WASHINGTON – In what Association of Corporate Credit Unions Executive Director Mike Canning describes as the largest expansion of ACCU ever, the group is currently exploring the creation of a "Compliance Clearinghouse." "The mission of the compliance clearinghouse is to solve the problem of varying interpretation of federal laws and rules across the corporate network," said Canning. What often happens is one corporate's legal opinion of a rule or law is different than that of other corporates. The ultimate goal, said Canning, would be for the clearinghouse to get regulators to sign off on guidance it issues to its corporates so they know they are going down the right road. Canning said for regulators that truly don't have a "gotcha" philosophy and want compliance excellence, they would welcome this clearinghouse. The clearinghouse would deal with such laws as the Bank Secrecy Act, Gramm-Leach-Bliley and various regulations such as privacy and others. Canning noted that with NCUA's Office of Corporate Credit Unions now wanting corporates to comply with FFIEC guidelines, this service would be perfect timing. The ACCU first considered hiring legal counsel in-house, but it now appears to be leaning toward retaining outside counsel. Bringing someone in-house or utilizing CUNA's existing legal team would have meant the ACCU expanding its management agreement with CUNA. Canning said CUNA's legal team was concerned that the clearinghouse would go beyond the normal trade association function in providing legal advice. Also, CUNA's legal team might not have had the expertise in certain areas that are critical to corporates, such as broker/dealer services where regulations abound. The ACCU's executive committee has signed off on a Request for Proposal for the ACCU to find outside counsel. It will likely cost the ACCU between $200,000 to $300,000 a year, and Canning said the large corporates have agreed to provide additional funding for the service, though he would expect corporate-wide support. "It could constitute a 50% increase in our budget. Members are willing to pay for it. The top corporates in asset size, got together in six months ago, talked about it and decided to go ahead and fund it," said Canning. Getting the right law firm will be key, said Canning, noting he would like one that has a history of working with regulators. "We need a law firm that has excellent contacts to get the agencies to look at what we're going to propose to our members as guidance first, so there are no surprises when these exams come. The ultimate goal is compliance perfection," he said. The clearinghouse would also serve as a center for best practices, where policies, operational procedures and contract language could be developed and made available for all corporates. This initiative is by no means a slam dunk and there are potential pitfalls. "The possible negative is that the communication between this law firm, 30 corporates, and the ACCU gets bogged down and doesn't work properly," said Canning. And on a more litigious front there is the question of whether the ACCU, as a non-profit, could become liable if poor compliance advice is give or some allegation is made of preference of one corporate over another. Canning said the ACCU is still investigating this. [email protected]