18/04/2024 Practical Implications of MCC for

Transcript:18/04/2024 Practical Implications of MCC for:
18/04/2024 Practical Implications of MCC for Credit Unions Presented By Íde McCormack Contents Introduction MCC Requirements MCC In-Scope Activities for CU New F&P Controlled Functions Impact on Governance Arrangements Impact on Operational Processes MCC Gap Analysis Developing MCC Plan MCC F&P Register Fitness & Probity Controlled Functions F&P Due Supporting Diligence Documentation F&P Process for CU CF Roles F&P Due Diligence Requirements Data Protection Obligations Review of Governance & Operational Documents A key objective of the CBI over the last number of years is to ensure an appropriate and standardised level of professional competency within the financial services sector Achieved by the roll out of the MCR and Fitness & Probity Regimes The MCR will now include Credit Unions from 1st Oct 2024 for in scope activities The recent changes to the MCC/F&P requirements, the new Individual Accountability regime and the recently enacted Credit Union Amendment Bill represents some of the most significant changes to the Credit Union legal and regulatory landscape in recent years Introduction MCC Requirements Already applies to Credit Unions providing Mortgages and who act as insurance intermediaries The MCR requires credit unions to ensure relevant persons are compliant with MCC requirements after 1st October 2024 Individuals performing specified activities regardless of whether they are a member of staff, or a volunteer must meet the MCC requirements by 1st October 2028 but have commenced the process by 1st October 2024 MCC In-Scope Activities for Credits Unions After 1st October 2024 any officer providing information to members on Lending and Term Deposits will be required to hold or be in the process of attaining a recognized MCC qualification for these products, such activities include: Talking to a member about a loan or term deposit product Taking an application for a loan or term deposit, including for temporary arrangements and rescheduling a loan – so tellers, MSO, credit and credit control officers for example Deciding on a loan application (or other product) – so tellers (particularly for loans within shares), credit officers, credit committee, Board Overseeing/supervising the loan or term deposit process – e.g. Head of Lending, Supervisor, Operations Manager. Branch Manager, Credit & Credit Control Committee Loan or Term Deposit new product development – Management Team, Committee or Board New F&P Controlled Functions Impact on Governance Arrangements - Loans An entire Committee (Credit and Credit Control Committee’s) or Board needs to be qualified – which will require sufficient