Whether combined into one platform or a separate system, you also need to track, manage, and address member complaints, Diaz advises.
“The CMS is an excellent channel for identifying regulatory gaps that may not have been found for months, if not years, using a standard regulatory review process,” he says. “For this reason, examiners are focusing on the member complaint piece and drilling into how this is managed in the credit union.
“The most important part of a successful compliance program is to obtain buy-in at all levels of the organization,” Diaz continues. “It’s easy to say ‘yes, of course we believe in being compliant.’ But the challenges arise where the rubber meets the road.
“When you have a disagreement with a business area as to whether a practice is permissible, is there an escalation process to determine risk acceptance? Are you empowered to take the matter to your risk or compliance committee for discussion? Is there a formal process for all of this to happen?”
If the answer to those questions is “no,” your credit union is exposing itself to risk that may not be commensurate with the board’s risk tolerance, Diaz says. “Compliance officers need to walk a fine line between member service and risk mitigation, but it’s achievable with proper buy-in at the top.”
Ihrig concurs. “The CEO must be fully engaged,” he says. “There’s no sitting on the sidelines.”
‘The CEO must be fully engaged.’
Williamson turns to CUNA’s resources to stay at the top of her compliance game.
“CUNA is a great supporter of compliance professionals through its community, blogs, trainings, schools, conferences, and other tools,” she says. “CUNA’s knowledgeable professionals are able to assist when needed.”
Williamson recommends reaching out for assistance and signing up for CUNA’s Compliance Community, noting “if you are new to compliance, CUNA offers a mentoring program.”
CUNA released the CUNA Compliance Management System™ (CCMS) as a membership benefit for all credit unions that are affiliated members of CUNA or their league.
The system, built with technology by Woodinville, Wash.,-based Quantivate, was designed with extensive input from credit unions. The web-based software offers opportunities to scale to the most complex compliance needs with a fee-based level, CUNA Compliance Management System PLUS™ (CCMS+), as well as Quantivate modules that can be added to create a full governance, risk management, and compliance management suite, reports Ihrig. “Credit unions tell us it’s easy-to-use, and they love that it’s centralized,” Ihrig says. “And it will help you sleep at night.”