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Ten Steps for Strong Policies

Policymaking can seem more overwhelming than the regulatory changes that require it.

December 09, 2011
KEYWORDS board , compliance , ncua , policies
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6. Jump on the express

Communications such as NCUA’s Letters to Credit Unions are a vital resource for any credit union’s policymaking effort.

That’s because they may provide clarifying information about specific regulations, express concerns about compliance, issue warnings, or announce rule changes that will impact your policies and procedures.

Require each of your department heads to sign up for NCUA Express by visiting ncua.gov. This service will send NCUA communications, such as Letters to Credit Unions and Regulatory Alerts, directly to the inboxes of your staff, so there will not be an excuse that they didn’t receive them.

7. Use an examiner resource

Another tool set to aid in your policy construction: NCUA AIRES questionnaires. These will provide some insight into what examiners will look for as they review various policies and procedures.

You can access these publically available documents on the agency’s website.

8. Schedule an annual check-up

Just as your doctor recommends you see him or her at least once each year, so too, does NCUA recommend you schedule an annual check-up for your policies. In many cases, the agency isn’t recommending it—they’re requiring it.

NCUA mandates that credit unions review all incentive bonus, investment, member business lending, and security policies annually.

For all other major policies, the NCUA cites annual reviews as a best practice for safety and soundness.

9. Document, document, document

A simple scan of the language during a board meeting may be all your credit union must do to review a policy. There may not be any necessary changes or updates.

Be sure, however, that even these minor reviews are documented in board meeting minutes and inside the policy itself. Add review dates to the policy headers and add the updated documents to your policy manual and/or shared network.

10. Don’t wait to be told

Examiners operate under the premise that credit unions have no excuse for not being informed of the current rules and regulations. For this reason, they expect all policies and procedures to exist and to be up-to-date.

Don’t wait to be told your credit union is a missing a policy—unless, of course, you enjoy frequent visits from your friendly examiner.

JAMI WEEMS is senior compliance officer for PolicyWorks LLC and a frequent contributor to TheWorksBlog.com.

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