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In these high performing credit
unions that I mentioned, you can go

through the board packet and you can
pretty much figure out what they're

trying to do and how they're doing
it just from a single board packet.

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Hey everyone.

I'm Mark Treichel and thanks
for joining me today for another

episode of with flying colors.

Today, I'm joined by a member of my team,
Todd Miller, and we're going to discuss

the role and elements of good policies.

Todd, before we jump into the role
and elements of good policies at

credit unions, for those of you who
may not have heard your past episodes

or may not know you yet, could you
give a little bit of your background?

Sure.

I was with NCUA from November of
1987, all the way to June of 2021.

When I retired, it was
a very enjoyable career.

I enjoyed it a lot.

Learned a lot.

I was at the various roles.

I, um, Bill, during my M
career, I was examiner.

Of course is what I started
right out of college.

I was a problem case officer.

I spent 10 years as a regional
capital market specialist.

And the last 10 years of my career,
I was the director of special

actions in the Western region.

Dealing with troubled credit unions.

Dealing with troubled credit unions,
where you got to see some challenges.

No doubt.

It's, it's interesting.

So we had three jobs, the same
examiner, problem case officer

and director of special actions.

Also, I was on the, on the West coast.

I guess it was your region, but you
know, the regions merged together,

And you started, it didn't dawn
on me until you just said it, you

started a year after me, and you
worked exactly one year more than me.

So our tenure is, I think you
might have one more month on that.

I, so anyway, I digress.

All right.

So policies, what are they?

What makes them good?

What's their role and
what's their element?

So we're going to talk about policies.

And so what, based on, you know, you
just described what your background is.

So something in your background,
something that you saw.

Made you want to discuss this
as a topic, Todd, what was that?

Well, there's a number of things is why
I wanted to discuss this as a topic.

If you go back and look at what we do,
we help credit unions pass their exams.

And of course, a lot of the exam issues
are policy related and underlying

that is we expect boards to have the
general direction and control of their

credit union and how do boards carry
out their duties, basically they do

that through their written policies.

And secondarily, they also
do it through their business

plan and their strategic plan.

Those are the two primary ways that
boards kind of carry out their duties to

have that general direction and control.

We talked about, as a director of special
actions, I dealt with troubled criteens.

Well, I also had 20 some years of
dealing with what I would call very

high performing credit unions as well.

And there's some very consistent
characteristics in these high

performing credit unions.

One, they have very strong corporate
cultures and its policies and

strategic plans is how they build
those corporate cultures and

how they convey that to staff.

I always thought it was very interesting
in the high performing credit unions.

You could go way down to Branch
managers and tellers sit in the

lunchroom, talk to loan officers,
every employee in these high performing

credit unions was on the same page.

They knew what was in the strategic plan.

They knew what they were
supposed to be doing.

They knew why they were
supposed to be doing it.

They were all very
efficient organizations.

They all had very strong policies.

Across the organization, and
it's a characteristic of high

performing credit unions.

Their staff know what they're supposed to
be doing, why they're supposed to be doing

it, how they're supposed to be doing it.

And that's all conveyed to them through
written policies, that strategic plan.

That business plan, you know,
you, you reminded me of something.

1 of my employees and Albany used
to say that the regional office ran

itself and it ran itself because it
had good policies, procedures and

structure and corporate culture.

And you get that when you have
that all in place, you can just see

how you can be a high performer.

So that that's a correlation to
a regional office that applies to

the credit union world as well.

So, well.

Go ahead, maybe just
another piece to that.

Maybe another way to paraphrase
that and describe it is it's

transparency across the organization.

And we're going to digress
just a 2nd, because I can, and

I have the mic at the moment.

But even if you look at my
35 years at their time, when

employee morale was better.

Higher lower, I mean, it was generally
good the entire time, but there was

times when it was better and those.

Years when it was better than
others, it was always years

where NCOA was more transparent.

The level of transparency from
the top to the bottom was better.

And I think NCOA over the years
is they tried to improve that.

You know, they have that national
supervision policy manual now, and I

think they actually work at being a
more transparent organization over time.

Yeah, and you know, and transparency
goes to expectations when someone

when you're transparent and people
know what your expectations are.

People always desire to
achieve expectations.

And if you have the structure in place.

It allows everybody to excel.

So great point.

All right.

So specific to policies, what exactly
are we going to dig into today, Todd?

Well, I think we'll break this down
into kind of just three pieces.

We'll talk about why you
should have policies.

I'll give you some just general thoughts
on policies and how to execute them.

And then last and probably
the most important piece.

We'll talk about common elements
to good policy, and I don't care if

you're writing a policy that's related
to personnel, a lending policy, an

ALM policy, a compliance policy.

Policies have some common elements,
and if you make your policy

statements consistent throughout the
organization, you'll just end up with.

A more transparent and effective
organization, and we'll talk about

some of those common elements
to a good policy statement.

Very good.

So, Todd, why does the credit union need
to have a set of comprehensive policies or

set another way even an individual policy
that covers a particular specific topic?

And what's the purpose?

There are many, many reasons for
this, and I'm just going to list them.

It's not going to be all inclusive.

We could probably spend an
hour going through just why

you should have a good policy.

There's always hot, but number 1,
they're required by regulation.

And if you go through the regulations,
you're By regulation, credit unions

have to have specific policies.

They need a lending policy.

They need an interest rate risk policy.

They need a liquidity policy.

Those are mandated by regulation.

If they're into a member business loan,
they need a member business loan policy.

If they're buying participations,
the regulation requires they

have a participation policy.

So, first off, They're
required by regulation.

Kind of a corollary to them being
required by regulation is good policies

ensure compliance with the law.

There's a plethora of regulations out
there that you have to follow from hiring

all the way to non discrimination in
your lending, everything in between.

Um, but another purpose of policy, just
ensure your staff know what those legal

requirements are and you comply with law.

Policies are a good training tool.

You know, when you hire a new
employee, how do you get them

familiar with the organization and
what they're supposed to do and what

the organization's expectations are?

So policies are a good training tool.

One of them you mentioned earlier,
when we were talking about NCUA,

policies are there to set expectations.

You communicate that corporate
culture, their values and mission.

And that corporate culture
is really important.

And there's a lot of benefits
to a strong corporate culture.

Organizations with strong corporate
cultures, they tend to be more efficient.

They have lower employee turnover.

Your employees tend to be happier.

They know what expectations
are and they meet them.

Makes for a more pleasant work
environment for all your employees.

There's fewer compliance failures
and service quality to your members

just tends to be much higher when
you have good written policies.

Second piece of that, or a continuation
of that is, they set standards for

behavior and conduct and performance
for both employees and management.

And this is really important, is that
people know how they should behave

and they should have standards.

And this is kind of an
important one for management.

If you expect your employees to
follow policies, you need to make

sure as management and executives
that you're following themselves.

From a board perspective, good
policies, keep management accountable.

And from a human resource perspective,
it helps you defend against lawsuits and

it lets employees know where to get help
in terms of if they have any questions

about employment or about any aspect
of their job, policies, let them know

where they need to go to get answers.

So that's just some general
reasons and the purposes for having

policy and Good policy statements.

There's a lot there to unpack Todd.

And as you were going through it.

I'm going to highlight 1 of the topics you
mentioned, which is it's good to have 1,

because they're required by regulations
and where the rubber meets the road.

You and I were chatting with the.

Credit union the other day, and
we were having a discussion.

The credit union had a
draft examination report.

They thought that perhaps some things
didn't need to be in a document

resolution and that perhaps they
could be in an examiner finding.

And as they brought that up.

You know, you pointed out to them
that the items that were in the

resolution were there because they
were violations of regulations.

And you didn't think and you
thought that that's probably

where they should be because they
were a violation of regulation.

Anything you want to, I'm assuming
you agree with that, but anything

you want to add to that thought.

No, I'm not going to add to it.

I agree that place, there was like,
I think it was four violations of

regulation and policies are so important.

You just shouldn't, credit unions
shouldn't get themselves into where you

have multiple violations of regulations.

And if you have good policy statements
and good training programs to

educate your staff on those policy
statements, you're not going to end

up with regulations of violation.

Very good.

So you've touched on some of the
reasons or purposes for good policy

statements, and you also mentioned
that we're going to discuss, discuss

common elements of a good policy.

Before we dive into that, are there
any other general thoughts before

we get into specific policy elements
that you'd like to chat about?

I do.

I have a couple things before
we get into basically the common

elements of a good policy.

These are just some things
that I've learned over my.

Years of experience with N.

C.

U.

A.

I didn't read these in a book.

They're just my observations.

We're not a management consultant.

These are just kind of my views.

Implementation.

It needs to happen from the top down.

And I mean, the board needs to
be clear in setting expectations.

Um, a lot of times they do that with
that strategic plan and business plan.

They do that in their
policy statements as well.

Um, you want to have a high performing.

Thank you.

Organizations, your executives
need to set a good example, and

they need to abide by policies if
they expect staff to do so as well.

So, lead from the front, sound policies
are implemented from the top down.

Policies need to be readily
accessible by staff.

It's hard to expect your staff
to comply with policies if

they don't know what they are.

So within your organization,
have them in your library, make

them easily accessible to staff.

And if you're a loan officer,
your lending policies probably

should be in writing in your desk.

Have staff meetings, go over
them periodically, but they

should be easy to find for staff.

And so make them accessible, spend
some time training on them, communicate

them throughout the organizations.

Policies need to be kept current.

And we find this a lot with our clients
and exam work and organizations grow

and their policies get outdated.

They don't grow with the organization.

So if you're going to have a
good policy program, You should

have review dates put in there.

Let's look at these periodically.

Let's make sure we keep them current.

A new regulation comes out.

Read the regulation.

Is that consistent with current policies?

They need to be kept current
on the other side of the coin.

While employees should
be educated on policy.

They should also know that there's
consequences for not following policies.

Well, expectations are important.

Training is important.

There does need to be consequences
if policies are not followed.

You'll have a breakdown in the
organization if there isn't

consequences for not following policy.

Policy exceptions should
be documented and reported.

A lot of people write policies and
you can never write a policy that's

going to cover every situation
that will come up with a member.

So there are going to be times where
there's exceptions to serve a member

or help out an employee or whatever
it may be, but policy exceptions

need to be documented and reported.

If you get into the situation where
You're having more exceptions are

a lot of exceptions to policy.

It's time for the board and management sit
down and say, is that policy appropriate?

We're having to go through and
create a lot of exceptions to

policies to serve our members.

Well, maybe our policy needs
a little bit of revision.

Todd, that last comment, you
remind me of a line from a song,

which is, it's a one time thing.

It just happens a lot.

And if it happens too much, like you said,
maybe it's time to reevaluate the policy

when the exception becomes the norm.

Let's tweak that.

The other thing I want to say, when you
talked about it coming from the top down,

it reminded me of, you know, the NCA
security system in the central office.

This is kind of an abstract reference,
but I would occasionally forget my badge.

And I would walk into work because
I live close to the office.

And I remember the first time after
I had been executive director and

I forgot my badge and I had to let
the guard would let me in and I saw

in the look of his eye, it was like,
well, Mark really needs to have me BS.

I need to escort him up the elevator.

And before he even hesitated, I said,
I know you need to come with me.

You know, I wanted to let him know.

That I was going to follow the rule
and when we got on the elevator and

there were other folks in the building
and they saw that I had to follow the

rules as executive director, you can
really set the tone at the top by every

action you take in the credit union,
whether it's policy or procedure.

So I thought of that example,
when you started talking about the

importance of compliance from the top.

So, all right.

With that background, let's get
into what the key elements that

are common to all policies.

You mentioned interest rate risk,
you mentioned liquidity, you

mentioned commercial lending.

If you got that, there are key elements
that are going to be in every policy.

Let's walk through that Todd.

I will.

And this is the corporate
culture thing too.

When you sit down and write your
policies, you put all these elements

in there and it should be consistent
how you write your policies.

These across the organization, you
just see that in high performing

credit unions, there's a format to
these, but I'll go through what I

see is some of the common policy
elements that should be in any policy.

If I kind of back it up the way I
would summarize it is your policy

should really describe your risk
management process in the organization.

So, common policy element, purpose
and objectives of the policy.

Let's tell.

The organization and our staff,
why do we have this policy?

And what are we trying to
accomplish with this policy?

Kind of the second common element
that I would say that you'll

find in good policy statements
is they establish accountability.

Who's responsible to identify,
measure, monitor, control risk

with respect to that area.

And there will be some internal
controls laid out within the policy.

And this is part of the accountability.

You separate risk taking from reporting.

It's just good accountability.

You separate the person who's
making decisions from who's

reporting on the outcomes.

It's a good internal control.

Another common element to good policies
is the board will communicate its

risk appetite within those policies.

I'll call it a risk appetite statement.

Just kind of some examples of
things that fall under that whole

category of Risk appetite statements.

You'll have organizational
wide balance sheet limits.

Well, X percent of net worth
will go into commercial loans.

X percent of net worth will
go into indirect loans.

X percent of net worth will be to grade
D borrower, C and D subprime loans.

You'll have interest rate risk limits.

You'll have liquidity limits.

Whatever the policy is dealing with.

You'll have some balance
sheet wide limits.

There should be limits on individual
authority within a policy.

Individuals at this level
are authorized to do X.

Individuals at this level
are authorized to do Y.

If we get to this point,
it will take a committee or

multiple people to approve that.

There should be limits
on individual authority.

There should be limits on how that
authority is delegated downstream.

So you can authorize a CFO to purchase
investments up to 2 million blocks.

Well, you should specify what
can he let his subordinates do.

That should be laid out, you know, how
much can an individual with policy, the

authority delegated downstream limits
need to be real, not just guidelines.

And over my years, lots of credit, they
like to put guidelines and policies.

You get into higher performing
organizations, there's not

guidelines and policies.

There's hard limits and policies.

Guidelines might lead you up to a
limit, but limits need to be real.

I think you need to be wary
of guidelines that create some

wishy washy corporate culture.

Limits get fuzzy.

You can have guidelines, but they
need to be backed up with real.

Hard limits on the back end.

Limits need to be triggered before
risk profiles change significantly.

You'll see a lot of credit unions,
a lot of organizations, they'll have

the green, yellow, red thresholds
as a way to point out policy.

Hey, when we get to that
yellow, let's slow down.

The other thing is, is.

And I see this as a weakness,
and it happens in many credits.

There will be a regulatory limit, and
they will make that their policy limit.

When I'll just give you an example,
you know, we have a regulatory limit

that you can have 20 low income
credits can have 20 percent of their

deposits from non member, and you'll
see people write that in their limit.

But they're at zero.

There needs to be something trigger
when they go from zero for 10

years to 5 percent or 10%, it's
not an effective policy limit.

If it's doesn't create some warnings
as you change your risk profile.

Another one is investment.

I see when I was a capital market
specialist, there was a lot of

Cardenas wrote investment policies.

Their policies authorized
everything in the regulation from

repurchase transactions to high
risk, private label, mortgages.

In a lot of cases, cardians have
never ever bought those instruments.

They will never ever
buy those instruments.

They don't understand
half of those instruments.

Things like that should
not be in your policy.

Your policy should be real.

It should reflect the risk appetite
and they should identify if your risk

profile is changing along the way.

So they should be unique.

Those risk limits should be
unique to each credit union.

The next one is probably what I
would call maybe one of the most

important aspects of a sound policy.

And that's a system of reports
based on a risk assessment.

Reporting, I'll summarize it this way.

It needs to demonstrate management's
compliance with policy or turn it around.

Management needs to demonstrate
compliance with policy in

all aspects of the reporting.

So, if you have a policy limit,
there needs to be reports on that.

You have early warning
indicators within your policy.

There needs to be reports on that.

Now, reporting doesn't always mean
every single thing goes to the board.

But within the organization,
there needs to be reporting to

some level of responsibility.

I'll just throw something out.

A lot of credit unions are
involved in indirect lending.

For example, most places
track dealer delinquencies.

There are necessarily
need to tell your board.

What the delinquency level is of every
indirect dealer, they should know

delinquency overall, maybe delinquency for
an indirect lending program, but at dealer

level, they don't need to know that.

But certainly your loan committee and your
loan officers or chief lending officer.

They should know what that
delinquency is at a dealer level.

That's a key risk indicator.

So that reporting doesn't necessarily
need to be the forward level, but

there needs to be a system of reports
that provide your early warning

indicators, a demonstration with our
compliant and demonstrate compliance

with the credit risk appetite.

Whatever that might be, there
should be reporting on risk limits.

If you have organizational wide risk
limits, there should be reporting on that.

All those limits that are
a percentage of net worth.

I would argue those are limits
that should be reported all

the way to the board level.

It's kind of interesting.

And this is a little sidetrack, but I've
seen several high performing credit unions

They have a compliance report, and it's
interesting where you see it in the board

packet in those high performing credeans.

You see it close to the front.

It's not on page 300.

It's on page 3 or 5 or 7.

It's somewhere close to the front
in those high performing credeans

because they take it seriously.

And a lot of times there are
strategic plan elements on

that type of compliance report.

As well, policy exceptions,
they need to be reported.

We kind of talked about it a little
bit earlier on general thoughts.

If you get too many exceptions,
it's time to review your policy.

Another thing with Reporting
and compliance with policies.

I think it's important for boards,
especially that your reporting

process shows trends over time.

It doesn't show what your
limit was this month.

It shows where we're at this month.

It shows where we were at last
month, a quarter ago, a year ago.

Whatever the case may be, I think for
boards, they have a huge amount of

common sense and they might not be
experts at any one thing, but I think

most board members will, if they look
at a trend and they see things changing,

it will prompt them to ask a question.

And even for management.

It's good to know what direction you're
moving and how fast you're moving.

It's not just where you are, but where
have you been and where are you going?

You kind of need those
headlights down the road.

So trend reporting is very,
very important in my mind.

And I think for board member,
it's probably more important than

even knowing where we're at today.

It's where have we been?

Where are we at directionally?

Where are we going?

I think you need all three of those.

Types of reports and monitoring, and that
should be written down within your policy.

You should define this reporting
process very clearly in each

of your policy statements.

And then last, we talked about
the final thing is there should

be a systematic review day.

Not every policy needs to
be reviewed every year.

By regulation, there are certain
policies that do need to be reviewed

every year, but there should be some
ownership within the organization and

a specific review date for all policy.

Even in CUA, we go through all
our regulations every three years.

In theory, we go through
them every three years.

Anyway, I don't know why I'm
saying we, we're retired.

We're not part of any more habit, I
guess, but that review date is important.

And, you know, I think a lot
of When they get findings, you

just see it quite frequently.

They're going to hard.

They're working every day.

We're at 500 million.

All of a sudden you turn around.

Now we're at a billion 5 and
policies haven't changed, but

we've got all these new programs
and different things going on.

And it's important as an
organization grows that.

Those policies grow with them.

The examiner say they want it
appropriate to your complexity

and it just needs to so set up a
process to review them periodically.

So they grow with you.

That's a lot you through at the
audience a lot you through at me,

Todd, I'm going to highlight a couple
of things and then I'm going to have a

couple of follow up kind of questions
for you before we wrap up here.

But.

You know, your last, second to last
point on trends and a point in time, to

me, the word that jumped out is context.

I need to have context.

I like to see things over time.

Is it growing?

Is it shrinking your point that
just knowing a number today

can pretty much be irrelevant.

If you don't know what's the goal,
what's allowed and where have

we been and where are we going?

And I think you really said it.

Well, that providing that allows.

The board members to understand
and provides them the opportunity

to ask better questions.

And that can lead to a dialogue that can
lead the credit union to a better place.

So that's my take on trends at a point in
time, jumping back to limits on individual

authority, things that jumped into mind.

There is when people violate that
limit to authority, there's the

potential that you could have bond
claim and situations like that under

the most Intense of those scenarios.

Any thoughts relative to that
side of things as it relates to

limits on individual authority.

Yeah, and I'm going to go
back to something else.

I said earlier to the tone from the top.

If you have 1 employee violating limits
in his own authority or her own authority.

Other employees are going to
see that and you're going to see

that behavior occur through with
other people in the organization.

It's a morale killer when employees
see management saying do this

and they do something else.

It's just not good for morale.

A lot of times examiners find this
because those employees that are unhappy

and disgruntled about that will tell
their examiners that this is going on.

That happens a lot.

But yes, bond claims are never good,
and one of the things I mentioned in

my general thoughts, there needs to be
consequences for not following policies.

The system tends to break down if
there's not consequences for not

following policy, and individual
limits are a key part of it.

And I'll just say, in dealing with our
troubled credit unions and some of the

credit unions that NCUA has had to pay
out insurance funds to resolve, At the

heart of those, it seems too many times
there's individuals who just started out

with violating their individual policy
limits and it became a big problem

that cost the insurance fund money.

Well said, well said.

So, so this is a kind of a two
part question before we wrap up.

As you were talking about board
packages and what's included,

what's excluded, I'm pretty sure
in your mind you have a feeling of

what an optimal board package is.

You know, when you and I are talking
to different clients or when we're,

we're working trying to assist credit
unions, oftentimes you'll say to me,

I'd love to see the board package.

Cause that again, that provides you
context to best understand what's

happening at the credit union.

So along with that, separately, you
and I had chatted about, there's

probably going to be some future
podcasts that come out of this podcast.

Any, can you comment on either of
those two statements I just made?

Yeah, I just have a feeling Mark
has shared a list of podcast

ideas with a bunch of his staff
and clients and other things.

And I think you're going to see
future podcasts potentially on

individual policies, rather than
general elements, what should be

in an interest rate policy or what
should be in a business loan policy.

I can see that coming.

Board packages are an interesting thing.

A couple of times in my career,
I'd sit down with groups of my

own staff and say, Hey, what
should be in a good board package?

And board packages are very
interesting because there's

things the board wants to know.

And then there's things they need to know.

And you can't necessarily
make them read it every month.

But I will go back to you.

It's important that management
and executives give the board all

the information they need to know.

And maybe they won't read it every
month, but maybe they read it every 3

or 4 months or something of that nature.

I think it would be very easy to
spend a half a day sitting down with a

board is what's in your board packet.

And I think credit union board packets,
a lot of times they, well, the examiner

says, put this in there and they
put it in there and someone else's,

this should be in your board packet.

They add another sheet in there and
pretty soon this board packet is huge

and they've never really went back at
any given point in time as they've grown

and said, what needs to be in there?

You know, certainly if the board
wants to know something, you

need to put it in the rest of it.

I would go back.

Management needs to demonstrate
compliance with policies and give them

progress reports on that strategic plan.

But board packages, it's a very
interesting topic of what should

be in there, and it reflects
the nature of the credit union.

And I'll just throw out an example.

One of the problem credit unions
I had at one point in my career.

They were about 2 or 3
billion were sitting there.

Of course, they ended
up in special action.

So they have negative earnings
and all kinds of problems.

And I think they had at that time, 42
branches in their cost accounting system.

31 of their branches were losing money.

And my comment to the CEO is
don't you think your board members

would maybe like to know that?

Most credit unions, you know, they
don't necessarily report all that

branch profitability to the board.

And there's probably not a necessity to,
but at a strategic plan, occasionally,

it's probably information that you
should share with them sometime.

It's a pretty significant fact when three
fourths of your branches are losing money.

And maybe your board members
might want to know that.

So it gets situational.

Like all 42 branches were making money.

Well, it probably wasn't
something they would have needed

to share with their board.

So.

Board packages are an interesting topic.

When I was an RCMS and examiner, though,
the first thing I would always do was

just, I want to open a board packet.

I would share it with every
exam member on the team.

In these high performing credit
unions that I mentioned, you can go

through the board packet and you can
pretty much figure out what they're

trying to do and how they're doing
it just from a single board packet.

It's very transparent in these high
performing organizations, what's

going on, and you can figure it out
just looking at a board package.

That's a good place to wrap.

So the example of the branch offices, like
you said, if more than half of them are

losing money, that seems to fall into the
category of the need to know you said,

there's the want to know, and there's
the need to know they need to know that

so that they can take some actions to
lead the credit union into the future.

So another great episode, Todd, I
appreciate you sharing your wisdom

with the folks that will be listening.

And that's it for today.

I want to thank Everybody
who listened for their time.

I'm Mark Treichel, and I hope you join us
again next time for With Flying Colors.

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