A credit union lacked documented Consumer Protection Regulatory Policies and Procedures and anticipated coming under CFPB supervision in two years.
Developed 14 Consumer Protection Regulatory Policies and 229 Operating Procedures across 10 lines of business.
- Established policies, accessible to all staff, that detail the credit union’s commitment to regulatory adherence, to meet CFPB expectations for policy documentation
- Enhanced business line processes to ensure full coverage of regulatory considerations, and controls to validate the process is being followed – demonstrating adherence to regulators
- Implemented a formal, systemic Change Control process to ensure that procedures are not modified without approval, and that all staff operates on current versions
The client, a mid-size credit union, was seeking to document their Consumer Protection Regulatory Policies and Procedures in advance of crossing the $10 billion assets threshold for CFPB supervision.
Bridgeforce partnered with the client to identify 14 Consumer Regulatory Protection Policies that did not exist or required significant enhancement. All required policies were designed and drafted by Bridgeforce and approved by the Board of Directors.
In parallel, Bridgeforce partnered with the business lines we identified as having the most consumer regulatory risk. With each business line, we developed an outline of the required operating procedures. 229 operating procedures were drafted and approved through a formalized process.
A documented Change Control process was instituted to manage updates to procedures in the future.