Consumer Compliance

In a speech on September 10, 2019, NCUA Board Member Todd M. Harper gave his opinion regarding consumer financial protection, and the need for improved examinations and enforcement. He stated:

Since returning to the NCUA as a Board Member, I have spent some time exploring how the agency conducts consumer financial protection compliance reviews. My interest in this issue was sparked by news stories concerning lapses in consumer financial protection by individual credit unions during the last several years.

In general, I have found that the 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, which complete regularly scheduled risk-focused consumer compliance reviews and assign a separate consumer compliance rating outside of the CAMEL process.

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.

He continues:

Although credit unions are owned by their members, management’s actions may not always align with the consumers’ best interests and the requirements of federal regulations. That’s why I believe that the NCUA Board should work to ensure greater consistency in supervising consumer financial protection matters. In doing so, we will better safeguard member interests; especially as credit unions grow in size, scale, and scope.

Credit unions should take this as a sign of things to come. Are you ready for the increased focus on regulatory compliance? We can help. Compliance Services Group’s audits are based on consumer protection regulations. We provide consulting to help all financial institutions prepare for increased regulatory and consumer protection focuses.

Compliance Services Group, LLC is now scheduling audits and reviews for 2020! Please contact Kris Bullinger (360) 943-7137 x 107 or Kris.Bullinger@ComplianceServicesGroup.com to reserve your dates. For more information on our audits and reviews, see our Audit Services page.

 

Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since some of our employees are lawyers with an active bar license but are NOT engaged in the private practice of law, that Rule requires us to make disclosures clarifying that the services we perform may be law-related services, but they are not legal services.  Because they are not legal services, those services and our relationship will not be governed by the Rules of Professional Conduct that guide the client-lawyer relationship, such as rules applicable to privileged communications and prohibitions of conflicts of interest.  Notwithstanding this disclaimer, we will continue to govern our relationship with you using reasonable ethical and professional standards that are expected to meet your expectations.

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