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!