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.
For all the Latest Sports News News, Football News News, Download News Nation Android and iOS Mobile Apps. London: Arsenal will offer counselling to Granit Xhaka after the Gunners captain found himself in trouble for swearing at his own fans, according to reports in the British press. Xhaka cupped his ears and gesticulated to towards Arsenal fans who booed him when he was substituted during Sunday’s 2-2 draw against Crystal Palace at the Emirates Stadium. The 27-year-old appeared to shout “f**k off” at the crowd as he stormed towards the tunnel and pulled off his shirt.Arsenal manager Unai Emery admitted Xhaka was wrong to react that way and refused to confirm if he would remain skipper. Xhaka has held three meetings with Emery since the incident but the club are putting the player’s welfare ahead of any quick decision over his future.Reports in the British media on Tuesday said counselling will be offered should Xhaka decide on such a course of action, with Emery describing the midfielder’s mood as “upset, devastated and very sad”.It is also believed the outburst was a reaction to cumulative issues which have built up over time, including social media posts targeting Xhaka and his family.His wife Leonita set her own Instagram profile to private after receiving abusive messages aimed at her husband, while Xhaka himself raised a few eyebrows by changing his profile picture on the platform from one where he is sporting the Arsenal armband to an image of him captaining Switzerland.It is understood Xhaka has been made aware by the club of the benefits of offering an apology, but he is so far not in the right frame of mind to do so and is keen for any subsequent acknowledgement of wrongdoing to be genuine.”At the moment, I am not speaking and I don’t want to speak about that,” Emery replied when asked if Xhaka could lose the captaincy over the issue.”Now he is upset, devastated and sad. It is not only yesterday and today. He is feeling the supporters don’t like him.”His commitment with the club is a great commitment every time. He wants to help.”His behaviour was perfect in training, with the group and with the club. He knows he was wrong.”He was wrong and he feels it inside very deeply. But that is normal as a human.” Xhaka will not travel with Arsenal for Wednesday’s League Cup tie at Liverpool.
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