ComplySight
Newsletter

In this Issue:

Introduction

ComplySight System Enhancements

ComplySight Training Resources

Contact Us

Closing Comments from Glory

Introduction

You should have received a Regulatory Alert on Friday, September 7! Here is some more detail on the interpretation.

HMDA Changes resulting from S.2155

On August 31, 2018, the Bureau of Consumer Financial Protection (BCFP or CFPB) issued an interpretive and procedural rule to amend certain provisions of the Home Mortgage Disclosure Act (HMDA) impacted by the passage of S. 2155 (Economic Growth, Regulatory Relief, and Consumer Protection Act). The “interpretive and procedural rule” among a few other things, clarifies the amended data points that credit unions will be required to report if they qualify for the partial exemption. In order to qualify for the “partial exemption” for reporting covered “open-end” loans, the credit union must have originated less than 500 “covered” open-end loans in each of the two preceding calendar years. In order to qualify for the partial exemption for “closed-end” covered loans, the credit union must have originated less than 500 “covered” closed-end loans in each of the two preceding calendar years.

However, some of you may be asking yourself, “wait a minute, I thought that I didn’t have to report any data on open-end covered loans if my credit union originated fewer than 500 in the two preceding calendar years.” You are right! Credit unions should keep in mind that the changes resulting from S. 2155 did not adjust the definition of a financial institution under HMDA. Therefore, credit unions that currently originated less than 500 open-end “covered” loans in each of the two preceding calendar years, are not required to report ANY data under the existing definition. Where credit unions will see the regulatory relief is if they originate more than 25, but less than 500 “covered” closed-end loans. Those credit unions will qualify for the partial exemption and will only need to report on twenty-two data points.

Credit unions that qualify for the partial exemption are only required to report on the twenty-two data points that are listed in the “Unchanged by the Act” column in the picture outlined below.

One other change to note is that credit unions are required to provide (through the Loan Application Register) information so that each loan and application they report is identifiable. Under the “old” rules, this was done using a Universal Loan Identifier (ULI). While, the ULI is not a required data point to be reported if the credit union is eligible for the partial exemption, the credit union does have the option of reporting it anyway. Otherwise, the credit union can use a “non-universal loan identifier.” The requirements in the procedural rule indicate that the non-universal loan identifier:

• May be composed of up to 22 characters;
• May be letters, numerals, or a combination of both;
• Must be unique within the credit union; and
• Must not include any information that could be used to directly identify the applicant or the borrower.

The credit union must only assign one non-universal loan identifier to a covered loan or application and may not use a non-universal loan identifier previously reported if the credit union reinstates or reconsiders an application that was reported in a prior calendar year.

 

ComplySight System  Enhancements

We have more exiting changes to announce!

Examiner/Audit Finding Updates

We listened to your feedback and have made a number of changes to the Examiner/Audit Findings!

Some additional fields have been added to the Examiner/Audit Finding (EAF) form when creating an EAF. The new fields are optional and include Audit/Examination Date, Review Type (users can choose from Federal Exam, State Exam, Internal Audit, External Audit and Other) and Review Results (users can choose from Finding, Recommendation, No Finding or Recommendation, Document of Resolution, or Other).

We have also expanded the rights of L3 users to delete any EAF they have created. In the past, EAFs could only be deleted by an L2 or L2.5 user.

Please Note: Because information regarding who created an EAF was not captured previously, L3 users will only be able to delete EAFs created on or after September 10, 2018.

Examiner/Audit Finding and Action Item Updates

Information has been added to the Examiner/Audit Finding and Action Item (AI) to show who created each Item and the date of creation, who resolved each Item and the date it was resolved. Many users have told us this would be helpful information, especially for Items that are assigned to multiple people or have multiple changes made to a particular Item. The “created” and “resolved” information is found on the Action Item/Manual Action Item (AI/MAI) and Examiner/Audit Finding Lists, and within each individual Item as well.

Please Note: The Created By and Resolved By information will only show on items created or resolved on or after September 10, 2018. Because that information was not captured in the past, it is not available on items created or resolved prior to this update.

Indicator Buttons are now Linked on Factor Selection Screen

When selecting the Factors for Grading, the Factor Selection Screen will indicate which Factors have open Action Items or Examiner Audit Findings (EAFs). We have had many requests to make these indicator buttons interactive – and now they are! If you click on an “In-Progress” Action Item, Manual Action Item (MAI) or EAF button, you will be taken directly to that Item (or to the AI/MAI or EAF list if there is more than one active AI/MAI or EAF for that Factor).

Compliance Status Report Updates

The Compliance Status Report layout has been updated to be more readable and user-friendly.

The Overall Compliance Grade graphic is now centered on the page, with Comments underneath, followed by the graphic of the Compliance Grades By Area. Beneath that would be any comments for specific Areas added by the user.

ComplySight Training Resources

Video Tutorials

Log in to ComplySight and click on the “Training and Support” link in the left navigation menu to access video training tutorials to make your ComplySight experience even better! These are also available 24/7!

Contact Us

Technical questions (software operation issues) can be submitted through the Technical Support form in ComplySight.

Compliance-related questions can be submitted through the Compliance Questions form in ComplySight.

For other questions: click here

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Closing Comments from Glory

We wanted to take this opportunity to thank all of you who completed our League InfoSight user survey! We take these results very seriously and they help us prioritize future developments! Here is a brief summary of some of the results related to ComplySight.

1. Awareness. I know, we’re preaching to the choir – you all receive our newsletter and are aware of ComplySight, however, we always have so many people indicate that they are not familiar with ComplySight and what it is. Please, help us spread the news! If you hear another credit union looking for a cost-effective compliance management system, let them know we are a perfect option.

2. Don’t have time to implement/use the system. I found a quote that holds true for ComplySight, “the harder you work for something, the greater you will feel when you achieve it.” Yes, I’m not going to pretend that getting ComplySight fully graded is an easy task that doesn’t take a lot of time. What I will tell you, just like any system, doing that heavy lifting WILL help you save time in the long run. Don’t forget, you don’t have to complete the grading of every single Factor in a few months. It might take the credit union a year or even two to get the system fully graded. However, once that process is done, the credit union can focus on high risk areas, areas that need improvement, and/or schedule a review cycle that is more manageable to maintain.

Also, since I’m on a roll with quotes, as Steve Jobs says “great things in business are never done by one person. They’re done by a team of people.” Leverage ComplySight to assign tasks and reviews and make implementation of the system a team effort; you will get more buy-in and will be able to accomplish more.

3. Our credit union isn’t large enough to use the system. We know that ComplySight has a lot of content and it can be overwhelming for credit unions (the largest asset size and smallest). The difficult part is that most of the regulations contained in ComplySight require compliance from credit unions of all asset sizes (depending of course on product offerings). As a small asset size credit union, we wouldn’t expect you to devote the same amount of human resources to implementing the system as a larger asset size credit union, so your implementation time may take longer, however your compliance with regulations is just as important. We would argue that ComplySight is a system that is most helpful for smaller credit unions that may lack a compliance department (or individual expert) and have limited time to research compliance issues. ComplySight can be set up to allow all employees access and provide them with a system where they can learn information about a particular regulation by topic, along with all the associated League InfoSight resources (InfoSight and CU PolicyPro), in one location.

4. More training and webinars. Yes, we agree! We are starting up our live webinars again. We also completely revised our “Training and Support” options within ComplySight. Now webinars are available to walk users through multiple functions within ComplySight that coincide with our ComplySight User Guide! What else would be helpful?

5. Always evolving. We also received comments on a few issues that users thought would help them to better engage with the product. A few comments were related to enhancing the functionality for the Examiner Audit Findings, which we were already in the process of developing! Additional suggestions included the ability to create customized reports, making the system easier to use, better navigation, easier to find information and a more streamlined process to show a review has been completed.

We’re in the process of brainstorming our next priorities with these in mind. We agree with our commenters and are looking at ways to make the system easier to use, like a wizard to walk credit unions through certain activities (set up, factor grading, adding employees, etc.). We agree that providing step-by-step instructions through the system (like Turbo Tax) would be helpful. Also a Report Wizard that allows users to customize their own reports continues to be one of our priorities and we continue to scope out that functionality with our developers. We’re also looking at all of the other suggestions and how we can implement those changes to assist our users.

What other ideas do you have? Please share with us!! You know we love your feedback!

Thanks again for all of your support!

Glory

Glory LeDu, CUCE, BSACS, CUERME

Glory.LeDu@LeagueInfoSight.com

ComplySight is a product of League InfoSight, CUNA and your State Association or League.

Check with your League/Association for information regarding availability in your state.