By helping reevaluate the rules, the regulatory experts at your CU can open entirely new pathways for entirely new members.
COVID-19 made life extraordinarily difficult for a lot of people in ways they never anticipated. Adults that had never experienced a job loss, an inability to pay their bills, even homelessness or food insecurity, found themselves navigating unfamiliar financial territory. Many are still very much in the throes of their struggles and searching for support and resources.
Credit unions were built to offer hope in exactly these circumstances—to give their neighbors, all of whom were traditionally excluded from banking services, a safe, trustworthy way to access financial resources—especially during times of economic downturn.
That said, credit unions must also keep themselves out of financial trouble. Doing so requires them to adhere to a set of rules and regulations. It’s a rigorous, complex process made possible by the establishment of policies and procedures that leaders can train staff to follow. The trouble with many of these policies and procedures is they are built to address the mainstream, the traditional, the usual.
But, if we learned anything in 2020, it’s how quickly the usual can change.
Reevaluating the Rules
As the industry confronts a new normal in which members’ needs—and members themselves—begin to look different, compliance and risk leaders have a sizable opportunity to contribute. That’s because they are the chief owners of policies and procedures, not to mention the resident experts on all things regulatory in nature. By helping colleagues reevaluate the rules they’ve been following, compliance and risk leaders can open up entirely new pathways for entirely new members.
This is particularly true for consumers struggling with pandemic-related impacts that have pushed them out of mainstream financial services.
Expanding What’s Permissible One Policy at a Time
Take an individual who is experiencing homelessness, for example. Especially as economic forecasters warn of a foreclosures wave due to the pandemic’s impact on jobs, this is a circumstance that credit unions must be prepared for. Account opening procedures mandate that a credit union collect a physical address, which could be difficult for a prospective member experiencing homelessness to provide. Compliance and risk pros can review existing polices to be sure they encompass the full scope of permissible physical addresses. For instance, Title 31 Chapter X concerning customer identification programs states that an address must be collected. However, the regulation also allows for individuals without an address to provide one belonging to next of kin or of another contact individual.
Acceptable ability-to-pay documentation is yet another area compliance and risk leaders can help credit unions adapt for a broader range of assistance to a broader group of people. Methods and technology for evaluating creditworthiness are evolving, and plenty of alternative providers are taking advantage of them to prey on desperate people turned away by banks. With guidance and support from compliance and risk colleagues, credit union lenders and their teams can use the same strategy, except for good.
Members who are not U.S. citizens are another group of people in great need of financial assistance and guidance as the nation moves toward COVID-19 recovery. Many were left out of the stimulus package relief because of the lack of a Social Security number. Higher degrees of poverty and a higher level of employment in jobs that can’t be done remotely has put immigrants and their families at higher financial (and health) risk during the pandemic.
Compliance and risk pros can reevaluate policies and procedures to ensure identification forms other than a Social Security number are not only allowed but welcomed. A major part of executing an inclusive approach is going beyond acceptance to enthusiasm. If credit union staff are familiar with and comfortable checking international passports, ITINs or Matrícula Consular ID cards, for example, they are much more likely to nurture a welcoming atmosphere for people who want to join the cooperative.
Reengineering Escalation for a Better New Member Experience
Speaking of a welcoming atmosphere, compliance and risk leaders can have an impact in this area by helping design an escalation process that feels smooth and hospitable. When frontline staff understand what to do and to whom to go when they are presented with an unfamiliar form of identification, the prospective member feels accommodated and accepted. Particularly in underserved, close-knit communities, that kind of experience can kick off a highly successful word-of-mouth campaign that brings many new members to the credit union’s doorstep.
Involving Compliance and Risk Early On
Change is hard for many people, and it can be even harder when hindered by fear of running afoul of the law. This is where experts in regulatory compliance can step in. For those leaders to have the greatest impact, however, they should be involved in strategic discussions around growth and evolution as early as possible. It’s not uncommon for a credit union to build a financial inclusion plan without the upfront input of their compliance and risk folks. This, unfortunately, perpetuates a misguided stereotype compliance pros continuously battle—that they lead the “No” department. Getting these folks involved from the outset ensures financial inclusion programs are in alignment with the credit union’s regulatory obligations and strategic compliance aspirations.
Keep in mind, too, that compliance and risk leaders can serve as influential champions of inclusion. Because they touch so many areas of a credit union’s operations, they typically have a large internal network. Allowing them to be a part of developing a financial inclusion strategy and associated program may mean more team members see the value of the initiative and get involved to an even greater degree than expected.
Erin O’Hern is VP/strategic initiatives for PolicyWorks, W. Des Moines, Iowa, a governance, risk and compliance consultant credit union service organization. Kenia Calderón Cerón is client relations director for Coopera, W. Des Moines, Iowa, which helps credit unions better reach and serve the Hispanic market.