank compliance.

And remember the adage: You eat an elephant one bite at a time. Careful planning will get you to compliance—one step at a time!

ERIN MENDEZ is executive vice president/chief operating officer of SchoolsFirst FCU, Santa Ana, Calif., and chair of the CUNA Council Forum. Contact her at 714-466-8109. For more information about CUNA Councils, visit cunacouncils.org.