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Cary J Anderson

In my past life as a credit union CEO I had an Enterprise Risk Management Committee (ERM) that dealt with all of the above. Anthony is correct in stating no in the credit union is outside of the compliance game. Our committee involved every department, everyone on the committee reviewed every regulation, policy and procedure because these touch everyone. A monthly report was provided to the board from the committee. We were always complimented by our NCUA examiner on how we handled compliance and he stated he wished other credit unions would establish ERM Committees. Having a compliance officer is important but they cannot know how everything works in the credit union, an ERM committee brings this insight to them.

Ray Hasson

Spot on, as usual. And, item #2, the second bullet item means, 'from outside your credit union' (And then only if you already require all managers and directors, or volunteers, to have read the Handbook). Otherwise it also should apply to anyone coming from another credit union. Many won't have read the latest (rev 2006) - which reminds me I should be checking frequently for a new update.

Thanks, Anthony. Great information.

Anthony Demangone

Thanks, guys. A good friend passed along another great rule.

Keep in mind that most regulations flow from laws. Flaws that some pin on NCUA, are actually out of their hands. Congress builds in some inflexible requirements when they pass legislation.

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