Your credit union has a tool to calculate what regulatory burden costs your credit union - effectively its members - by assessing the time and expenses involved in regulatory compliance. With data in hand, you can illustrate for policymakers the need to curb the regulatory overreach that's come under increased scrutiny.
What the calculator does
The cost calculator, developed by the Credit Union National Association (CUNA) and Cornerstone Advisors, is a spreadsheet with tabs for:
To complete it, you'll need to collect general information about the credit union, and ask employees in multiple areas of your credit union's operations to estimate:
- The percentage of employees' time spent on tasks tied directly to regulations
- The percentage of third parties' time spent on regulatory-related tasks
Since some regulations affect multiple areas of the credit union, the spreadsheet captures data across a wide array of operations.
Data tallying & comparison
The spreadsheet uses your estimates to calculate the total expense. In addition to dollar values, regulatory costs are shown as a percent of assets and compared to data from a credit union peer group from the formal study that tallied state and national estimates of regulatory costs. For example, the total regulatory staff time for an individual credit union may represent 20% of the total full-time equivalent (FTE) time in the organization compared to 17% for peers.
What costs are calculated
The calculator tallies regulatory costs across four key areas of operations:
Analyzes compliance, internal auditing, BSA, enterprise risk management and vendor management and, in part, evaluates time spent on:
- monitoring regulations
- policy and procedure updates
- compliance reviews
- governance and processes deemed good business practices
- implementation and management of software
- vendor reviews
Analyzes origination and servicing for mortgage, consumer and business loans and collection activity, and, in part, evaluates time spent on:
- app/loan file reviews
- HMDA reporting
- certain appraisals required by regulation
- flood insurance requirements
- credit reporting reviews
- CARD Act compliance
- loan modification reviews
Analyzes branch operations, retail administration, call center and deposit operations, and, in part, evaluates time spent on:
- BSA/AML processes, including CTRs
- Customer Identification Program (CIP) processes
- policy/procedure updates
- internal help desk and administration of branch policies/procedures
- project management dedicated to member services
- time explaining or disclosing regulatory requirements (Reg. D transfer limits, etc.)
- tax reporting 1099s, etc.
- regulatory compliance reviews
- research for regulatory requests
Analyzes finance & accounting, IT, legal and HR functions, and, in part, evaluates time spent on:
- regulatory reporting (includes call reporting
- recently imposed stress testing
- reports or analysis required by examiners beyond normal business practices
- core and other application updates related to tax and other regulatory changes
- regulatory/compliance reviews (disclosures, member communications)
- regulatory disputes and interactions
- ACA compliance
- Department of Labor compliance including reporting
- compliance training (development & delivery)
Where to find the calculator
The calculator and its usage guide are on CUNA's Regulatory Burden Study page.
The League encourages credit unions to participate in our ongoing regulatory advocacy to improve their operating environment and member servcice.
Contact Paul Guttormsson, League VP - Regulatory & Compliance.
Wisconsin credit unions come together as a single League to Unite for Good; we remove barriers, increase awareness and foster service excellence. All of these steps help more Americans to see credit unions as their best financial partner and regard their credit union as their primary financial institution. Read more articles in our Unite for Good series.