Anthony Demangone of NAFCU: The 7 Deadly Questions

Anthony Demangone is the Director of Regulatory Compliance at NAFCU. You can read his thoughts on regulation, compliance, NAFCU and CUs at large over at the NAFCU Compliance Blog, and you can regularly hear him talk about current issues in credit unions over at...well, the Current Issues in Credit Unions podcast over at That Credit Union Blog. 

Recently, Anthony wrote an interesting article for NAFCU's magazine, The Federal Credit Union. I want every one of our regular readers to pop over to Anthony's blog and read the article in full. It's great food for thought and comes with this disclaimer: 

Editor's note: This has been a tough stretch for credit union compliance officers. Regulation Z, HVCC, the CARD Act, the FACT Act, Truth in Savings, Regulation E, MDIA, and HOEPA have all ganged up to throw myriads of new requirements at credit unions. If you want to get the most out of your compliance officers and preserve their sanity, please pass this article around to your non-compliance staff.

Please, give the article a read and let Anthony know what you think. We'll take your comments, too, if you prefer. 

Compliance officers get questions.  That is a fact of life.  We get big questions and small ones.  Complicated questions, and simple ones.  Some questions, though, give us heartburn.  These questions cause us to close our door and bang our head against the wall.  

In a perfect world, these questions wouldn’t exist. The world, however, is not perfect.  We know that.  All compliance officers want is to hold these questions to a minimum.

The following list shows what to avoid when asking a compliance officer a question.  Whenever possible.  When that is not possible, go ahead and ask. But come bearing gifts.  Or antacid.

1. "I heard it from a friend who heard it from a friend…" questions.  These questions often start with the phrase, “I was at a conference, and I heard that we have to do (insert issue).”  Ah, the wild goose chase.  Compliance officers do appreciate it when other credit union employees come to them with new compliance information...

2. Last-minute contract reviews. Often, these questions look like the following: Can you look at this contract?  We need to have it signed today, and we want to make sure that everything is OK...

3. Oversimplifying questions.  Some questions might seem simple, such as this one: What disclosures do we need to have on this (insert document, such as periodic statement, late notice, etc.)? That question is not simple.  It is fairly complicated. What makes this question so troublesome is that the answer turns on many, many variables...

4. Conference call questions.  (The phone rings in a compliance officer’s office.)  Hello. We’re in the middle of a meeting, and a question has come up regarding the Home Valuation Code of Conduct.  Can we do (insert question)? Don’t worry…we’ll stay on the line and wait for your answer...

5. Open-ended questions. These questions might look like this one: What do we need to know about this (insert subject)?...

6. The “onion” question.  I call this type of question the onion, because it involves layers.  A compliance officer gets a question, and they answer it.  But then the person comes back with additional details...

7. The “sneaky” question.  Often, credit union employees have disagreements concerning whether some action is permissible.  Sometimes, one of the employees involved in the disagreement will try to use a compliance offer to buttress his or her argument...

Click here to visit the NAFCU Compliance Blog and read the full article!