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3. Asset/Liability Management Policy and Procedures An ALM Policy is not actually required. However Read -- NOTE D as it is nonetheless recommended. Here you may also address loan concentration targets (with loans by type, risk tier, concentration levels, etc). This will make your Examiner happy and concentrate such information in “one place” facilitating the ease of review. NCUA General Procedures may be adopted as approved by the Policy – such as Investment Procedures may be Separate for Management – Board to Operate within the parameters of the Policy No Further Comment. 6. Advertising Procedures 9. Credit Union Physical Security Procedures 15. Compliance Program Policy and Procedures NA NA Procedures Recommended with Tie-in to Compliance Policy and Required Approvals due to Liability and Reputation Risk Exposure. NA Procedures are No Further Comment. Strongly Recommended and Likely Expected based on issues addressed in the NCUA Examination Guide as if Credit Union’s -- Treated as if Included in 12 USC 1881 (“Bank Security Act”) See – NCUA Letter No. 02-FCU-12 NA NA Recommend a Short Policy and a More Detailed Procedure to support the Credit Union’s compliance operations and to provide “good faith” error defense protections available in case of a claim or regulatory action. In this policy the Credit Union can address basic due diligence, training and “good faith” procedures to insure compliance – Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 32
16. Conflict of Interest/Code of Ethics Policy and Procedures Policy is Required (also covers “Bank Bribery Act”: See NCUA Letters to Credit Union Nos. 03- FCU-07 (General and Sarbanes-Oxley Standards); NCUA Letter No. 84 on Insider Dealing and Conflicts of Interest Policies and Procedures may be bifurcated as the Credit Union chooses. However, the elements addressed in the foregoing must be addressed. rather than addressing same via several different polices (i.e., include all the general regulatory polices and/or procedure here into a single “Board Approved Policy” with Detailed Management Procedures. No Further Comment. 18. Credit Union Business Continuity Policy and Procedures // Disaster Recovery – // and Pandemic Influenza Policy and Procedures Policy Required: 05- FCU-02 – Travel Expenses (to pay / reimburse) NCUA Letter No. 109 –The board of directors and senior management of financial institutions are responsible for: • Establishing policies, procedures and responsibilities for comprehensive contingency planning. • Reviewing and approving the institution's contingency plans annually, documenting such reviews in board minutes Policies and Procedures may be bifurcated as the Credit Union chooses. However, the elements addressed in the foregoing must be addressed. No Further Comment. Required: See NCUA Letters to Credit Union Nos. 08-FCU- 01; 06-FCU-12; 06- FCU-06; 01-FCU-21; 98-FCU-12 Copyright©1994-2010 by Credit Union Resources & Educational Services, LLC. All rights reserved. Revised February 2010 33
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Compliance Update - I REGULATORY AN
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Introductory Notes: Basic Obligatio
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performed by boards of directors. T
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What if an applicant “volunteers
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Please answer the following questio
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MULTIPLE ISSUES AND RESOURCES - SOM
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• Review of the negative shares r
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illustrates how certain provisions
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SAMPLE CREDIT UNION BUSINESS PLAN M
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EMPLOYMENT AGREEMENT Revise to addr
Page 21 and 22: 13. Evaluate the job performance of
Page 23 and 24: 2. By Employer For No Cause. Employ
Page 25 and 26: Vendor Due Diligence II Security As
Page 27 and 28: Vendor Due Diligence VII TERM AND T
Page 29 and 30: Vendor Due Diligence XII Backgroun
Page 31 and 32: Monitoring the Vendor At a minimum,
Page 33 and 34: NOTE: The BSA also contains a “wh
Page 35 and 36: (5) Confidentiality of reports. SAR
Page 37 and 38: PRIVACY - INFORMATION SECURITY Priv
Page 39 and 40: Disposal of Consumer Reports and Ot
Page 41 and 42: Compliance Update - II REGULATORY A
Page 43 and 44: Introductory Notes: Knowing if you
Page 45 and 46: I. POLICY AND GUIDELINES Portions O
Page 47 and 48: any CUSO. [Gifts may not be accepte
Page 49 and 50: Conference and Seminar Costs Fees f
Page 51 and 52: We have stated that there must be a
Page 53 and 54: IV. POLICY REGARDING CONFLICTS OF I
Page 55 and 56: public, even though, such relatives
Page 57 and 58: and other relatives who live in the
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Page 61 and 62: Legal / Compliance Consultation Not
Page 63 and 64: MERGER AND CONSOLIDATIONS ISSUES NO
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Page 67 and 68: A Review of ‘Red Flags’ and wha
Page 69 and 70: Business Depositors: Understanding
Page 71: WHAT POLICIES, PROCEDURES AND RISK
Page 75 and 76: Union Assessment 33. Identity Theft
Page 77 and 78: Procedures 60. Training Policy See
Page 79 and 80: Also - consider the other changes c
Page 81 and 82: policies, procedures and documents
Page 83 and 84: Underwriting Advertising In July 20
Page 85 and 86: 135-2009 Community Notice // OE/CE
Page 87 and 88: Credit Union’s lien right are not
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