One side effect of the avalanche of regulatory and compliance changes all credit unions face in the last few years is member perception and reaction to such required actions by the credit union. Since we are small (fewer than 500 members and about $2 million assets) and have limited services (no member checking, for example), we can not reach “statistically significant” conclusions, but we certainly must deal with member reaction to required actions we must take.
Even though we are federally chartered, we are subject to state (Virginia) laws and regulations on “abandoned” property. Generally speaking, a savings account with no activity for over 5 years must be turned over to the state. At our recend federal examination, our examiner noted (from the data download) that a number of accounts had no activity for over five years and hot us with required action to turn these over to Virginia. How stupid and a member has to “do something” to keep Virginia from taking their money!! Since I do not want to turn over the funds, I sent letters and notices to all members with inactive accounts over 3 years to “encourage” them to “do something”. Most members are very understanding of the requirement to comply with state law. One member, however, seemed upset with me that I would even consider sending her money to the state.
The new risk based pricing notices (full page) are now required for every loan (however good the rate) that does not get the “best” rate. Another misleading and useless piece of paper for us to produce, give the member, etc.
On January 1, we were required to have new (full 8/1/2 x 11″ two sided sheet) “Privacy Notices” sent every year to every member. The old 1/4 sheets were not in compliance. Nobody reads them, but it added 17 cents (next year will be 20 cents) to many statements sent to members that had multi-page quarterly statements. In our case, the member can not “opt out” of any information sharing — but we have to send these notices.
I suspect it will get worse. Elizabeth Warren and the new CFPB will have more ideas about changing many of the regulations we must deal with.