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CU PolicyPro Operations Manual Semi-Annual Release 2008.1 June/July 2008. Presenters: Veronica Madsen – General Counsel Mary Ann Koelzer – Technical Product Manager. Revised Sections. 1150 – Field of Membership
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CU PolicyPro Operations ManualSemi-Annual Release 2008.1June/July 2008 Presenters: Veronica Madsen – General Counsel Mary Ann Koelzer – Technical Product Manager
Revised Sections • 1150 – Field of Membership Policy was amended to add in verification of membership eligibility information and the “once a member, always a member” information. • 1200 – Organization Election procedure information was added along with a new key field variable. • 1210 – Compensation and Reimbursement New title: “Compensation, Reimbursement and Indemnification.” Information regarding indemnification was added. • NEW 1235 – Education & Volunteer Training Guidelines Education and training guidelines that were contained in the old “Compensation and Reimbursement” policy was made into a separate, new policy. • 1300 – Audits Policy was amended to include the specific audit requirements associated with credit union asset size. • 1615 – Privacy New definitions and the required content of both the annual privacy and opt out notices were added.
Revised Sections • 2110 – Bank Secrecy Act An additional line was added in the training subsection to reflect the training requirement for board and committee members. • 2190 – Disaster Contingency Planning Two new contingency considerations were added. • 2212 – Individual Retirement Accounts Share insurance and record retention considerations were added. • 2270 – Safe Deposit Boxes The wording of this policy was amended to reflect “must” and “will” instead of “should.” • 2280 – Share Insurance Policy was amended to include: requirements for excess share insurance; additional member education content; the official sign; and advertising rules.
Revised Sections • 2300 – Share Draft Policy Policy was renamed “Share Draft Accounts,” and a reference to the overdraft protection policy was added. • 2310 - Share Draft Telephone Inquiries (Title Updated Only) • 2400 – Funds Availability Substitute check information was added to this policy. • 2500 – Truth in Savings Additional information was included in this policy, including a new section on the advertising requirements. • 2611 – ACH Management A new subsection related to bonding was added to this policy.
Revised Sections • 4100 – General Security Procedures Information related to cash transferred by armored car, the procedures for verifying the identity of visitors and closing procedures were added to this policy. • 4120 – Information Security This policy was re-formatted to reflect the other policies in the PolicyPro Manual. Additionally, policy was amended to reflect “must” and “will” instead of “should.” • 4140 – Robbery Procedures Addition robbery recommendations were included in this policy. • NEW 4310 – Patch Management New policy was created to meet the regulator requirements for information security. • 5200 – Liquidity Management Additional information added for liability management and liquidity crisis mechanisms. • 6100 – General Investment Policy Additional information on approving issuers and non-conforming investments was added to this policy.
Revised Sections • 6110 – Broker/Dealer Relations Additional information regarding what will be examined in a broker-dealer due diligence review was added to this policy. • 6130 – Investment Controls and Monitoring Policy was amended to reflect additional information regarding the monitoring of non-security investments. • 6150 – Safekeeping of Investments A new subsection on due diligence considerations was added to this policy. • 6200 – Investment Portfolios Information regarding aggregate and individual investment type limits was added to this policy. • 6210 – Authorized Investments Additional information was added to both the authorized and unauthorized investments subsections.
Revised Sections • NEW 6220 – Non-Deposit Investment This new policy reflects NCUA Letter to Credit Unions No. 150 related to this topic was created in response to a credit union’s request. • 7120 – Fair Lending Information, including the types of discrimination, was added to this policy. • 7125 – Loan Application Additional information required by Regulation B was added to this policy. • 7130 – Loan Authorization Added footnote related to credit decisions made by credit committee • 7145 – Loan Limits Added footnotes related to loan limitations • 7140 – Loan Insurance Policy was amended to reflect the required disclosures whenever loan insurance products are advertised.
Revised Sections • 7160 – Loans to Insiders Policy was amended to define “insiders.” • 7200 – Consumer Loans Policy was amended to reference the General Lending Policy. • 7206 – Lease-Like Loans The issues pf forced-placed insurance, delinquency and repossession were added to this policy. • 7215 – Overdraft Protection (Courtesy Pay) Policy was re-written to reflect the guidance and that that this account benefit will not be advertised (requiring additional disclosures). • 7245 – Truth-In-Lending Disclosures for Closed-End Credit Policy was amended to reflect the revision to Regulation Z regarding the electronic delivery of disclosures.
Revised Sections • 7250 - Truth-In-Lending Disclosures for Open-End Credit Policy was amended to reflect the revision to Regulation Z regarding the electronic delivery of disclosures, as well as the addition of the general disclosure requirements. • 7255 – Unsecured Loans The Truth-in-Lending disclosures subsection was amended to reference both the closed-end and open-end disclosures policies. • 7310 – Construction Loans Requirements for loan approval and when draws will be disbursed was added to this policy. • 7330 – Residential Real Estate Loans Information regarding aggregate and individual investment type limits was added to this policy, as well as new secondary market standards. policyNCUA Letter to Credit Unions No. 124 guidance was added to this policy. • 7400 – Other Types of Loans Policy was amended to reflect the additional policies that were added to this section. The listing of loans on this policy was deleted and replaced by a key field for purposes of customization.
Revised Sections • 7410 – Indirect Dealer Financing Information contained in NCUA guidance was added to this policy regarding: due diligence, loan limits, loan authorization, dealer reporting information, dealer contract information and dealer controls. • 7430 – Participation Loans The documentation requirement was added to this policy. • 7510 – Collection Process The issues of the various notices, bankruptcy and legal action were added to this policy. • 9110 – Equal Credit Opportunity Act – Regulation B Additional requirements from Regulation B were added to this policy. • 9120 – Fair Debt Collection Practices Act Additional information related to obtaining the debtor’s location and the validation of debts was added to this policy.
Revised Sections • 9140 – Truth in Lending Act – Regulation Z Extensive changes were made to this policy. Additional information from Regulation Z was added. • 9150 – Unfair and Deceptive Practices – Regulation AA Policy was amended to include unfair contract provisions, unfair or deceptive practices against co-signers and unfair late charges. • 9200 – Home Mortgage Disclosure Act – Regulation C Information related to reported information and when LARs must be filed were added to this policy. • 9210 – Real Estate Settlement Procedures Act – Regulation X Extensive information was added to reflect the provisions of RESPA. • 9300 - Bank Bribery Act Amendments were made to the penalty subsection for violations of this Act.
Revised Sections • 9310 – Bank Secrecy Act Because this policy is already contained within the manual that includes all of the requirements of the BSA, this policy was deleted from the Section 9000 policies. • 9330 – Right to Financial Privacy Act Policy was amended to include additional information from this Act. • 9420 – Monetary Control Act – Regulation D Policy was amended to reflect the current asset threshold reserve and reporting qualifiers, as well as the current reserve requirements. • 9430 – Truth in Savings Act Policy was re-written to reflect NCUA Part 707 (Truth in Savings) requirements. • 9500 – Americans with Disabilities Act Policy section on employment requirements was re-written, and now includes the addition of public accommodation requirements reflecting credit union obligations to the general public.
Revised Sections • 11001 – Fair Credit Reporting Act (FACTA) Extensive amendments were made to this policy to reflect the requirements of the FACT Act. • 11002 – Furnishing Information to Credit Reporting Agencies Policy was revised to include the various reporting requirement reflected in the FACT Act. • 11004 – Pre-Screened Offers of Credit or Insurance Policy re-named to clarify that it relates to pre-screened offers. Information related to the requirements for providing pre-screened offers of credit was added to this policy. • 11005 – Adverse Action Based on Information Contained in Consumer Reports Entire policy was reorganized and additional information added. • 10006 – Receipt of Notice of Dispute of Accuracy Information Policy was re-written to reflect the credit union’s duties when a notice of dispute is received.
Revised Sections • 11011 – Disclosure of Credit Scores Policy was re-written to reflect the disclosure requirements related to home loan applications. • 11012 – Disclosure of Information to Victims of Identity Theft Policy was re-written to reflect the credit union requirements and process for disclosing transaction information alleged to be the result of an identity theft. • 11013 – Prevention of Re-Pollution of Consumer Reports Policy was re-formatted to reflect the format of the other policies in the PolicyPro Manual.
Formatting Updates • The following sections had no updates; however, the formatting of the numbering was not set up properly in the Web Master. These sections have been updated to correct the numbering/sub-numbering formatting issues. There are no Word Documents showing these changes, this is for reference only. • 2220 - E-Commerce • 2610 - Automated Clearing House Operations • 3155 - Travel Reimbursement • 6105 - FASB 115 Compliance • 7101 - Loans • 7415 - Subprime Auto Indirect Lending • 7600 - Loan Review and Classification
Updating Your Web Manual • Login to your Manual (https://ops.cucareonline.com/) • Click on Manual Builder
Updating Your Web Manual 3. Click the Open button to open your Manual
Updating Your Web Manual 4. Archive any existing sections that have been revised in the update. 5. To do this locate the desired section in the table of contents on the left side of the screen.
Updating Your Web Manual 6. Click on that section and then click on the Move to Archive button located at the bottom of the Table of Contents
Updating Your Web Manual 7. Once you have archived any desired sections you are now ready to add the new and revised sections from the Semi-Annual Update. 8. To do this click on the OPS Master manual as seen below
Updating Your Web Manual 9. Locate the desired section to add into your manual. When you click on the section and the text populates the word processor, click on the Add Selected button at the bottom of the Table of Contents
Updating Your Web Manual • The new/revised section will now be added in its entirety into your Working Manual. • There may be policies that you want to update, but you have already customized for your credit union. For these policies, you need to make a decision: • A. Use the Tracked Changes documents from the library as a guide to incorporate the new changes into your existing customized policies • B. Archive your customized policies, bring in the revised policy in its entirety, then re-customize it with your credit union information • Which way you decide will depend on how many revisions the policy has, and how much customization you have already done.
Updating Your Web Manual Questions?
Updating Your Word Manual • The Semi-Annual Updates are available to download through an online link for Word Users. • All OPS Manual – Word subscribers are sent an email with login rights and instructions to access the files. • Before updating your Operations Policy Manual in MS Word format review the Revised policies in the update. • Compare them with the existing policies in your manual. If there are any of the revised policies that you plan on updating but would like to keep the existing policy as a backup follow the directions to Archive in MS Word.
Updating Your Word Manual Directions to Archive in MS Word • Open your OPS Manual and scroll down to the section you would like to archive. • Highlight the entire section by clicking your left mouse button at the section title and dragging it all the way to the end of the section. • Once highlighted go to the Edit menu and choose Copy. • Open a new Word document by going to the File menu and choosing New. • When the new document appears go to the Edit menu and choose Paste. The section will now appear in this new document. • Go to the File menu and choose Save As. • In the Save As dialog box save the document as “Section XXXX ARCHIVE.doc” where the X’s determine the section number. Save the document in your My Documents folder. • If you need to revert to the former section for any reason you can open this file and copy the contents back into your OPS Manual.
Updating Your Word Manual • Open your Operations Manual, find the spot where you want to add the new policy, place the cursor on the last line of the page. For instance, to add new policy 6220 (Non-Deposit Investment) go to the section prior to where the new policy will reside. In this case that would be Section 6210 so place the cursor at the end of the section. Minimize the window when you have done so. Place cursor at the end of the section prior to where the update will go
Updating Your Word Manual 2. Open the new policy, place your cursor at the beginning of the policy and click CTRL+A to highlight the entire page. Once it has all been highlighted as below go to the Edit Menu and choose Copy. Minimize the window.
Updating Your Word Manual 3. Go back to your Operations Manual go and choose Paste from the Edit menu or by using the right click function. This will paste the new policy into the spot that you designated in step 1.
Updating Your Word Manual 4. Go to the beginning of the new policy, place your cursor directly above it (just above the dividing line of the title). Between the end of the old policy and the beginning of the updated or new policy
Updating Your Word Manual 5. Next, go to the Insert Menu and choose Break. In the dialog box click the radio button next to Next page under Section break types and then click the OK button. 6. This will move the new policy to a new section page.
Updating Your Word Manual 7. Go to the footer of this page by scrolling down to the end of the first page of that section. You will notice that it shows the previous section’s title and page number.
Updating Your Word Manual 8. To change this to the new section double click right on top of the footer. The header/footer toolbar will appear.
Updating Your Word Manual 9. Click on the icon in the header/footer toolbar that reads Link to Previous when you place your cursor on it. 10. Click on this icon once so that it is no longer highlighted in orange. The footer for the new/updated section is now independent of any other footers.
Updating Your Word Manual 11. Now highlight the section name in the footer 12. Type in the name of the new section. Next, go to the far right of the footer and change the section number ONLY to the new section number (do not change Page or the -1 after as the page number format does not need to change). Click the Close button on the Header and Footer toolbar when finished.
Updating Your Word Manual 13. If you are adding in additional new or revised sections into your manual just follow the above steps. Once you have made all your changes, save the manual.
Updating Your Word Manual Questions?
Thank You for Attending Our Webinar If you have any questions regarding the information that was presented today please feel free to contact us. Veronica Madsen (800) 262-6285, x461 vam@mcul.org Mary Ann Koelzer (800) 262-6285, x581 mek@mcul.org Jeremy Rundell (800) 262-6285, x586 jjr@mcul.org