Generally, the answer is “yes”. However, it will depend on the nature of the outsourced solution. The role of a Compliance Officer is multi-faceted. A Compliance Officer must monitor new and changing regulations and determine whether they affect credit union operations. He/she must keep senior management and the Board apprised of regulatory changes and must ensure that staff members are trained on any new or changing regulatory requirements. He/she must ensure that the regulatory requirements are implemented in a timely and accurate manner. He/she must ensure that new products and services are in compliance with regulatory requirements. He/she must be prepared to address questions from the staff and the board in reference to regulatory matters and must monitor credit union operations to ensure compliance. Unless, your outsourced solution is capable of addressing all of these areas, you will still need someone within the organization to bear responsibility for those areas not handled by the third party. In particular, most outsourced solutions do not provide the implementation piece. This means you will need to have someone in your organization who is responsible for implementing regulatory changes, for addressing any compliance violations noted during examinations and audits and to act as a liaison with your examiners and auditors during their visits. The AffirmX Compliance Solution is not designed to replace your existing loan officer, but rather to make him or her more effective by performing the very time consuming monitoring of operations through our cloud-based on-going compliance review and by providing timely and informative compliance reference tools, such as our online compliance manual and periodic regulatory updates.