Compliance Blog

First of all, it feels like a Monday.  But in fact, it is Wednesday.  Ah, the Compliance Guy loves a day off in the middle of the week.    Thanks to all you Veterans for all that you have done!

To be honest, I'm crafting this late Tuesday evening because I forgot to pen a posting before I left the office on Monday.  I looked through our Book of Answers for a good gem, and I found this classic answer to a wild goose chase.

Question: Our FBI decal (stating that the Federal Bureau of Investigation has jurisdiction to investigate felonies committed against a federally insured credit union) is non-existent or needs to be replaced. Are we required to have one?

Answer:  No. In July of 1981, NCUA proposed a revision of part 748 of NCUA's Rules and Regulations, which would have inserted, among other things, § 748.1(a)(3), under the heading "Security devices and procedures": "A decal will be displayed in a conspicuous place which states [the FBI's jurisdiction], unless the credit union's board of directors determines that display of the decal would identify a credit union office which otherwise is undistinguished from its surroundings." 46 Fed. Reg. 38527. In April of 1982, the NCUA board, "[u]pon further analysis of the proposed rule… decided that § 748.1 could be deleted from the final rule without jeopardizing credit union safety and soundness," with the stated reason that the "NCUA Board believes that credit unions; [sic] boards of directors are in the best position to decide the minimum security devices and procedures necessary for their credit unions," noting that two out of the three commentors that addressed the section favored its elimination. 47 Fed. Reg. 17980. Thus, the proposed § 748.2 became what is now the current § 748.1, "Filing of reports." The optional FBI decals, however, are still available from NCUA, and instructions for ordering them are located at: www.ncua.gov/Publications/pub_avail/pub_avail.pdf.

Now, does it hurt to have that decal?  Certainly not.  I've watched enough movies and television crime dramas to know that you don't want the F.B.I. after you.  I suggest that you print this out and carry it with you.  And when someone asks about the decal, you can drop this information on them. Be sure to move away quickly before they can ask you how you knew this. 

Always cloak your compliance skills in mystery.