April 12, 2019

Compliance blogs address consumer complaints, vendor management risks

computer compliance coffeeIn the latest Compliance Blog posts, NAFCU's Shari Pogach and Elizabeth LaBerge take deep dives into the CFPB's recently released consumer complaint report and the NCUA's vendor management expectations.

Pogach, NAFCU's regulatory paralegal, breaks down the CFPB Consumer Response Annual Report and outlines key trends within the top reported complaints.

According to the report's findings, credit or consumer reporting, debt collection, mortgage, credit cards and checking or savings were the most complained about issues, comprising approximately 89 percent of all complaints received by the bureau. Although the CFPB only handles complaints for financial institutions with more than $10 billion in assets, Pogach notes that the report is still helpful for smaller credit unions to monitor the financial issues that consumers are concerned about.

In response to an increase in reports that NCUA examiners are paying special attention to vendor management and outsourcing processes, LaBerge, NAFCU's senior regulatory compliance counsel, highlights guidelines from the NCUA's 2007 letter to credit unions.

In the letter, which LaBerge outlines in her blog, the NCUA identifies out three major concepts to address when evaluating third-party arrangements:

  • risk assessment and planning;

  • due diligence; and

  • risk management.

LaBerge notes that the FDIC has also been looking into vendor management issues. For more resources on developing a vendor management program without exposing a credit union to unnecessary compliance risks revisit this NAFCU Compliance Monitor detailing NCUA expectations.

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