NAFCU Compliance Blog

Today's Reports are Tomorrow's Regulations: Overdraft Edition

Written by Steve Van Beek

On Tuesday the CFPB issued a Study of Overdraft Programs which outlines their findings of studying the overdraft market.

The Study was supplemented by the following materials:

• Press Release: CFPB report raises concerns about impact of overdraft practices on consumers

• Prepared Remarks: Director Richard Cordray on overdraft report press call

• 3-Page Fact Sheet: CFPB report raises concerns about impact of overdraft practices on consumers

For compliance officers and risk managers, I'd start with the Fact Sheet and then dive into Cordray's speech and then the Study to get an idea of where the CFPB is heading next on overdrafts.

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Here are a couple of items that stood out to me from Cordray's remarks:

"Our report today examined overdraft practices at some of the country’s larger financial institutions and found wide variations across them when it comes to overdraft opt-in rates and costs. At some institutions, more than 40 percent of new customers were opting in for overdraft coverage; at others, it was less than 10 percent. The gap may reflect differences in the substance of overdraft programs, or differences in customer base, or differences in marketing approaches. On this point, we are interested to dig in and learn more about the reasons why." (Emphasis added).

What is your credit union's opt-in rate? How are you marketing your overdraft programs?

"A second takeaway is that financial institutions have very different policies, procedures, and practices that can be highly complex and difficult for consumers to understand, yet greatly affect whether and how often they will incur overdraft fees...Some charge no overdraft fees on items under a certain amount (say, for example, a transaction of $5 or less); others do not charge if the total amount of the net overdraft at the end of the day is under a certain amount. At still other institutions, if you miss by as little as a penny, you may incur a hefty overdraft fee. Predicting or planning around these results can be highly complex." (Emphasis added).

Does your credit union have a de minimis exception for overdrafts?

According to the recent Pew Trusts report, 22 of the largest 36 banks had minimums before an overdraft would be charged:

One change suggested in the Pew Report was to add a "reasonable and proportional" limit on overdraft fees. In other words, if a member overdraws by $5 - you'd be limited to a $5 overdraft fee. Similar to the existing restrictions on penalty fees for credit cards under 12 CFR 1026.52(b)(2).

NCUA Report: Electronic Banking Threats and Security

Written by Bernadette Clair, Regulatory Compliance Counsel

One of the articles in NCUA's May 2013 Report, takes a look at Electronic Banking Threats and Security. The article reminds credit unions to be diligent in safeguarding member information and ensuring proper security and controls when offering E-banking services, such as internet banking, phone banking, mobile banking, etc. (Exam Tip: According to the article, NCUA examiners have received updated training on E-banking security and have been instructed to review these areas in more detail during exams.)

The article highlights guidance from the regulators related to E-banking. From the article:

"In October 2005, the Federal Financial Institution Examination Council (FFIEC) issued guidance entitled Authentication in an Internet Banking Environment. The guidance provided minimum supervisory expectations for effective authentication controls related to high-risk online transactions involving access to customer information or the movement of funds to other parties.

In 2006, NCUA issued a Letter to Credit Unions, No. 06-CU-13, to aid in the implementation of the authentication guidance and provided answers to frequently asked questions. The letter reinforced the risk-management framework specified in the FFIEC’s earlier letter and updated supervisory expectations for effective member authentication mechanisms, layered security and other controls to combat identity theft, cyber attacks and online transaction fraud.

A 2011 Letter to Credit Unions, No. 11-CU-09, reflects a more layered approach to risk-management, and includes annual risk assessments for E-banking services. It discusses minimum monitoring requirements at initial login and for funds transfers, as well as additional guidance on challenge question authentication techniques. The letter also has valuable information about new expectations for customer awareness programs, as well as, recommendations for increased scrutiny of commercial accounts.

In February 2013, NCUA issued additional guidance in the form of a Risk Alert, 13-Risk-0[1]. The Alert encourages risk mitigation strategies, against DDoS attacks such as: 

• performing risk assessments aimed at identifying risks associated with DDoS attacks;
• ensuring incident response programs include DDoS attack scenarios during testing; and
• performing ongoing third-party due diligence of Internet and web-hosting service providers to identify risks and implement appropriate traffic management policies and controls."

Here are links to the guidance documents referenced  in the excerpt above:

FFIEC’s Authentication in an Internet Banking Environment

NCUA Letter to Credit Unions, No. 06- CU-13

NCUA Letter to Credit Unions, No. 11-CU-09

NCUA Risk Alert, 13-Risk-01

See the article for additional details and guidance resources.

What is Three-Dimensional Compliance?

Written by Steve Van Beek

Last week, I shared two slides from my upcoming presentation How the CFPB Impacts Your Credit Union at NAFCU's Directors Conference in Asheville, NC. One of the key takeaways will be the idea of Three-Dimensional Compliance.

So, what is Three-Dimensional Compliance? In short, it is a new way to think about the role compliance plays in the credit union. Here is a snippet from my article in the May/June The Federal Credit Union magazine:

"Beyond the Checklist

The creation of the CFPB means that credit unions need to review the role compliance plays in the credit union. Often the compliance officer is brought into a discussion late in the process, and her job is to approve or disapprove a particular action based on the regulatory requirements. Going forward, this “yes or no” approach to compliance will need to change. The CFPB’s focus is principle-based as well as requirement-based. Not only will credit unions need to determine if their product or service is compliant with laws, regulations and guidance, but they will also need to expend resources to document that the product or service provides a benefit to members.

When new requirements are issued, credit unions won’t be able to simply work through a checklist of new requirements and make tweaks to their products and disclosures. They will also need to undertake a three-dimensional analysis of the product or service, asking: 

• Why is the regulator taking this action?

• How were consumers impacted by the prior practices?

• How do consumers view the product or service?

• How does the credit union market the product or service?

• Does the credit union’s marketing of the product or service correspond with how the product or service is used by members? 

In other words, when regulators identify a product or service that has been abused (by either consumers or financial institutions), credit unions need to complete a full 360-degree review of their offerings in order to reduce their compliance, reputation and strategic risks."

You can find the full article here.

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Reading the CFPB's Tea Leaves. If that message sounds like something your senior managers or Board needs to hear, be sure to pass along information about NAFCU's Annual Conference - specifically our Regulation & Economy Track. We'll be meeting in Boston from July 9-13 and you can see the description of my talk below:

Reading the CFPB’s Tea Leaves 

The pace of the Consumer Financial Protection Bureau’s rulemaking has put credit unions on the defensive. For example, the CFPB’s final mortgage regulations will require a complete overhaul of credit unions’ mortgage operations. Hear which requirements will need special time and attention from your staff and gain best practices to stay on track with your implementation plan. And, just as importantly, hear which areas the CFPB is looking at next. Today’s scrutiny leads to tomorrow’s regulatory requirements. We’ll discuss the CFPB’s focus on prepaid cards, private student lending, overdraft protection programs and checking account disclosures – including what steps your credit union can take now to prepare for new requirements. 
Steve Van Beek, Esq., NCCO, Director of Regulatory Compliance, NAFCU

Full information on the conference can be found here.

2013 HMDA Getting it Right Guide; New NAFCU Calendar; Reg Alert on Escrow Proposal

Written by Steve Van Beek

2013 HMDA Guide. Yesterday, the Federal Financial Institution Examination Council (FFIEC) issued the 2013 HMDA Getting it Right! guide. According to the main page:

"The 2013 edition reflects the transfer of authority over Regulation C from the Federal Reserve Board to the Consumer Financial Protection Bureau. Appendix D, comment 1003.2 (Financial Institution)-2 is updated with the asset-size threshold exemption applicable to collection of 2013 data. There are also minor changes to the general text of the Guide, including updates to Sources of Geographic Information and Submitting the LAR."

You can find the full PDF of the 2013 Guide here.  

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Long Time Coming. Now, you may be wondering when the last version of the Guide was issued?  2010.  The 2011 version would have been the lame duck one when the Federal Reserve still had authority for Regulation C (HMDA). However, there was no guide issued. On July 21, 2011, the CFPB took over Regulation C and they failed to release a guide in 2012.  Fortunately, in year two, the CFPB found the time to update the Guide and provide guidance to HMDA-reporting institutions.

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Garbage In, Garbage Out? The CFPB is a self-described "data-driven" agency. If you doubt it, take a read through this Bloomberg.com story: U.S. Amasses Data on 10 Million Consumers as Banks Object. To me, if you want to be data-driven - the best first step is to make sure your regulatory requirements are clear and understandable so that the data you collect (whether it be consumer complaints, HMDA data, or anything else) is as reliable as possible. But, that's just me.  

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NAFCU Calendar.  NAFCU has a new calendar on our website that features:

• Compliance Deadlines;

• Important Regulatory Dates;

• Education & Conferences;

• CU Research Survey Deadlines; and

• Other Important Dates.

The calendar allows you to navigate month-by-month, click to find more information and add dates to your own calendar. For example, the "more information" link on the June 1st Escrow Changes Deadline includes this information:

CFPB Compliance Deadline: Escrow Requirement

Description:

Amended escrow requirements for higher-priced mortgage loans. Added a new small creditor exemption for credit unions that meet a four-part test.

Regulatory Text: 12 CFR 1026.35

NAFCU Compliance Blog: Mortgage Reform - Escrows

NAFCU Resources: www.nafcu.org/mortgagerules/#escrow

Download the latest full Compliance Calendar, including proposed regulations, past deadlines and more.

Date:Jun 01, 2013    

Add to Calendar                                             Back to Calendar

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NAFCU Members. The Mortgage Rules webpage includes NAFCU's Regulatory Alert on the CFPB's recent proposed rule. The proposal was published in the Federal Register yesterday and only provided 15-days for comments (comments to NAFCU on the Regulatory Alert are due on Wednesday, April 24).  

Outstanding Article on Reg E Error Resolution Procedures; Upcoming NAFCU Webcasts

Written by Steve Van Beek

Last Wednesday, I blogged on an article from the Fourth Quarter 2012 Philadelphia Federal Reserve's Consumer Compliance Outlook on Vendor Risk Management. Today, I wanted to share another outstanding free article on Error Resolution Procedures and Consumer Liability Limits for Unauthorized Electronic Funds Transfers.

The article is an absolute must read  - especially the examples which demonstrate the timeframes and liability limits. I strongly suggest passing this around to others at your credit union and consider using for training.

Reg E error resolution procedures has been mentioned by NCUA's Office of Consumer Protection in the past as an area where they see numerous member complaints and technical violations by credit unions (for example, by missing the timeframe requirements).  Again, take a look at the full article and be sure to share liberally at your credit union to ensure everyone is on the same page.

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Upcoming NAFCU Webcasts.  We have another full slate of webcasts for the next month or so. Registration is open for all the webcasts listed below:

• Which New Requirements Apply to HELOCs? - April 10, 2013.  Register by COB Wednesday to Save $100!
  • Unfortunately, the new requirements applicability to HELOCs are scattered throughout the 3507 pages of mortgage information released by the CFPB. I'll be explaining which requirements apply to HELOCs and, just as importantly, which do not. If your credit union makes HELOCs, be sure to sign up!

• Preparing for New Mortgage Servicing Notices - April 17, 2013
  • Suzanne Garwood of Venable, LLP will explain new mortgage servicing notices including the mortgage periodic statement, interest rate adjustment notices (ARM notices) and force-placed insurance notices. Keep in mind that the small servicer exemption only applies to the periodic statement requirement and all credit unions servicing closed-end mortgages would need to comply with the ARM notices and force-placed insurance notices. Sign up by April 10 to Save $100!

• A Look Inside NCUA's National Supervision Policy Manual - May 1, 2013
  • Hear from experienced credit union attorney David Reed and Larry Fazio, Director of NCUA's Office of Examination & Insurance, on NCUA's new National Supervision Policy Manual. You'll receive an overview of the examination process - including recent (and future) changes by NCUA. Sign up today!

• NCUA's Office of Consumer Protection: Function, Role and Objectives - May 8, 2013 - Free to all credit unions!!
  • Keeping an eye on NCUA's Office of Consumer Protection was a key takeaway from NAFCU's Regulatory Compliance School. The webcast will feature Gail Laster, Director of NCUA's Office of Consumer Protection, and Moisette Sweat, Director of Consumer Compliance Policy & Outreach, as they explain the role of NCUA's Office of Consumer Protection. Because of the importance of this information, we are making this webcast available for free to all credit unions.  Sign-up here (look to the right for the "Register Now" button).

You can find additional information on NAFCU's live and on-demand webcasts here.  

Vendor Risk Management - Compliance Considerations

Written by Steve Van Beek

Back in May 2012, the Philadelphia Federal Reserve's Consumer Compliance Outlook webinar series discussed Vendor Risk Management - Compliance Considerations (the slides are available here). The Fourth Quarter 2012 Consumer Compliance Outlook publication included an article that provides highlights of the main themes. As you can see from the headings and subheadings, this article is a must read:

Vendor Risk Management - Compliance Considerations

QUESTIONS ABOUT THIRD PARTIES

What Are Common Types of Third-Party Relationships?

What Are the Risks of Using Vendors?

PRACTICES THAT INCREASE THE RISK OF VIOLATIONS

• Overreliance on third-party vendors.
• Failure to train new staff or retain knowledgeable staff.
• Failure to adequately monitor the vendor.
• Failure to set clear expectations.

EXAMPLES OF VENDOR RISK MANAGEMENT COMPLIANCE ISSUES

Flood Insurance Monitoring

Loan Modifications

Credit Card Administration

Disclosure Software

Revenue Enhancements

BEST PRACTICES

• Due diligence.
• Risk assessment.
• Clear contractual expectations.
• Comprehensive monitoring program.
• Board oversight.

CONCLUSION

Vendors provide value in the expertise and experience they offer; however, financial institutions must still maintain active oversight. It is important to remember that when a vendor performs a service or function, the institution bears ultimate responsibility for compliance. Because varying levels of risk remain with the institution that offers the product or service, a strong vendor risk management program is key to maintaining compliance and avoiding claims of improper treatment of bank customers. With good vendor management, banks can minimize the risk of less direct oversight or control and maximize the benefits gained through a well-managed vendor relationship. Specific issues about vendor risk management should be raised with your primary regulator.

Again, I recommend reviewing the full article and passing it along to your colleagues.

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I also wanted to highlight the subsection on board oversight - which states:

"Board oversight. Keeping the board of directors properly informed about the vendor management program is key to ensuring that they can provide proper oversight and that the bank’s management process addresses the risks inherent in third-party relationships. The board should review the vendor management policy, due diligence reports, risk assessments, and monitoring results."

Board of Directors & Risk Management. Risk management and the role of the credit union's board of directors will be the focus of my colleague Anthony Demangone's presentation at NAFCU's upcoming Board of Directors and Supervisory Committee Conference.

Additionally, I'll be presenting on How the CFPB Impacts Your Credit Union and will include a discussion of the CFPB's latest actions related to "unfair, deceptive or abusive acts or practices" (UDAAP) - including how the actions of third-parties resulted in liability for the financial institutions. If your board is considering attending, sign up by Friday, March 29th to Save $100.

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NAFCU's Online Training Program also includes 14 courses for credit union boards - including one on Risk Management.  

Five Takeaways from Regulatory Compliance School; Earn your NCCO!

Written by Steve Van Beek

Last week was NAFCU's 2013 Regulatory Compliance School, and we had an outstanding class. Great questions, great speakers and great networking opportunities.  

Here are five takeaways from School:

• The role of compliance is changing and credit unions need to make sure their compliance function is three-dimensional

• Credit unions need to establish a mortgage rule implementation team to manage the numerous changes

• The actions of the CFPB and NCUA's Office of Consumer Protection have the potential to increase reputation risk at credit unions

• Compliance officers need a seat at the table during product development and rollout

• No one can do it alone - compliance officers should reach out to colleagues (both internal and at other credit unions) to ensure their CU is keeping up with all the new requirements

Congratulations to the Class of 2013 - it was truly a pleasure to spend the week examining the existing (and future) regulatory environment facing credit unions.  

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Compliance Seminar. If you missed Compliance School, consider joining us in October for our Regulatory Compliance Seminar in Nashville where we'll be reviewing the latest compliance issues facing credit unions. We're building the agenda now, so if you have any suggestions of "must cover" topics - just shoot us an email.

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Earn Your NAFCU Certified Compliance Officer (NCCO) designation. Compliance School offers the ability for attendees to sit for four examinations and earn the NCCO designation. We also offer a self-study approach that allows anyone seeking a thorough understanding of the laws and regulations impacting credit union operations. 

The NCCO exams track NAFCU's Credit Union Compliance GPS (the 2013 version) and interested persons can purchase all four exams and have them proctored by a colleague at the credit union. If you are interested in earning your NCCO exam, take a look at the following resources:

• What is on the NCCO exams?

• NAFCU's 2013 Credit Union Compliance GPS*

• 2013 NCCO Exam Study Guide (opens as a PDF)

• NCCO Program Frequently-Asked-Questions

The FAQs include this one making it clear the NCCO designation is open to everyone:

Does my credit union or organization need to be a member of NAFCU for me to pursue the NCCO designation? 

No, the NCCO program is open to everyone. Any credit union professional who desires to improve their overall comprehension and skills in the compliance arena may pursue the NCCO designation.  Currently, there are CEOs, compliance officers, internal auditors, attorneys, lending officers, risk managers, vendors and numerous other individuals who have successfully passed the exams to become NCCOs.    

*The GPS is not required to take the NCCO exams. However, it is strongly recommended as it serves as the primary text for the NCCO exams. In other words, the information needed to answer each exam question is covered in the GPS text. Additionally, keep in mind that the GPS is one per credit union (or organization). If your credit union sent one person to our 2013 Compliance School (or you've purchased the 2013 GPS), you would not need to purchase another copy.  

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Or, budget to join us for our 2014 Regulatory Compliance School where you'll receive in-person training and the opportunity to sit for the NCCO exams!  

Today's Reports are Tomorrow's Regulations - Private Student Loans Edition

Written by PJ Hoffman, Regulatory Affairs Counsel

In case you haven’t noticed, it seems that everyone has an opinion about private student lending. In just the past few months we have seen regulators, legislators, and news outlets all getting in on the act. If your credit union is involved with private student lending or anticipates entering into the market sometime soon, then you need to be paying attention. After all, today’s reports are tomorrow’s regulations. 

We’ve been ringing the bell here at NAFCU on student lending as reports and requests for information have come up, but it is important to understand the landscape going forward.

The CFPB has had this issue in their sights for a while now. In October 2012, the CFPB’s Student Loan Ombudsman released a report on private student loans that highlighted and summarized information and complaints received by the CFPB concerning the student loan marketplace. Many of the issues centered on frustration about the inability to speak with personnel empowered to negotiate a repayment plan, inability to refinance, and inability to access repayment plans previously advertised. While the CFPB acknowledged that credit unions and other small financial institutions generated very few complaints and that increased participation from those same small institutions might benefit the market, it is incumbent upon us to see that today’s reports are tomorrow’s regulations.

The CFPB has taken it two steps further in focusing on financial products offered to students, which Steve mentioned here on this blog, when they introduced two requests for information on financial products marketed to students through colleges and universities and another on the private student loan market. NAFCU has put out Regulatory Alerts on both available here with comment letters to follow.

Just last week, the CFPB offered a proposed rule to define larger participants of the student loan servicing market. This would extend the CFPB’s supervisory authority to encompass any non-bank and non-credit union that services over 1 million student loans. Although this rule will not affect credit unions directly, it will undoubtedly change the student loan servicing market and therefore any credit union that deals in that market.

The CFPB is not the only regulatory agency keep their eye on private student lending. Our own NCUA just published an article in their March report titled “Understanding The Risks of Private Student Loans” where they warn of upcoming risks to credit unions regarding private student loans. With quotes like “NCUA anticipates private student loan delinquency rates will likely increase in coming years” and “NCUA expects credit unions to establish reasonable concentration limits for a private student loan portfolio to protect against risk” you know that the NCUA is keeping a keen eye on private student lending. It’s not a coincidence that this article is coming out around the same time as the CFPB requests and we need to be sure to read the tea leaves going forward on this issue.

We’ll be keeping you informed as we hear and see new developments but if your credit union is involved with private student lending please be aware of the recent increase in attention by regulators. 

Help is Here: NAFCU’s 2013 Credit Union Compliance GPS

Written By JiJi Bahhur, Regulatory Compliance Counsel

We talk to credit unions every day. And, we hear the same concerns, fears and frustrations:

• How do we keep up?
• How do we know if this is the latest information?
• Where can I find that guidance document?
• When will someone explain this information in plain English?
• How do we get everyone on the same page without busting our limited training budget?

It is with these conversations in mind that we created the GPS and are pleased to announce the 2013 edition (with a very shameless plug).

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NAFCU's Credit Union Compliance GPS - 2013 Edition. Hot off the electronic presses is the 2013 edition of NAFCU’s Credit Union Compliance GPS.  Written by NAFCU's compliance team, this electronic manual spans almost 500 pages and covers everything from the basic anatomy of a federal credit union to specific regulations from the NCUA, CFPB, and more.  It is the ideal companion for all credit union compliance officers and staff, consultants, vendors and attorneys.  The GPS translates complex regulatory language into plain English to help credit unions on a day-to-day basis while at that same time providing links to the applicable regulations, laws, and guidance documents.

And here’s the great part – you don’t have to be a NAFCU member to purchase the GPS.  The GPS is available to anyone and everyone at one affordable price ― $399 for NAFCU members and $499 for nonmembers. One purchase allows you to share the electronic manual with your entire credit union or business. And for no additional cost, your purchase of the 2013 GPS includes access to NAFCU’s new Scope & Applicability Charts to help you make sense of the CFPB’s new mortgage rules.

If your credit union has a prior version of the GPS (via purchase or attending a prior Regulatory Compliance School), you'd need to purchase the new 2013 GPS in order to receive the latest information. We've put a ton of time and effort into thoroughly reviewing the 2013 GPS to reflect regulatory changes. Additionally, we provided some additional bells and whistles to the 2013 GPS based on credit union feedback:

• an expanded section on the CFPB;
• user-friendly bookmarks, hyperlinks and pagination for easy navigation; and
• enhanced study tips for those studying for the NAFCU Certified Compliance Officer (NCCO) exams.

For a closer look, click here and check out our “sneak peek” documents available in the tabs to the right-hand side of the webpage (e.g., main table of contents, one page table of contents, section by section listing). 

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NAFCU Certified Compliance Officer (NCCO) Program. NAFCU’s Credit Union Compliance GPS serves as the learning manual for NAFCU’s annual Regulatory Compliance School held each March.  NAFCU also offers a self-study program which allows anyone interested in obtaining a solid foundation of the compliance issues facing credit unions to take the four exams required to earn the NCCO designation.

If you are interested in the GPS, take a look at our new NCCO Exam Study Guide (opens as a PDF) and consider taking the next step and obtaining your NCCO.  

The Extra 30 Minutes & Director Education

Written by Steve Van Beek

On Friday I blogged about the Importance of Informed, Decisive and Strategic Board Members.  Over the weekend, I read another article that highlighted this issue and included a great tip.  The article was from NCUA Board Member Michael Fryzel and states:

"Recently, when visiting a credit union, I heard an excellent idea on helping board members better understand the many aspects of the financial services world. I call the idea "the extra 30."

Each month, prior to their board meeting, directors arrive at the credit union 30 minutes early. Those extra 30 minutes are then spent listening, asking questions and learning about one specific topic that will help them do their jobs better.

The range of subjects covered during the extra 30 minutes can be anything from the value of passbook accounts to asset liability management. It can even be a discussion on an NCUA regulation or the benefits of derivatives.

The extra 30 sessions should be concise, plain English presentations that provide solid information on a particular subject. The session should leave the participants knowing a little more than they knew before and eager for what is to come at the next session."

Of course, when I'm reading the section above I'm thinking about ways credit unions can use NAFCU's Online Training Program which includes 14 unique modules for boards. The majority of the modules are between 25 and 35 minutes in length - a great way to train during "the extra 30 minutes."

Board Member Fryzel continues:

"Director education is one of the most important functions of a credit union. The people entrusted with fiduciary responsibility need to know what their credit union is doing and what they are voting to approve when making decisions. Credit unions must continue to provide directors with the opportunity to understand and become familiar with the many aspects of our ever changing financial world. The first step in achieving that goal is to make education easy, available and understandable.

What better way to begin than with just an extra 30?"

Again - this builds on Friday's blog post on the Importance of Informed, Decisive and Strategic Board Members.  

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Modules from NAFCU's Online Training Program. Below is a listing of the 14 board modules in NAFCU's Online Training Program:

1. The Nature, Foundation and Organization of Federal Credit Unions (33 minutes)
2. The Role of the Federal Credit Union's Board (34 minutes)
3. The Role of the Supervisory Committee (33 minutes)
4. Ethics and Fiduciary Duties (26 minutes)
5. The Regulation of Federal Credit Unions (23 minutes)
6. The Examination of Federal Credit Unions (38 minutes)
7. Risk Management (36 minutes)
8. Privacy, Security & Identity Theft (19 minutes)
9. The Bank Secrecy Act, Money Laundering and Financial Crime (44 minutes)
10. Asset Liability Training (35 minutes)
11. Discrimination Issues for Credit Unions (32 minutes)
12. On-Demand Webcast:  Essential Financial Literacy Education (60 minutes)
13. On-Demand Webcast:  Corporate Governance and Board Fiduciary Duties (90 minutes)
14. On-Demand Webcast:  BSA & OFAC Compliance for Directors and Supervisory Committee Members (75 minutes)

I see numerous opportunities to get your extra 30!  You can get a sneak peek at the Online Training Program here.