We’ve been saying for years that there are certain Regulators that are much harder when it comes to compliance than others. If you have ever experienced a change in regulators, you can probably attest to that fact! While the end goal of the regulators is the same, they do take different approaches, focus on different areas, etc. It can come as quite a shock when exams get tougher!
The following is an excerpt from a recent speech given by a NCUA Board Member.
“NCUA’s current method for examining and enforcing consumer financial protection laws and regulations in credit unions with less than $10 billion in assets that it supervises is not comparable to our sister agencies,” and that “NCUA’s different approach to consumer financial protection reviews runs counter to the congressionally mandated mission of the Federal Financial Institutions Examination Council, which works to ‘prescribe uniform principles, standards, and report forms’ across all types of financial institutions.”
Obviously, this is one person’s opinion but it does make you stop and think, maybe more so if you are regulated by the NCUA, is our compliance program really as good as we think it is?
Another thing we tell clients all the time is, just because examiners didn’t say anything about a specific area this exam, doesn’t mean you don’t have problems in that area. The goal of an exam isn’t to point out every single little error. Exams are often risk-based and it could be that examiners didn’t focus on that particular area this time, but they will in the future. In other words, don’t let an exam give you a false sense of security!
Banker’s Compliance Consulting is here to help! We not only assist banks with their compliance needs but credit unions as well. We’d love to talk with you and find out what we can do to make compliance less of a headache for you!
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.