About Compliance

CUCC is a central compliance point of contact for credit unions. There are increasingly onerous requirements on credit union boards to demonstrate compliance, satisfy regulatory obligations and keep up-to-date with continual regulatory changes.

Having the right tools on hand can help reduce the burden many boards and consequently compliance officers are facing.

The CUCC supports and provides credit unions with the tools necessary to meet their compliance obligations under the Credit Union Act, 1997 (as amended), PRA/FCA requirements and all other financial services legislation and supports credit union compliance officers in managing regulatory change and reducing the risk of non-compliance

The CUCC is an on-going subscription service which provides numerous supports to those officers responsible for compliance within the credit union.

These supports are provided by a team that not only has a strong legal and compliance background, but also extensive experience of working with credit union officers and voluntary assistants.

This unique blend of compliance knowledge and credit union know-how makes the new service a must have for credit union compliance officers and ensures the guidance and support provided to subscribing credit unions is professional, tailored and practical.

The Credit Union Compliance Centre is an annual subscription service for credit unions in Northern Ireland and the Republic of Ireland.

This service will support the compliance function, however it will not supplant compliance roles within the credit union. The annual subscription fee is €2,400 / £1,800 (plus VAT at 23%) which provides access to all CUCC services.

Benefits to subscribing credit unions include:

Access to all resources on www.cucc.ie
Free attendance at the quarterly Compliance Working Groups (four per annum in both the ROI and NI)
On-going advice and support from credit union compliance advisors
Access to compliance templates, guidelines and briefing documents
Monthly compliance updates
Guidance on the compliance statement (ROI)

Subscribing to the CUCC couldn’t be easier, just follow these four simple steps:

Email compliance@creditunion.ie to register your interest on behalf of the credit union.
A letter of engagement with attached terms of business will be sent to the Honorary Secretary to be signed by the Chair of the Board or other authorised officer.
Once the signed letter is returned, you will be asked to nominate a primary and secondary contact person.
The primary contact person will be issued with a unique identifier (username) and password – your credit union can now access the CUCC service.

Name	Role	Email
Joan Guy	Compliance Advisor	jguy@creditunion.ie
Nicky Langton	Head of Risk & Compliance	nlangton@creditunion.ie

Factor	Description	Ranking
Competition in Financial Services	Short-term One of Ireland’s pillar banks have publicly indicated that they are actively pursuing the credit union unsecured personal loan market. The recent activity in the mortgage market can result in members forming long-term relationship with their banks. There is also evidence that Banks are focused on improving their CRM approaches. The pillar banks have the resources to ensure quick loan decision turnaround times in addition to competitive interest rates. There is evidence of significant investment by banks in high-convenience service delivery and better relationship management for customers. Introduction of new competition in the unsecured lending market in the form of PCP from car manufacturers / dealerships and direct-to-SME lenders should be considered although credit unions are making good comparisons recently between credit union loans and PCP finance from car brands. Slower growth of credit union loan-books relative to average growth within the ROI financial services sector is an indicator of the new competitive environment.	4 –
Competition in Financial Services	Long-term The same long term challenges that were present in Q4 2016 remain in Q1 217. The introduction of more Fin Tech companies into the financial services market will result in increased competition in the lending and secondary financial services market for credit unions. High-tech, low-cost base and strategically agile – Fin Tech companies could pose stiff competition to traditional financial services institutions. Advancements in technology and changes in EU policy may open up the ROI financial services market to non-domestic based financial service providers. Current and potential members who have established long-term borrowing relationships with their banks (driven by effective relationship management and key product availability) will be difficult to bring back to the credit union.	4 –

Factor	Description	Ranking
Social changes & consumer preferences	Short-term As previously indicated, millennials & generation Y present a key challenge for credit unions in how to become relevant to these consumer segments by delivering suitable products and services. The credit union strategy should consider the investment the main banks have undertaken and are continuing to undertake in developing their communication/advertisement channels on social media and also in their development of internet based loan application processes.	9 –
Social changes & consumer preferences	Long-term Millennials and generation Y have arrived as the core borrowing demographic of credit unions. Credit unions must attract this segment in delivering basic, convenient suitable products and services. This is a business priority in many credit unions. Failure to capture significant market share within these demographics will be harshly felt in credit unions finance in the long-term.	9 –

Factor	Description	Ranking
Media coverage & public sentiment	Short-term Credit unions continue to benefit from negative public sentiment towards the banking sector, i.e. the CBI tracker mortgage rate examination. Public view of credit unions as trusted and people-oriented financial service providers continues evidenced by increased savings figures. Recent negative media coverage relating to credit unions (CBI F&P report, AML sanctions) has dented an otherwise positive public sentiment towards credit unions.	6 –
Media coverage & public sentiment	Long-term If more frequent negative press arises, due to the emergence of further compliance, viability and/or governance issues within credit unions, it could sway current public opinion as trusted financial institutions.	6 –

Factor	Description	Ranking
Credit Union Mergers and the Common Bond	Short-term Same concerns as Q4 2016 remain in that mergers across the sector are opening up a wider range of strategic options available to credit unions due to increased scale. Registrar has indicated that expected cost savings and economies of scale have yet to materialise in some post-merged credit unions. Urbanisation impacting on rural common bonds means some credit unions are losing-out on potential members. Credit unions may find opportunities to expand into under-serviced common bonds through the merger process.	5 –
Credit Union Mergers and the Common Bond	Long-term Smaller standalone credit unions may find themselves at a competitive disadvantage if operating a common bond over-lapping with larger neighbouring credit unions created through the merger process. Where credit union members satisfy multiple common bonds, high-calibre potential borrowers are likely to gravitate to the larger credit unions with a wider range of services, higher levels of convenience and more competitive rates. Pressure to re-define the concept of the common bond may intensify as the expanding geographical / industrial reach of credit unions test the viability of the common bond in its current form.	5 –

Factor	Description	Ranking
Interest Rates	Short-term With interest rates likely to remain low in the short term, investments returns remain difficult in turn impacting on credit union income. There is also a possibility that even negative interest rates may be charged on credit union deposits. Bank of Ireland since October 2016, have been charging a negative interest rate of -0.1 % on large corporate and institutional customers for deposits of €10 million or more. Indications are that AIB will shortly follow suit. Credit union investment income is down 20% in 2016 when compared with 2015. The low interest rates on investments in conjunction with a declining loan to asset ratio represents a significant challenge to the future operating model of credit unions.	2 –
Interest Rates	Long-term Indications are that ECB interest rates will begin to rise in Q4 2019. While this will be encouraging for investment returns, it may bring other challenges especially when other financial institutions begin increasing mortgage interest rates. This could reduce consumer confidence and in turn affect consumer spending. It could also affect loan repayment capacity. However the impact of low interest rates on the credit union operating model needs to be considered into the long term. Without the development of products and services, credit unions are unlikely to develop sufficiently to ensure a sustainable business model into the future	2 –

Factor	Description	Ranking
Financial Services Information Technology	Short-term This continues to remain an ongoing short term priority for credit unions prioritising the enhancement of its IT capabilities in areas such as payment services, debit cards, online services, e-signatures, internal analytics and operations systems. Data fraud or theft and cyber-attacks ranked number five and six in the top ten global risks in terms of likelihood of occurrence in the World Economic Forum’s 2017 Global Risks Report. According to a PWC survey, there were more instances of cybercrime in Ireland in 2016 (44%) compared to the global average (32%). The capital and operating costs of certain technologies are high and therefore the business case for investment requires ongoing careful consideration. For credit unions not investing in enhancing IT capabilities – exposure to cyber-attacks is lower, but vigilance should be maintained with special attention given to addressing the risks of aging IT infrastructure. Credit unions should reference the IT Risk Management & Cybersecurity for Financial Institutions guidelines issued by CBI for expectations in this area.	1 –
Financial Services Information Technology	Long-term The CBI through their supervisory work state that firms have insufficient awareness, understanding and prioritisation of IT and cybersecurity risks. IT systems and controls are not sufficiently robust and firms are not doing enough to minimise the potential impact of an IT failure or successful cyber-attack on their business. Less than half of Boards (41%) are requesting information on the cyber readiness of their organisation in spite to the fact that cybercrime is perceived as the highest risk to Irish businesses in the next 2 years (PWC survey). Due to limited resources, insufficient scale and restrictions within the business model – credit unions are at risk of falling further behind relative to competing banks and other financial institutions in the development of their IT capabilities to support their business model. Banks are continuing to invest in new technologies and improve existing infrastructure and they have the resources to do so. This continues to give these firms a significant edge over smaller competitors. For those credit unions not investing in enhancing their IT capabilities – the long-term future of their business model is more uncertain.	1 –