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ComplySight Newsletter

A Web-Based Compliance Management and Tracking Solution
June 2017
Vol. 4, No. 4

In this Issue:

Introduction

Area/Item Highlight

FAQs

Webinar Schedule

Contact Us

Closing Comments from Glory

Introduction !

More Enhancements!

You asked and we listened! We have just released several enhancements in ComplySight based on YOUR feedback and requests!

Here’s an overview of what’s new:

Dashboard Updates

We have overhauled the graphic on the Dashboard that previously showed all overdue items to provide a snapshot of your own assignments, whether or not they are overdue. Assignments “In-Progress” will show in black and “Overdue” items will show in red. Users logged in as L2, L2.5 or L3 can click on the Subject of the item to go directly to the item, whether it is an Automatic Action Item, Manual Action Item or Examiner/Audit Finding. A toggle in the upper right corner allows you to switch the view from your own assignments (“My Assignments”) to see any items you have assigned to other users (“Assigned by Me”).

ComplySight Dashboard

ComplySight Dashboard

Technical and Compliance Help – File Upload

Now users asking technical or compliance questions can upload a document to help clarify their question. Simply click the Browse/Choose File button at the bottom of the screen to attach a file!

ComplySight Dashboard

Automatic Action Items –Subject Field Added

This is a newly required field for automatic Action Items and can be helpful to organize and clarify them as they are generated. Previously, the Manual Action Item and Examiner/Audit Finding input screens allowed users to add a Subject line, but the automatic Action Item screens did not, showing “Automatic Action Item” instead of the Factor or other identifying language. Any existing Automatic Action Items in the system prior to this enhancement were given a default Subject using the Area – Item – Factor associated with that Action Item.

ComplySight Dashboard

Update to the Action Item Report and the Examiner/Audit Finding Report

The Action Item Report and the Examiner/Audit Finding Report have been updated to include filters to allow you to filter by Area, Item, Status and/or to whom the Item is assigned to. Also, direct links to the Items are now included within the “Subject” column (links are available to L2, L2.5 and L3 users).

ComplySight Dashboard

New Report - Files Uploaded Report

A new report – the Files Uploaded Report – has been added. This report will show ALL files uploaded, not just those that have been associated with content items.

This report contains filters to view files uploaded by owner, uploaded within a particular year, and those with 0 associations or 1 or more associations. Within the report, users can click on the file name to open/view the file and click on the number of associations to see with which content the files have been associated.

ComplySight Dashboard

New Column in File Manager – Number of Associations

Within File Manager you can now see at a glance how many content locations have files associated. To see the exact locations, users will still click on the “Associations” link, but this new information lets users see easily which files are not associated with any content or those associated with many content locations.

ComplySight Dashboard

Remove all Associations - File Manager Level

Within File Manager you can now remove ALL associations with one click of a button (of course, you must either be the File Owner or have the FM permission in order to remove file associations) rather than removing files from content location one file and one content location at a time. Keep in mind this operation cannot be undone, so this function should be used with caution!

ComplySight Dashboard

Remove all Associations – Content Location

Within a particular content location you can now remove files associated with that content location for a particular user level (of course, you must either be the File Owner or the FM in order to remove file associations) rather than removing files one at a time. Keep in mind this operation cannot be undone, so this function should be used with caution!

ComplySight Dashboard

We hope you find these recent enhancements helpful and make your ComplySight experience even better!

Area/Item Highlight

Area/Item Highlight: Investments/Conflict of Interest Rule

Overview

The Department of Labor (DOL) expanded their definition of a “fiduciary” to include persons who provide investment advice or recommendations for a fee or other compensation with respect to assets of a plan or individual retirement account (IRA). Fiduciaries to plans and/or IRAs are not permitted to engage in certain “prohibited transactions.” These new rules establish certain exemptions from the prohibited transactions to continue to allow certain fee structures, as long as there is adherence to applicable standards designed to ensure that advice is impartial and in the best interest of members and/or non-members.

The effective date of these new rules was June 7, 2016 with an applicability date of June 9, 2017.

Exemption - Exemption

The credit union would be exempt if they do not:

1) Refer members/non-members to broker dealers for non-deposit investment products; and

2) Do not offer investment retirement accounts (IRAs) at the credit union.

Factor 1 - Classification of a Fiduciary

The credit union understands that an employee may be designated as a fiduciary with respect to a plan or IRA by rendering investment advice for a fee or other compensation.

The credit union’s procedures and processes properly identify employees who may be provided compensation (direct or indirect) when providing investment advice as defined below:

• A recommendation as to the advisability of holding, acquiring, disposing of, or exchanging, securities or other investment property or a recommendation as to how it should be invested after the securities or other investment property are rolled over, transferred, or distributed from the plan or IRA;

• A recommendation as to the management of securities or other investment property, including, among other things, recommendations on investment policies or strategies, portfolio composition, selection of other persons to provide investment advice or investment management services, selection of investment account arrangements, or recommendations with respect to rollovers, transfers, or distributions from a plan or IRA, including whether, in what amount, in what form, and to what destination such a rollover, transfer or distribution should be made; and

• With respect to the investment advice, a recommendation made either directly or indirectly through or together with any affiliate by a person who:

• Represents or acknowledges that he/she is acting as a fiduciary within the meaning of the Act or code;

• Renders the advice pursuant to a written or verbal agreement, or understanding that the advice is based on the particular investment needs of the advice recipient; or

• Directs the advice to a specific advice recipient or recipients regarding the advisability of a particular investment or management decision with respect to securities or other investment property of the plan or IRA.

Factor 2 - Policies and Procedures to Avoid Conducting Prohibited Transactions

In order to avoid being be considered a fiduciary under the rules, the credit union has policies and procedures in place to do one or both of the following:

1) Provide no compensation either directly or indirectly to credit union employees that result from any transaction associated with the credit union’s term deposit investment retirement accounts.

2) Provide no investment advice to members or non-members, including recommendations with respect to rollovers, transfers, or distributions from a plan or IRA, including whether, in what amount, in what form, and to what destination such a rollover, transfer or distribution should be made.

If the credit union has no policies and procedures to prohibit one or both of the activities listed above, it has worked with legal counsel to create a Best Interest Contract Exemption compliant with the rules.

Factor 3 - Best Interest Contract Exemption - Bank Networking Arrangements

If the credit union or its employees receive compensation (incentives, bonuses, prizes, etc.) based on the referral of a Retirement Investor to a Broker Dealer they must utilize a Best Interest Contract Exemption specific to Bank Networking Arrangements*. Credit unions that rely on the Best Interest Contract Exemption under the rule:

1) Acknowledge fiduciary status with respect to the investment advice to the Retirement Investor;

2) Adhere to the Impartial Conduct Standards;

3) Implement policies and procedures reasonably and prudently designed to prevent violations of the Impartial Conduct Standards;

4) Refrain from giving or using incentives for Advisers to act contrary to the customer’s best interest; and

5) Fairly disclose the fees, compensation, and Material Conflicts of Interest, associated with their recommendations.

*In order for this exemption to provide relief to the credit union, the arrangement of the referral of retail non-deposit investment products must satisfy applicable federal banking, securities and insurance regulations, under which the credit union employee refers credit union members or non-members to an unaffiliated investment adviser registered under the Investment Advisers Act of 1940 or under the laws of the state in which the adviser maintains its principal office and place of business, insurance company qualified to do business under the laws of a state or a broker or dealer registered under the Exchange Act, as amended.

Factor 4 - Impartial Conduct Standards

The credit union will adhere to, and if they have a third-party relationship with a broker-dealer, oversee and ensure their adherence, to the Impartial Conduct Standards by:

1) Giving advice that is in the Retirement Investor’s Best Interest (i.e., prudent advice that is based on the investment objectives, risk tolerance, financial circumstances, and needs of the Retirement Investor, without regard to financial or other interests of the Adviser, credit union, or the credit union’s affiliates, related entities or other parties);

2) Charging no more than reasonable compensation; and

3) Making no misleading statements about investment transactions, compensation, and conflicts of interest.

FAQs

ComplySight FAQs

Question: What’s the difference between accessing File Manager and having the FM permission assigned to a user?

Answer: All ComplySight users, with the exception of the L4 user, have access to File Manager. This access allows users to upload and associate files with various content throughout ComplySight for easy access during reviews. Each user only has access to manage the files they upload. The “FM” designation, however, is a very powerful level of access within ComplySight. The users with this access have authority to affect changes to ALL files uploaded into File Manager, even those that they did not originally upload or associate.

ComplySight
Webinar Schedule

To view a Recorded webinar, click on the title of the webinar.

Webinar Schedule

RECORDED WEBINARS - Click on the title of the webinar to listen. (A “safe” download of WebEx may be necessary.) These are available 24/7!

The existing recorded webinars provide you with a variety of topics that will get you started on your ComplySight adventure. New ones are added as needed, to share new enhancements.

File Manager

Introducing the newest enhancement to ComplySight that is a central repository to manage all uploaded documents within ComplySight. File owners now have the ability to upload documents in bulk and assign them to multiple Areas, Items and/Factors as needed.

Factor Selection Navigation Screens

To simplify the ability to access Factor Grading screens and Item information, the Factor Selection screens have been redesigned. Check out this short webinar for details!

Access Level 2.5 and How to Use It

Introducing the newest access level, allowing the L1 Administrator to set L2.5 access and then assign specific Areas that only that user may review.

Introduction to ComplySight
Designed to introduce and show the many features and benefits of ComplySight.

Training & Tips – Where to Start?
This webinar will: suggest a starting point as a new ComplySight user, discuss how Factor Grading works, review the Action Item Build/Edit process, and discuss the need for a compliance management tool that regulators - and you - will appreciate.

Training & Tips – How to Export Data
When you need to archive or copy data out of ComplySight for a fresh start or to provide information for a Board meeting, this webinar will explain the process.

Training & Tips – Reg Alerts, Etc.
This webinar explains Regulatory Alerts, Factor Weighting, Assigning Employees, and gives a quick preview of Level 2.5.

Training & Tips – Reports
What reports are in ComplySight and how are they utilized?

Contact Us

Technical questions (software operation issues) can be submitted through the Technical Support form in ComplySight

Compliance related questions can be submitted through the Compliance Questions form in ComplySight.

For other questions: click here

Closing Comments from Glory

Happy Summer!

As you can see from this newsletter, we have been busy incorporating changes in ComplySight that are being requested by our awesome users! We can’t tell you how much we appreciate your feedback! Compliance is hard enough, so if there is a way for us to make ComplySight easier for you to use, we are all ears!

I know I have mentioned the concept and intention multiple times in our previous newsletters, but I’m happy to say that we have officially begun the development of the Complaint Management System within ComplySight! We are jumping up and down about it too, because it is going to be such an amazing resource for our credit unions. It’s also perfect timing, since we know examiners are going to start asking about credit union’s compliance management systems as part of the new FFIEC Consumer Compliance Rating System! By the way, if you weren’t excited enough - our goal is to have this enhancement complete and available for our users by the end of the year!!

ComplySight is evolving in ways we never imagined! Kudos to our amazing users who are always willing to provide us feedback and collaborate on ideas for improvement and kudos to our passionate team who can envision and execute on those collaborative concepts.

COMPLIANCE ROCKS!

Glory

Glory LeDu, CUCE, BSACS, CUERME

Glory.LeDu@cusolutionsgroup.com

ComplySight is a product of League InfoSight, CUNA and your State Association or League.

Check with your League/Association for information regarding availability in your state.