Filed under: Current Issues in Credit Unions, Uncategorized | Tags: compliance, CUSOs, FACTA, Regulation GG, Regulation Z
Faith, Hal, Katherine, Anthony and Rob talk a lot about compliance this month, but it’s more interesting than it sounds, really, I promise!
–Reg Z update (again!)
–How will the interchange rate modifications affect credit unions?
–Reg GG tips
–Tips on FACTA policy revisions.
–CUSOs 101: what can they do and what can’t they do?
–At what point should a credit union create an iPhone/iPod/iPad app?
The CIiCU hosts are:
Brian Witt
Hal Scoggins
Farleigh Wada Witt,
Attorneys at Law
121 SW Morrison Street, Suite 600
Portland, Oregon 97204
Telephone: 503-228-6044 503-228-6044
Fax: 503-228-1741
http://www.fwwlaw.com
Guy Messick
Katherine Weber
Messick & Weber P.C.
211 North Olive Street
Media, PA 19063
Telephone 610-891-9000
Fax 610-891-9008
http://www.cusolaw.com
Faith Anderson
American Airlines Credit Union
P.O. Box 619001
MD 2100
DFW Airport, TX
75261-9001
(800) 533-0035 (800) 533-0035
https://www.aacreditunion.org/default.asp
Anthony Demangone
AFCU Director of Regulatory Compliance
NAFCU – National Association of Federal Credit Unions
3138 10th Street North
Arlington, VA 22201-2149
Telephone: 703-522-4770
Toll-Free: 800-336-4644
Fax: 703-524-1082
http://www.nafcu.org/
Robert Rutkowski
Shareholder
Weltman, Weinberg & Reis Co., L.P.A.
323 W. Lakeside Avenue, Suite 200
Cleveland, Ohio 44113
Telephone: 216-739-5004 216-739-5004
Fax: 216-739-5642
http://www.thatcreditunionblog.com
http://www.weltman.com
Subcribe to the show via iTunes Music Store: http://phobos.apple.com/WebObjects/MZStore.woa/wa/viewPodcast?id=151785964&s=143441
Filed under: technology, Uncategorized | Tags: app, credit unions, ipad, iphone, ipod
By: Robert Rutkowski
Much has been written about grabbing the Gen Y audience and otherwise leveraging technology to reach out to new and existing members. Looking at the app store for iPhone/iPod/iPad, it shows that many financial institutions (including credit unions) have apps that offer a variety of services. On the more extreme end, a credit union could run a billpay app or something more pedestrian such as finding locations or checking account balances.
In deciding whether or not to take the step of actually creating a credit union app, the first question is how much would it cost? I have heard the number $30,000 thrown around as an example. Really it depends on what you are trying to do. If you want to show your members where you’re located, there are app creators out there that would help a credit union create an app for very little. On the other hand, interfacing a bill pay system through an app would be complicated and accordingly, expensive.
Expense is only one factor, however. Would your members even use it? If your membership base (or your potential membership base) is not tech savvy or not very interested in using apps or internet related products, creating such an app would probably bring a low return on investment. On the other hand, if your targeted member medium or existing member base is young and tech savvy and more importantly, interested in technology, an app could be very exciting to these people. Anything that establishes a communication base between you and a significant number of your members has value. How many of your members use bill pay now? How many of them are potential iPhone/ iPod/iPad users? How many people would ultimately end up using this type of product? This may be hard to identify, especially for a smaller credit union. Perhaps a membership survey would be of some value or even something more informal on the credit union’s website.
Finally, is it even possible for your credit union to interface its data processing system with an app? Ultimately, that is a question for your data processor. Certainly, if you have a bill pay product now, that sort of thing is possible. Depending on how your data processor handles its products, it may or may not be able to help you in this endeavor. I recently gave a seminar where one of the Credit Unions identified the fact that there data processor actually ran the credit union’s bill pay through ATM processing thus, placing its bill pay service within the new Regulation E changes. Such a bill pay system might have trouble getting linked to an iPhone/iPod or iPad via an app. On the other hand, the system using the ACH process probably would link more easily. The credit union wishing to develop an app should involve its data processor, involve its data processor at the very beginning.
For the right credit union with the right membership base, an iPhone/iPod/iPad app would be a good investment to offer enhanced member services and reach out to potential members.
By: Dave Cliffe, Esq.
Despite stabilizing home prices and efforts to keep struggling debtors in their homes through modifications and other loss mitigation, the number of distressed homes in Ohio on the market continues to accumulate, albeit at a slower pace. While the national median value of a home declined in the first quarter of 2010 by 0.7%, median home prices in Ohio showed a marked recovery. In Akron, for example, median home prices nearly doubled to $95,000 from $50,100 for the first quarter of 2009. Prior to the recession, Akron experienced a median home price of $119,000 in 2007.
Economists, however, forecast continuing high inventories of foreclosed homes into the foreseeable future. Over two million American households are currently in foreclosure and one in eight homeowners seriously delinquent on their payments have already had their loan modified at least once. In greater Cincinnati, three houses were foreclosed in 2009 for every five houses sold, and six percent of homeowners were more than 90 days behind on their loan at the start of 2010. While most credit unions in Ohio enjoy lower default rates than their regional counterparts, loan modifications, deeds in lieu, short sales and other loss mitigation techniques will continue to grow in an effort to staunch the volume of nonperforming loans short of filing foreclosures.
If you have any questions concerning this matter, please contact Mr. Dave Cliffe, Esq. Dave is an associate in the Real Estate Default Group located in the Cincinnati office of Weltman, Weinberg & Reis Co., LPA. He can be reached at 513.333.4054 or via email at dcliffe@weltman.com.
Sources: The Wall Street Journal; Cincinnati Enquirer
Filed under: credit unions, humor, marketing, Uncategorized | Tags: marketing, surveymonkey, surveys
by: Robert Rutkowski
I was on a call this morning for an American Bar Association subcommittee meeting of all things when some very erudite people were discussing using SurveyMonkey. Despite my own geeky interests, I had not heard of this service before. I went ahead and created a short, four question survey for you, dear reader, on the SurveyMonkey site. You can take this survey here. I’ll try to update this post later to show the results. (assuming there are any, LOL!)
Even though I’m not personally big into surveys (despite just inflicting one upon you), I can see some utility in this. If you want to find out what you’re members are thinking about concerning an issue, you could put a link on the website or put it out on Facebook or Twitter. Heck, because it’s free you could even use it to figure out what your employees want for lunch on Employee Appreciation Day.
I suspect people with genuine marketing skills could really make hay with this site. Even with my own meager skills in this regard, I definitely recommend that you check it out.
Filed under: Uncategorized
Today’s blog comes courtesy of Christopher Morris, Manager of Communications & Web Resources for CUNA Councils.
Using Social Media in Employee Training at Your Credit Union
A few weeks ago I was presenting at the CUNA HR/TD Council Conference about social media and its relevance to credit union HR and training. A key part of my session was based on how to incorporate social media into employee training. It’s an often overlooked area and once you dig in, the possibilities are limitless only by your imagination (and perhaps an imperious IT department).
Here are a few ideas:
• Train Your Staff on Social Media – What is it? How does it impact the credit union? If a member comes in talking about credit union info on Yelp or Foursquare, what are they talking about? Aside from the benefit to your credit union, it’s good for your employee’s personal and professional development as well. Even an hour slipped into your next all employee staff meeting will go a long way.
• Discuss Your Social Media Policy – First, create one. Then discuss it with your staff so they understand it (many might misconstrue it as your policy limiting what websites are accessible at work). Many of your employees have Facebook pages, blogs or some social media presence and if they list your credit union somewhere within it, a good social media policy is a necessity. Your employees are brand ambassadors – remind them.
• Discuss Privacy Settings on Social Media Sites – This is related to the first two points, but warrants a separate discussion because it not only affects your CU, but your employees’ reputation as well. Remind your employees to check and regularly monitor their social media profile privacy settings (on Facebook for example). They need to continually ask themselves, “Who am I representing here?” and “How visible is this?” when posting information.
• Show Credit Union Videos from YouTube – Sure, you can show new employees your stale PowerPoint slide or photocopied handout on the CU difference…or you can show Larissa’s snappy two-minute YouTube video. I was glad to hear more and more CUs are going this route. There is a wealth of relevant videos you can show including the BankerSpank spots, Difference between CUNA & CUNA Mutual (yes, that’s me), A Brief History of Credit Unions, and many more.
• Discuss Recommendations on LinkedIn – This is more related to human resources than training, but it’s important. Consider this: An employee is terminated from the credit union. A few weeks later, he asks some former colleagues to write a recommendation on LinkedIn, which they do (either because they don’t know the nature of his leaving the CU or they were friends, etc). Could that be construed as a reference? Make sure your reference check policy includes LinkedIn and employees understand all references must be screened by HR. At the very least, whatever your policy is regarding LinkedIn, it should be consistent and everyone must be on board.
• Explain Security Risks – This is the main reason many CUs ban social media sites entirely. However, if you do give employees access (and you probably should – for HR and marketing at the very, very least), they need to understand the security risks involved.
What else did I miss? How do you use it?
Christopher Morris is Manager of Communications & Web Resources for CUNA Councils. He blogs regularly at the newly created CUNAverse at http://cunaverse.com.
Filed under: bank secrecy act, Uncategorized | Tags: bank secrecy act, bsa, credit unions, quiz
Something a little different today, I’m giving a quiz. Next week, I’m doing Bank Secrecy Act (BSA) presentations, so I have BSA on my mind. I thought I would share and test your BSA knowledge. Don’t worry, there’s no grade. As a matter of fact, most of these are easy!
If you miss 1 or 2, you’re an Ace! If you miss 3-4 you still have a lot of BSA knowledge. If you miss 5-9, it’s time for your annual training. If you miss 10 or more, you really don’t do compliance, do you?
Here we go:
1. What does CTR stand for?
2. True or False: If an insider commits a fraud, it doesn’t matter how much money is involved, you must file a Suspicious Activity Report (SAR).
3. True or False: The Board of Directors (BOD) must be notified when the credit union (CU) files a SAR.
4. True or False: A SAR must be filed within 45 days after the investigation.
5. True or False: If a member deposits $10,500 in dimes, the CU must file a CTR.
6. What’s the amount of money that triggers the filing of a SAR on a member exhibiting suspicious activity in many instances?
7. Who is the proper party to file a SAR when there is suspicious activity at a shared branch under a shared branching agreement?
8. True or False: The BOD must approve the CU’s BSA policy.
9. If a member refuses to give his or her date of birth to the CU, can an account be opened?
10. For how long must the CU maintain a descriptive record of any document used to verify identity?
11. How long do you have to file a CTR?
12. How much time do you have to report on a §314(a) request?
13. With the filing of a certain form, in what two instances can CUs share information with each other concerning SAR filings?
14. Give three examples of suspicious activity.
15. Identify one of the three stages of money laundering.
16. Should you run a beneficiary on an account through OFAC?
17. Can you tell the person who is the subject of a SAR you filed that you filed it?
18. Do you have to file a CTR if an entity depositing cash over $10,000 qualifies for a Phase 1 CTR exemption?
19. Does law enforcement need a subpoena to get records used in completing a SAR?
20. How often to you have to file a SAR for ongoing suspicious activity?
21. True or False: SAR filings for CUs went down in 2008.
22. True or False: It is not necessary for a CU to have its BSA program independently tested.
23. True or False: It is not necessary for a CU to have a BSA officer.
24. True or False: Staff training on BSA is a required element of a BSA program.
25. If a CU files a SAR on a member, should the filing of the SAR, on its own, be the sole basis for the closing of the account?
26. If your CU has to file a CTR on a member does it also have to file a Form 8300 with FinCEN?
______________________________________________________________
Answer key:
1. Currency Transaction Report
2. True
3. True
4. False
5. True
6. $5000
7. The agreement between the parties may specify, but it is safest for both to file.
8. True
9. No
10. Descriptions of documentary and non-documentary verification must be retained five years after the date the record is made.
11. 15 days after the transaction generally.
12. 2 weeks.
13. Terrorism or money laundering
14. It’s endless. Of course anything illegal, but even things where the member looks like he or she is trying to evade BSA law or policy or, really, anything that doesn’t make sense or doesn’t have an explanation. Given the penalties for not filing a SAR, file them early and often.
15. Placement, layering, integration
16. Yes
17. No
18. No
19. No
20. Every 90 days.
21. False
22. False
23. False (Title isn’t the important thing. But someone must be in charge of day to day management of the BSA/AML program.)
24. True
25. No
26. No
Special thanks to Anthony Demangone for double checking my quiz! Special thanks to Michelle Cochran for helping me to clarify the answer to #10.
Today’s blog comes courtesy of Shari Storm, Vice President and Chief Marketing Officer of Verity Federal Credit Union. Shari is the author of the new book ‘Motherhood is the New MBA”, available here.
Marketing – A Fable
Once upon a time, a long time ago, in a place far away, there was a small little village. The village had a prince, who was responsible for the village and villagers.
One day the tax assessor told the prince that the village needed more people to live there in order for the prince to pay for his next endeavor.
You see, the prince wanted to build a beautiful wall around the village so the villagers felt more secure. But that is beside the point.
The prince thought about it and wondered how he could get more people to move to their village so he could collect more taxes. Soon, he called upon a fair maiden and asked her if she had any ideas.
“Well,” she said brightly, “I could send the town crier over to the village West of ours and announce to those villagers how wonderful our village is. He could tell them to move here.”
“That is a tremendous idea. Do it.”
And so the maiden sent the town crier and he convinced several villagers to move to the prince’s village. Enough taxes were collected and the wall was built.
Soon after, the prince called for the maiden again. “I want to employ someone to pick up all the garbage. I am going to need more taxes. Will you send the town crier to the villages to the East and to the South of us and tell more people to move here?”
And so she did and so they did.
Soon after, the prince called the maiden and said, “I was recently at a jousting match and I saw that the village North of ours painted a big sign that says, ‘Move to our village.’ I would like a sign bigger than theirs to put up at the next jousting match.”
And so the maiden, with her can-do attitude, hired craftsman and painters and designed a bigger and better sign. More people moved to the village and more taxes were raised.
Soon after, the prince called for the maiden and said that he wanted to employ more dog catchers and he so he needed to collect more taxes.
Always eager to help, the maiden suggested, “Why don’t we raise taxes on milk and I will convince people to buy more milk?” The prince loved the idea and sent her on her way.
The maiden hired two other energetic villagers and they visited every house and gave every home a new challis as to encourage more milk consumption.
Some villagers bought more milk and some did not.
Soon, the prince called for the maiden.
“You have done many things to grow our village,” the prince said.
The maiden beamed with pride. The prince continued. “I would like a report on the ROI.”
The maiden looked confused, “The ROI?” she asked with hesitation.
“The RETURN ON INVESTMENT,” he said.
“Yes, I know what it means, but… I…..I.”
The prince cut her off. “You’ve hired town criers, craftsman, painters, village visitors. You purchased boards and paints and all those chalices. How much revenue did it actually bring in?”
“But..,” the maiden stammered, “We’ve been growing,” she said weakly.
“First of all, we didn’t collect all the taxes we needed with your chalice project. We do not have enough money to hire dog catchers. And also, the growth we had before that, how do you know that is due to your efforts? Perhaps villagers moved here because of the great wall we built, or because of our garbage pick up system. How do you know it is because of the sign you hired people to paint?”
The maiden shrugged, not knowing what to say.
“Just as I thought,” said the prince sighed. “Off with her head.”*
__
*This is a purely fictional story. It bears no resemblance to any company in any industry that the author knows of.
Epilogue
Luckily, the prince didn’t really send the maiden to the guillotine. He just wanted to say that for effect. But the maiden did see the writing on the wall and decided to leave the village.
As she was walking over the bridge to the village across the river, the tower guard saw her coming and told the prince of that village. Before she reached the moat, the draw bridge came down and prince of the new village greeted her with open arms.
“I’ve been looking for someone to help me get people to move to this village,” he said and they all lived happily ever after.
The End.
