First off, NCUA has released the agenda for its December Board Meeting. You can access it here. (It appears fairly light to the Compliance Guy from a compliance point of view.)
NAFCU members - we've published a Regulatory Final on NCUA's recent final rule that incorporates its bylaws into NCUA's regulations. You can access it here. (NAFCU member log-in needed.)
OK, its Friday. How about something a little bit lighter. The Compliance Guy is getting married this May. Therefore, my care-free, dating days are now behind me. (Thank the Lord!) But those dating days really prepared me for compliance research. Don't believe me? Well, here's one dating/research connection. I'll share others in future weeks.
Dating/Compliance Lesson #1. Watch out for loaded questions
Most people are polite by nature. We prefer the oblique to the blunt and honeycombs to red vinegar. The women I date are no different.
They often ask one question, when they should be asking another.
What do you think about smokers? What do you think about dogs? What do you think about big families? These are all loaded questions. My date doesn’t really care what I think about smokers in general.
She wants to know if she can light one up after gulping down a $90 bottle of wine that the waiter said would complement her crab cakes.
As a compliance officer, you often are in the same boat. “Can we charge this fee?” upper management may ask. You may be tempted to serve up a yes or no answer, but be careful. The question is loaded. As a rule of thumb, I always translate “Can we charge this fee?” into “We’d like to charge this fee. We think we can do it this way. Can we? If we can’t, is there another way? Oh, and how will it affect the APR and our disclosure requirements? And is there anything else I forgot to ask?”
Carefully determine what management needs. A good compliance officer will ask questions and seek clarification. What is management trying to do, and what does it want? Until you truly answer those questions, your research efforts may go wasted.