The lowest-cost compliance resource undoubtedly remains the information from the regulatory agencies. Of course, they’re also the one who deliver the highest cost non-compliance adherence penalties so take that resource for what it’s worth. Nonetheless, the information regularly produced by the federal agencies is extensive and available at no material cost. As would be expected, the resources from the government often come en masse with limited “sifting” and generally require internal resources to wade through and prioritize the data.
A quick search of the Internet beyond regulatory sites will yield nearly unlimited sites seeking to advise on compliance issues. A review of these sites can result in beneficial insights to compliance matters, but again require the user to have foundational understanding of the information presented in order to identify what is relevant to the user’s credit union.
Like recipes for cooking a delectable meal, having access to multiple sources that opine on the proper methods, ingredients, etc., to make the various courses of the meal is one thing, but actually executing the recipes is quite another. So it goes with compliance resources. Some resources are capable of advising on topics and others may provide methods or assistance to pursue various aspects of compliance. However, achieving the elements of the full compliance “meal” requires an array of capabilities. A complete and strong compliance resource, regardless of cost, must be able to do four elements effectively:
1. One, the resource should provide meaningful and prioritized information to the user in a way that enables guidance against risk factors affecting the credit union. This would include acting as a partner for analyzing new issues as they arise and adjusting key documents and schedules (audit, training, policies).
2. Two, the resource should provide tools for the credit union, including access to policies, procedures, forms and training materials.
3. Three, the resource should partner with the credit union in reviewing key compliance risk areas, including BSA, Lending Compliance, Operations, Deposits, Advertising, etc. The reviews should be based on priorities recognizing the finite resources of the credit union.
4. Four, the resource should promote examination preparation and assist the credit union in meeting the requirements of the examination.
As would be expected, federal resources fall short of each of the above elements and credit unions that elect to “go it alone” often find the price of soloing costly in the form of challenging examinations, enforcement orders, etc. There is little question that the full cost of a compliance solution must be considered.
There certainly are high-cost solutions to the compliance challenge, but they are often outside the fiscal realities of many credit unions. Moreover, a high-cost solution is not a guarantee of results. Other lower-cost resources predominately focus on one or two of the areas, but few, if any, outside of AffirmX are able to deliver all four elements in a risk-focused, efficient and effective manner. Add the element of AffirmX’s frequent partnership with Credit Union associations and the winning combination and value is unparalleled.