Posted by Steve Gibbs, CUCE, BSACS, AVP Shared Compliance, Credit Union Resources, Inc on 2/12/2016

In recent years, regulatory requirements such as the Bank Secrecy Act and FACTA Identity Theft Red Flags have diverted our attention away from many other basic, and equally important, directives and regulations.  In particular, the need to perform a periodic web site compliance review has crept up on many institutions who, in many cases, have failed to schedule the review and were summarily criticized by regulatory authorities.  Is there something deeper here than just the regulations and directives?  Why is it important to have a web site compliance review performed?

Legal/Litigation.  It is no secret that the United States is probably the most “law-suit” prone nation in the world.  Litigation is filed for any number of things as diverse as “overly-hot coffee” to advertising practices.  With advertising in mind, let’s look at our web site.  Should we think about our web site as advertising?  You bet!  It’s one of the most effective means of advertising in this modern market.  It also opens up our web sites to the world and to billions of individuals who may find fault with elements of the site.  Mistakes or omissions in copy can subject us to lawsuits for discrimination (Regulation B), fraud/deceptive advertising (Regulation AA) and child endangerment (Children’s Online Privacy Protection Act “COPPA”).   In addition, the internet not only opens us up to single lawsuits but  “class-action” litigation which can involve tens to thousands and even (in some cases) millions of person.  Just a small class-action suit could devastate the reserves and earnings of a moderate to larger-sized institution, bank or credit union.  Even in situations where the class-action fails, the credit union could still be left with overwhelming legal obligations and court costs.  Many times, these “pitfalls” will be caught in the web site review and resolved before any legal repercussions occur.

Reputation.  We have to remember that no matter how good our intentions may be and what the truth really is, we can fall victim to “perceptions” that result from negative circumstances in which our institution’s name is associated.   This is particularly true when we speak of our internet presence through the web site.  Complaints from failure to properly disclose loan or savings rates, regulatory violations (Regulation B or COPPA), or even hackers entering the site and manipulating information that might be misleading, objectionable or even causes members to be defrauded can prove detrimental to a good public image.  An effective web site compliance review will determine elements of importance that might negatively affect the operation of an institution’s web site, then resolve to reinforce and protect those elements.

Marketing.  As we’ve already asked, what is our web site but advertising?  The credit union can really put its “best foot forward” with a well laid-out, monitored, and consistently updated web site. Good compliance practices can even bolster the marketing effort, such as advertising that we are “an equal opportunity lender or employer”.  In addition, items such as “…in compliance with the U.S.A. PATRIOT Act, we check the identity of all membership applicants”, project a level of patriotism.  These items are reviewed closely within the scope of an effective web site compliance review.

Management.  Most of all, management may be judged by the program presented on its web site.  The web site, printed and posted material are a public face to the credit union and management must take responsibility for what is reflected.  Given the “avalanche” of recent regulations and directives, management’s attention has become increasingly more divided with regard to these issues.  An effective web site review keeps management, as well as other officers and directors, informed of any crucial changes or additions which the web site may require.

 

 

Categories: Compliance
Posted by Ms. Cheryl Ehmann, AVP Staff Analyst, Credit Union Resources, Inc on 2/10/2016

I feel like I am forgetting something!  What do I need to do daily, monthly, quarterly and annually in the accounting area?

Although this list may not be all-inclusive, it will make sure you hit the high points!

Daily, do the following:

  • Balance teller and vault cash
  • Balance ATM cash, if possible.  (This may be done when replenishing the machine.)
  • Balance shares and loans.
  • Balance suspense accounts. (ACH posting, share draft posting, etc.)

At month-end, do the following:

  • Accrue interest on loans (make sure interest is not accrued on loans more than 90 days past due).  Debit Accrued Interest Receivable, credit Interest Income.
  • Accrue interest on investments – make sure an accrual is outstanding for all interest earning investments on which payments have not been recorded on the last day of the month. Debit Accrued Interest Receivable, credit Investment Income.
  • Pay dividends, if necessary.
  • Accrue dividends – make the entry necessary to agree the liability account balance to the totals of the EDP reports.  Debit dividend expense, credit dividends payable.
  • Write down repossessed collateral to market value and reclassify as an other asset.  The initial write-down is posted to Allowance for Loan Losses.
  • Make the entry necessary to show the proper balance in the Allowance for Loan Losses account, based on the formal calculation.  Accounts are Allowance for Loan Losses and Provision for Loan Loss Expense.  If you need to increase the Allowance account balance, credit it.  If you need to decrease the account, debit it.
  • Post amortization for prepaid expenses.
  • Post depreciation for fixed assets.
  • Post accruals for accrued expenses.
  • Print a general ledger trial balance and make sure a reconciliation exists for every general ledger account with a balance.
  • Depending on closing frequency and how the system operates, you may need to close income and expense accounts out to net income, then transfer to undivided earnings.
  • Submit payroll tax deposits if a third party payroll processor does not do this for you.
  • Send monthly member account statements.

At quarter-end, do the month-end items plus the following:

  • File the 5300 report with NCUA.
  • Pay dividends if not paid monthly.
  • Close income and expense if necessary depending on schedule.
  • Submit payroll tax deposits if a third party payroll processor does not do this for you.
  • Send quarterly member account statements.
  • Determine if a reserve transfer is required.  If the credit union’s net worth is less than 7%, a transfer equaling 1/10th of 1% of total assets must be transferred from Undivided Earnings to Regular Reserves, unless you have a waiver from your regulators or unless you are under a net worth restoration plan with different specifics.

As of March 1 of each year:

  • Texas credit unions print a dormant account report and begin contacting members.

As of June 30 of each year:

  • Arkansas and Oklahoma credit unions print a dormant account report and begin contacting members.

As of July 1 of each year:

  • Texas credit union submit the Unclaimed Property Report to the state comptroller, remitting all dormant accounts with no activity for three years whose owners could not be contacted and all uncashed checks outstanding more than three years.

As of November 1 of each year:

  • Arkansas and Oklahoma credit union submit the Unclaimed Property Report to the state comptroller.  Arkansas should remit all dormant accounts with no activity for three years and all uncashed checks outstanding for more than three years.  Oklahoma credit unions should remit all dormant accounts with no activity for five years and all uncashed checks outstanding for more than five years.

At year-end:

  • Send 1099s.

 

Categories: Financial & Auditing
Posted by Mr. Dean Borland, SCMS, CUDE, VP Product Development, Credit Union Resources, Inc on 2/9/2016

This is one of a series of articles and blogs authored by some of the premier providers of data analytics solutions to help credit unions understand the basic tools, techniques, costs, and benefits of leveraging data analytics to manage the business of the credit union and match products and services to member needs. On behalf of Credit Union Resources, thank you Floyd Salamino, Marquis, for your dedicated service and support of credit unions.

In Part 1 of “Implementing a Data Analytics / Member Relationship Management Strategy,” we discussed the initial five steps of implementing a data analytics strategy including the importance of mapping a plan, equipping the organization with the right systems and partners, and creating the internal synergies to leverage data analytics to enhance member relationships. In Part 2 we will look at steps six through ten of the process, Executing the Plan.

THE EXECUTION

Involve employees from all appropriate functional areas – employee input will ensure the system property supports the workflow and processes.

  • Don’t just use your “best” employees. Find people you know are going to be resistant to change and start gaining their buy-in from the beginning
  • Consider a limited rollout of the member relationship management initiative with a pilot group before launching organization-wide. Encourage feedback from users and customize the system based on their input. Allow the pilot group to “own” the rollout and recognize them for the ultimate successes. Keep the group intact during the organizational rollout – they can be great ambassadors for the initiative.
  • Execute the plan. CRM is a journey, not a destination. Be patient and execute your plan.

QUANTIFY THE RESULTS

  • Identify a set of key measurements and track them on a regular basis so you can see how you are doing.
  • Determine a set of past performance benchmarks to serve as your baseline.
  • Establish measurable goals with defined timelines.
  • Communicate the goals with your entire staff. Be transparent with your objectives.
  • Track results and share with all levels – hold staff accountable for results.

DEBUNK REASONS FOR NOT USING A MEMBER RELATIONSHIP MANAGEMENT SYSTEM

  • “We know our members; we talk with them every time they come in.” How many of your members don’t come into your office on a regular basis? How many of your members are doing business with someone else instead of you?
  • “We are doing just fine without data analytics / member relationship management.” Will your next generation of members be satisfied with the service and solutions you provided to your last generation of members?
  • “We don’t want to appear too salesy.” A member centric culture focuses on providing solutions to member needs, not just peddling products.
  • “Our employees won’t use it because they are too busy… and if they don’t embrace and use it, it will fail.” Leadership is the key. Build employee buy-in from the beginning.

OVERCOMING THE COMMON PITFALLS OF MEMBER RELATIONSHIP MANAGEMENT

  • Lack of a clearly defined plan. Start by asking the question, “What are we hoping to achieve with member relationship management and data analytics?”
  • Lack of management support / buy-in. What are your alternatives?
  • Trying to do too much too quickly. Start simple, build as you gain expertise and capabilities.
  • Failure to follow through on the entire plan. Choose tools and vendors that are scalable, allowing you to start small and grow.
  • Failure to understand and properly manage employee resistance. Use your leadership skills to coach employees and to keep them motivated and positive. Don’t compromise.
  • Allowing the tail to wag the dog. Organizations that give up on member relationship management often do so because they lack C-Level buy-in, solidarity, and conviction.
  • How do we know what impact member relationship management / data analytics is having? Measure the monetary impact on the organization. Develop metrics and monitor them closely.

BIG FINISH

Once simple objectives for member relationship management implementation have been identified, they need to be restated into measurable outcomes, Measure your success against these objectives in order to prove success.

The success of any member relationship management system will be proportionate to the organization’s level of commitment and ability to plan, execute, track and measure.

Floyd Salamino is Vice President, Consulting with Marquis. Since 1987, MARQUIS has been a leading provider of marketing and compliance software and services, with hundreds of clients across the U.S. Jay can be reached at 800-365-4274 / FloydS@GoMarquis.com

Categories: Business Partners, Education & Training, Financial & Auditing, Marketing & Printing, Sales & Service, Strategic Planning & Consulting, Technology Consulting & Compliance
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