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Are Your BSA Procedures Up to Snuff?

Everyone knows credit unions must conduct independent BSA testing every 12-18 months. A credit union must consider their own size, complexity, and controls to determine if stretching out to 18 months makes sense. I...

Dear Examiner – I Respectfully Disagree!

There comes a time in every compliance officer’s career when an examiner makes a statement, or worse yet, identifies a regulatory finding that you don’t agree with. When this happens, you may wonder just...

Examiners and Mischievous Ghosts

I learned something new today. Did you know poltergeist means “mischievous ghost”? According to Wikipedia (because everything on the internet is fact), the word poltergeist came from the German language word polten (“to make sound”...

Thanks, Wells Fargo, You Shouldn’t Have

We can all thank Wells Fargo for an unexpected compliance gift this year. Thanks to some questionable incentive practices on their part, the CFPB has issued a Bulletin describing in great detail, their expectations...

Do You Hear What I Hear?

Listening to your members, via your Complaint Management System (CMS), is not only a good business practice, it is expected by your regulators. Having an effective program in place is another arrow in your...