8SHARESShareShareSharePrintMailGooglePinterestDiggRedditStumbleuponDeliciousBufferTumblr,Mike Tanner Mike Tanner is director of card compliance for PolicyWorks. As such, Mike is responsible for advising on various compliance concerns related to card products offered by PolicyWorks clients. His diverse … Web: www.policyworksllc.com Details While the term may suggest otherwise, variable-rate loans have been far from variable for nearly a decade. Month after month, year after year, variable rates remained unchanged – until December 2015, that is.For the first time in eight years, the Federal Reserve made the decision to increase the Fed funding rate at the end of 2015. The increase resulted in an upped prime rate, an index commonly used to determine the rate on a range of variable-rate loans, from home equity lines to credit cards.I imagine alarms bells and sirens sounded at lenders across the nation when the Fed made their announcement back in December. Why wouldn’t they? With so much time between rate changes, the event likely triggered a great deal of questions from lending staff who had never dealt with the like.By now, lenders – both novice and tenured – have survived the first rate change. However, the recent hike is just the first of what is predicted to be several changes to the prime rate in the coming months and years.The past eight years of rate stability were far from normal. Historically, the prime rate has not been consistent. If you look at the 10 years prior to December 2008, you get a clear picture of the fluctuation. During that particular decade, the prime rate changed 46 times. In 2001 alone, it changed 11 times. Go back even farther in time, and the peaks and valleys of the prime rate graph look like the Rocky Mountains.With history as a reference, it’s clear rate changes will occur more frequently in the future. How can your credit union prepare? Four critical areas of focus should be reviewed immediately: Procedures, marketing materials, UDAAP concerns and training.First, review your procedures to ensure you have a good process for managing future rate changes. There are quite a few details that, if overlooked, could leave you out of compliance and generate exam findings.Second, review any and everything you put in front of a member to understand whether or not it includes a rate. This may include advertising, disclosures, web banners, websites, signs, pamphlets and/or billboards. Regulations do give some leeway to update rates after a change. However, they are short-lived and vary based on the item and how it is delivered.Another area of focus for your credit union involves Unfair, Deceptive or Abuse act or Practices (UDAAP). Is your cooperative changing rates in a timely and consistent manner? An example of a practice that could raise the eyebrows of regulators is rate increases implemented in shorter timeframes than rate decreases. Consistency is the key to ensuring you are treating members fairly.Training is another area of focus. Are all staff members who will be answering member questions about rate changes prepared to provide thorough and accurate answers? Well-trained staff increases the chance of provide clear and consistent information. A well-intentioned, but untrained employee can easily give inaccurate or confusing details that set the credit union up for trouble.These are just a few of the items that need to be considered in your variable rate process. When you are designing the plan for how your credit union will process these changes, be sure to include your trusted compliance professional.Rate changes are going to occur on a more consistent basis than we’ve become accustomed. A well-thought out plan on how to address the inevitable ups and downs around the bend will be a crucial step to ensuring they are traversed smoothly and correctly for all involved parties.
“We feel we have been prejudiced right from the outset. The FA introduced a new policy to handle our application on the back of consultations with the City Till We Die group, and we therefore feel that our application was already pre-judged. “This feeling has been reinforced with yesterday’s announcement, as the club feels this will further prejudice the forthcoming ballot of season pass holders. “However, this is now the time for the silent majority to come forward and support the club’s aspirations. Details of the ballot will be released to season pass holders within the next 48 hours.” Gretton was puzzled by the reaction, but heartened by the club’s apparent failure to make its case with the FA. He said: “I honestly don’t know why they would say that. It’s a very odd thing to say because as I understand it, there’s been no decision made yet. “There’s been a recommendation which has to be ratified by the FA, so it does seem tactically a very odd thing to do, to accuse the FA when they is still a decision to be made.” Allam has threatened to walk away from the KC Stadium if he does not get his way. However, members of the fans’ group are convinced there is a way forward. Gretton said: “We have been broadly happy with what’s happened under the Allams’ ownership of the club and we would like this to be finished. That’s why we welcome a season ticket holders’ poll. “If we can get a popular vote against the name change, we are not going to crow about it – we have no need to. “Hopefully, he would just abandon the plan and we could say ‘well done for being the bigger man’. We’d be delighted about that and we could start afresh.” Meanwhile, Tigers striker George Boyd has been charged with misconduct by the FA for allegedly spitting at Manchester City keeper Joe Hart. Boyd has until 6pm on Wednesday to respond to the charge. The club’s owners levelled the accusation at the FA in a statement released on Tuesday, 24 hours after it was revealed the FA’s membership committee had recommended rejection of an application to rename the club ‘Hull Tigers’. A decision will be made at a meeting of the FA’s Full Council on April 9, but Allam has vowed to put the matter to season pass holders in the hope of backing his proposal with a resounding ‘yes’ vote. Press Association However, the City Till We Die campaign group is convinced supporters, many of whom have reacted angrily to the move to alter the club’s name after 110 years, will not give him what he wants. Spokesperson Mark Gretton told Press Association Sport: “There have been so many polls and every one of them has voted against a name-change. “Every reputable poll that has been done, whether by a fans’ group, the Hull Daily Mail or the official supporters’ club, they have all voted against a name-change. “That said, asking the fans is a good idea. We suggested this back in November. “We wrote to him (Allam) about it, but he ignored us and in the press, that was when he started with his ‘no one tells me how to run my companies’. “We assumed he’d gone quiet on this. That would have been a very sensible thing to do back then so whatever the result, the pass holders can have a say in this decision.” City’s statement confirmed that pass holders will be balloted on the matter, which Allam believes is vital if he is to make the club more marketable, with details of the vote due to be released within 48 hours. The statement said: “The club is disappointed with the timing of yesterday’s announcement made by The FA. Hull supporters have warned owner Assem Allam not to bank on season ticket holders voting for his proposed name-change after City accused the Football Association of being prejudiced in its dealings.
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