Joyce Johnson Keehan, compliance officer at $4.5 billion asset Hudson Valley Federal Credit Union in Poughkeepsie, N.Y., received a Compliance Champion Award Best in Class for credit unions with more than $500 million in assets.
The new honors from CUNA recognize outstanding achievements in credit union compliance management by individuals and credit unions.
Q: What’s your compliance philosophy?
A: I take a conservative approach, with a mindset of attempting to protect the credit union the best I can.
But it can be beneficial to have less-conservative colleagues on the team to create a healthy balance of favorable yet compliant answers for those in charge of implementing the laws and regulations.
I’m also a firm believer in understanding how the credit union operates. Having an operations background has helped me when researching and interpreting certain issues because I can envision how something is going to work as I’m reading through a particular rule.
I know my limits. When I’ve exhausted every resource and still can’t come to a conclusive answer, I turn to our trade organizations and legal counsel for assistance.
Q: How have recent regulatory changes affected how your CU runs its compliance program?
A: It requires greater organizational skills to keep track of when each regulation will become effective, especially when regulations have multiple effective dates. It also requires a greater number of people to implement the complexities required.
More than ever, we have to rely on our vendors and system upgrades to implement new regulations, whereas years ago it seemed that the majority of regulation implementation required new or updated disclosures.
Q: What’s one of the biggest compliance challenges you’ve faced?
A: When Congress first passed the Credit Card Accountability, Responsibility, and Disclosure (CARD) Act of 2009, I was still a “new” compliance officer, only in the position for about five years. The CARD Act was the most voluminous law I had experienced.
Colleagues told me to print the final rule and break it down into parts. I broke it down to preamble, rule, and staff interpretations.
I further separated these three parts into each section of the regulation and labeled the pages with tabs so I could easily review it.
If I have questions about a particular issue and want to know how it was finalized, or if I know of a particular issue that will be challenging to implement, I zero in on those provisions first before reading about the rest of the requirements.
Q: How can you make a positive impact on the CU system as a whole?
A: We need to advocate and educate our lawmakers on the impact of laws they’re about to pass.
We must continue to explain the need to balance member protection with common-sense applications of regulations that don’t add more burden to the members’ process.
I’m fortunate to work for a credit union that supports my ongoing compliance education. I enjoy helping people from smaller credit unions that have a tough time keeping up with all of the regulatory changes.
Networking helps us gain knowledge about our industry and everyday operations.
Q: What advice would you offer your compliance colleagues?
A: In 2014, CUNA’s CompBlog posted my top 10 pieces of advice that I would give to a new compliance officer. I still stand by that advice today.