The Irish League of Credit Unions established the Credit Union Compliance Centre (CUCC) as a central compliance and risk management point of contact for credit unions.
It is now an expectation of financial services regulators that each credit union has effective and embedded risk and compliance functions. The board of directors will depend on these functions to provide integrated assurance that the credit union is operating in a compliant and prudent manner.
The CUCC works to assist credit unions in fostering a strong organisational culture in the area of risk management and compliance.
On 22nd April at the ILCU AGM 2017, credit unions voted to support the Credit Union Compliance Centre (CUCC) motion to establish a compliance and risk management centre of excellence for all credit unions. Building on the success of the CUCC to date, and working directly with your compliance and risk management officer(s), we now have the opportunity to build better supports for credit unions and achieve a more consistent approach to compliance, risk management and control frameworks. Due to increased regulatory expectations, the rapid pace of change within the Movement and the strategic ambitions of credit unions, this initiative is very timely.
The benefits for credit unions of a more standardised approach to compliance and risk management are:
- A consistent framework for compliance and risk management will allow the internal functions to focus more time on output, with less time required on developing and maintaining the process;
- It will better position a credit union to tackle business model development and implement new services;
- It improves the availability of resources to allow for a more pro-active approach to tackling upstream compliance requirements and emerging risk areas;
- Risk data can be collected and aggregated centrally, which can then be disseminated and used by the risk function to benchmark against the organisation’s performance;
- It facilitates better information-sharing and networking amongst credit union risk and compliance professionals; and
- Ultimately it leads to better protection of our members’ savings.
As compliance is an ever increasing area of priority within the financial services sector; the CUCC Compliance Advisory Service is a compliance community whose mission is to provide a support network and compliance-specific resources to individuals involved in credit union compliance.
The advisory service is provided by a team that has significant expertise in areas of compliance. More importantly, the team has extensive experience of working with credit union officers and voluntary assistants. It is this unique blend of expertise and credit union know-how that ensures the guidance and support provided to credit unions are professional, tailored and practical.
The CUCC Compliance Advisory Service provides all the supports necessary to embed an effective compliance programme within a credit union.
|Compliance Programme Components||CUCC Supports|
|A Compliance Plan||
|A Compliance Policy||
|Clearly documented roles and reporting lines||
|A well-resourced and knowledgeable
|Robust compliance reviews||
|Accurate reporting to the Regulator(s)||
|Buy-in from all officers||
REGIONAL WORKING GROUPS
As this is a centre for compliance professionals, the guidance and
support is not just one way: the compliance function and other
senior officers within a credit union have the opportunity to share
knowledge and best practice with each other; and with neighbouring
credit unions. This is facilitated through regional working groups in
both the Republic of Ireland and Northern Ireland.
A dedicated website www.cucc.ie is available to all credit unions.
These online resources include relevant regulation and legislation,
compliance guidance, updates and briefing documents.
ONGOING ADVICE AND SUPPORT
Credit unions receive on-going phone and email support and
guidance on regulatory matters. The main point of contact in each
credit union is the compliance officer (or equivalent in Northern
Ireland); however other officers such as directors and management
may also avail of the service.
In addition to the extensive guidance and support, from September
2017 credit unions will also have access to credit union-specific
compliance management software. This software will enable credit
unions to track, analyse and report on their compliance requirements
and breaches in line with regulatory requirements. In addition to
this, the software will enable the credit union to produce a set of
reports to support the credit unions in its ongoing management of its
ANALYSIS OF COMPLIANCE REQUIREMENTS
From years of working directly with compliance officers, the CUCC
recognises that these professionals must prioritise their time in order
to deliver for their credit union. As such, complex legal and regulatory
requirements are analysed and distilled down to key compliance
requirements which can then be acted upon by the credit union.
This analysis is delivered through monthly updates and guidance sent
directly to the key contacts within each credit union.
The CUCC has developed its business model to enable it to provide
more supports to a wider number of credit unions. It is now funded
through an annual financial contribution made by each credit union.
The table below lays out the contributions to be paid during 2017 and
2018. The contribution must be paid by 1st July of each year.
The CUCC has developed its business model to enable it to provide more supports to a wider number of credit unions. It is now funded through an annual financial contribution made by each credit union.
Please contact CUCC for details.
1. Does the service provided replace what our Compliance Officer
The CUCC service does not supplant the requirement to appoint
a compliance officer / function. The CUCC is a compliance
community whose mission to provide a support network with
compliance-specific resources to individuals involved in these
roles / functions. This in turn enables effective discharge of
prescribed functions under the legislation.
2. Compliance with the Act and Rulebook/CREDS is now well
embedded in our credit union so what can the CUCC offer to
assist with compliance with other legislation coming down the line?
The compliance universe is now much wider than core legislation
and regulatory rulebooks. The CUCC team carries out ongoing
monitoring of the regulatory and legal environment in order to
anticipate upcoming provisions and the ensuing compliance and
risk requirements for credit unions. The CUCC team is trained in
specialist areas beyond the parameters of the Act and Rulebook/
CREDS such as data protection, financial crime prevention and IT
governance and provide ongoing advice and guidance on these
3. We currently outsource our risk and compliance, what does this
mean for us?
The Compliance Advisory Service does not replace the key role of
the compliance officer within credit unions – it is to support these
professionals in their role. The CUCC already works very well
with a number of consultants working in credit unions, and will
continue to do so.
4. We currently have our own risk and compliance software, what
does this mean for us?
The Compliance Advisory Service will give access to an excellent
compliance software package at no extra cost. However, this
is just one small part of an extensive range of support services
offered by the CUCC. If your credit union wishes to remain using
another software package, it will still benefit from all of these
Risk User Groups
As part of the subscription, risk user groups are facilitated by experienced risk management practitioners. These user groups, supplemented by detailed guidance documents, will cover all steps in the risk management process for credit unions including:
- Developing a meaningful risk appetite statement
- Designing an effective risk function
- Identifying and analysing risk
- Producing a Risk Register
- Risk mitigation and testing
- Responding to risk events
Risk Management IT Software
In addition to the extensive guidance and support, subscribers will also have access to credit union-specific risk management software. This software will enable subscribers to track, analyse and report on their own risks, controls and mitigations in line with regulatory requirements. In addition to this, the software will enable the credit union to produce and maintain a detailed Risk Register to support the ongoing management of its risk portfolio.
On-going Advice and Support
The CUCC Risk Advisory Service stands out from similar services operating in the Credit Union Movement in that subscribers have on-going access to advisors who will provide practical and professional support on any aspect of the risk management system and respond to queries as they arise. This on-going phone and email support will complement the guidance documentation and risk user groups to keep the credit union’s risk function on-track.
The CUCC Risk Advisory Service will operate as a 12 month subscription service for ROI and NI credit unions, commencing in September each year. Each subscribing credit union receives a unique identification number which will give access to the service and online risk management software. Subscribers may be required to quote this number when availing of the service. The annual subscription fee is €5,400 / £3,950 excluding VAT.
- A better understanding of the internal and external environment
- A robust methodology for analysing and mitigating priority risks
- More informed decision-making both at board and management level
- On-going organisational improvement in all key areas of the business
- High quality management information to support the implementation of the strategic plan
- Satisfy regulatory requirements in the area of risk management
- More focused application of resources to the areas of the business that need it most
Want to Know More?
The CUCC team would be delighted to discuss your own risk management support needs and how the Risk Advisory Service can enhance your risk function. If you are interested in learning more about the service, please contact a member of the CUCC team to schedule a live webinar.