Compliance Blog

Oct 10, 2008

What's In Your Agreement?; Roundtable

I have a homework assignment for you.  Go down to your branch, and ask for a new account packet.  This will contain all the information your members get when they open an account.  There will be pretty brochures, fee schedules, and an account agreement.

Read it all.

Once you read it, think back (and discuss with others) about times a given situation was not addressed in the agreement.  Here are two examples:

  1. Limitation of service policies.  These policies allow the credit union to limit services for abusive members or those who cause the credit union a loss.
  2. Right to refuse a deposit.  Can your credit union refuse a transaction?  I think you can, but it may be nice to spell that out.

How or whether you amend your agreement is a business decision.  It never hurts to have an attorney look over it.  And it would help if that attorney knows what she or he is doing.  And one last idea: there should be a master copy of agreements.  If possible, you should note why you include a particular paragraph, and what you are trying to achieve.  Word and other word processing programs usually allow you to add notes.  Such notes make it much easier for the next person to pick up where you left off.  A sample note might say:

Limitation of services clause added 10/9/08 by A.Demangone. Authority for this change: NCUA legal opinion letter 08-xxxx. Our goal is to limit services to members who verbally abuse tellers or who cause the credit union a loss.

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I'm at a compliance roundtable today.  For those who want to see what goes on in such meetings, check out the agenda here.

Have a great weekend, everyone!  (That does not go for the Badgers.)