A Special Member "Thank You"
We received a call a few weeks ago from a NAFCU member.Â Â Here's what happened.
A credit union member sent a loan officer a holiday card with $100 in it.Â It seems the loan officer went our of his or her way to help the member through a loan application process.Â The loan had already been granted, so it doesn't appear that the motive was bribery.Â Did the situation raise red flags?Â You bet.
First, with certain exceptions, no credit union employee may receive, directly or indirectly, any commission, fee or income in connection with any loan made by the credit union.Â 12 C.F.R. 701.21(c)(8)(i).Â Even if this had not been in the context of a loan, the gift certainly raises Bank Bribery Law concerns.
Here is IRPS 87-1, NCUA's guidelines for compliance with the Bank Bribery Law.Â
Luckily, the credit union employee in question reported the gift to his or her supervisor, and the money was returned.Â I wonder how often this sort of thing happens.Â Here are some other thoughts:
- What if the gift were $5?Â Or $10?Â Or a $10 gift certificate to Subway?Â (Eat fresh.)
- What if it were a box of homemade chocolate chip cookies?
- What if the gift were a box of gourmet, store-bought chocolate chip cookies, with a retail value of $50.00?
- What if the member purchased a $100 fruit basket for one employee?Â Or one division?Â Or for the entire credit union to share?
Great.Â Now I'm hungry.