According to this issue, a number of changes are required regarding the advance request voucher, underwriting style, open-end plans disclosures, and members’ periodic statements.  Vilker states that though the recent buzz is about CMG’s open-end program, it fully expects other forms providers to follow suit.  According to CMG, the deadline for the forms, disclosures, and underwriting changes is July 1^st, 2010 – for statement changes to take effect with the July month-end statement run.

The article focuses on the following areas for consideration:

• Forms. CMG relayed in a conference call that they will be providing CU*Answers directly with a list of all credit unions utilizing MFOEL plans and doing a mass change.  Once required changes are received, the Lender*VP team of CU*Answers will contact credit union clients to assess the time required and processes for pending changes.  The CUSO also states that it will not be contacting forms providers on behalf of the credit union, and urges credit union lending teams to be proactive.
• Process. From the perspective of underwriting, there are no recommended changes to the CU*BASE software, but numerous alterations within the credit unions’ manner of processing, underwriting and advancing funds.  Some of these changes include holding to the requirement that you cannot fully underwrite each time an advance is made on a loan, and disbursing funds on open-end loans which in the past may have been considered to be closed-end, such as automobiles.
• Periodic Statements. CMG’s recommendations place the same requirements on regular statements as were placed on credit card statements including the aggregation of fees, interest, and placement of sub-accounts in close proximity to each other.

Certain challenges were also recognized from a programming perspective, first identifying which members have a plan, and then tying all of the loans which fall into that category together with an identifying element.  Second, is aggregating these loans on a statement, combining the interest charges associated with them, and then pulling the fees out of the transaction information and listing them separately.

The Audit and Compliance team of Xtend is working closely with the Programming teams of CU*Answers to create a plan to attack these upcoming changes.  But, as with other recent regulatory mandates there remains a bit of debate on how far or close credit unions will require these teams, and the CU*BASE software to take the current CMG recommendations.  For this reason, the CUSOs have urged their credit union clients to communicate their wishes for adherence to Reg. Z changes.

Also stated, final decisions on how to attack these changes will be made no later than May 7, 2010, and any preferences and concerns can be voiced on the Advisor Reg. Z / Credit CARD Act Open forum: http://advisor.cuanswers.com/

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According to the CUSO, this booklet contains a cross-reference of some key CU*BASE features and services, showing whether or not they are being used by other credit union partners.  The Peer Analysis is organized by credit union member size, so you can easily compare a credit union’s usage of CU*BASE features with other credit unions of similar size.  CU*Answers advises that a regular review of the Peer Analysis categories will help remind credit union CEOs of CU*BASE features they may have been waiting to implement, and possibly give the motivation to start.

New items added for the 2010 Peer Analysis include:

• 5300 Call Report Tools
• Due Diligence Monitoring Flag
• Privacy 2010 Controls
• Dividend Donations
• Red Flag Address Warning
• Tiered Service Analysis Tool

And much more!

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This class is designed to teach credit union supervisory personnel the various tools used by CU*BASE to prepare for audits and examinations.  According to the CUSO, often the results of an audit or examination contact come down to how well the credit union can communicate their controls, management concepts, and the results of their activity.  CU*Answers has a full-time Compliance Officer with experience as both a credit professional and state examiner. This class will focus not only on audit preparation but on managing the application of data processing-related compliance issues, with CU*Answers as a partner.

Other objectives for discussion include exploring the credit union’s role in waving the regulation “red flag”, reviewing the reports CU*BASE generates used for ALM decision making, and investigating the information required in basic ALM Models.

This class is offered via web conference and registration for this course is required at least 2 days in advance, which can be done at http://cuanswers.com/education/syllabi/?course=2.62.

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CU*Answers says this unique division was created to assist credit unions utilizing its CU*BASE system in being better prepared to face growing daily compliance and internal auditing requirements. Daily monitoring activities are completed by the team of Audit Link specialists, allowing the credit union to redirect its internal staff to other important activities. Audit Link features a consistent stream of audit reports presented to each client’s management team, and delivers a high level of internal audit processes for which many credit unions have been lacking.

Jim Vilker, Business Manager of Audit Link, says “The enthusiasm of client’s utilizing this service has exceeded our 2008 growth projections by 100%. We currently have 20 credit union’s either using Audit Link, or contracted to start during the first quarter. This service is a great example of how credit unions can collaborate to craft a service as based upon a common need, reducing everyone’s cost and redirect various staff to better serving members.”

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