Ins and Outs of Fiduciary Outsourcing for Credit Unions

By: Richard W. Rausser, Senior Vice President of Client Services, Pentegra Retirement Services

With retirement plans seemingly becoming ever more complicated, outsourcing of fiduciary investment responsibilities has steadily become more commonplace. This is especially true in the case of the C-Suite at credit unions, which can find outsourcing very appealing.

Not only is the passing along of fiduciary responsibilities one less burden for credit union managers, allowing them to focus on day-to-day business and obviating the need for them to become qualified plan experts, but the practice can also serve to insulate them and their credit union from a number of risks.

Benefits of Outsourcing

Outsourcing to a sanctioned third-party fiduciary guarantees that a given plan’s documentation is up to date, complies with all laws and regulations, and delivers appropriate disclosures to plan participants and sponsors.

If a plan is large enough (meaning it has roughly 100 to 120 participants) it requires an independent auditor – the selection of which again can be provided by the external fiduciary, saving the credit union time and money. (It should be noted that investment fiduciary outsourcing can be appropriate for defined benefit and defined contribution plans of all sizes.)

In addition, the day-to-day management of a plan involves, among other things, making sure the plan is running as it should be; nuts and bolts record-keeping; and administrative decisions about such issues as a plan participant’s request for a loan or a hardship distribution.

Customizing Responsibilities

Arranging the responsibilities of a third-party fiduciary should be fairly easy to customize; one can outsource all of the above or cherry-pick whichever duties one wishes on an ala carte basis.

A credit union needs to provide a reputable third-party fiduciary with the following:

  • Data on the plan participants;
  • The money involved with the plan; and
  • A commitment to regularly review the plan’s performance (usually once a year).

In that way, any questions or concerns can be addressed efficiently. (Of course, any issues that rise before the review date can also be discussed at any time.)

Fiduciary Responsibility

If there are record-keeping errors made by the outside fiduciary, it is that fiduciary’s responsibility to make amends, including making up any monetary shortfall. In the unlikely case of a participant-filed lawsuit, the outside fiduciary is again front and center, providing the defense in the case and making good on any claims or settlements.

The credit union’s board and senior management are insulated from responsibility; even though the plan ultimately belongs to the credit union, it is the named fiduciary who holds the liability in such instances.

Such an arrangement can also be of value in the case of multiple employer plans (MEPs), an employee benefit plan that can be maintained as a single plan in which two or more unrelated employers participate. As each credit union has its own separate boards of directors, the advantages of having an independent fiduciary to manage and administrate the plan are readily apparent.

Credit Union Responsibilities

All of that said, there will remain some fiduciary responsibilities and liabilities for the fiduciary responsible for selecting and contracting with the outsourced fiduciary. Breach of contract is the most obvious of these, but there is also the matter of monitoring/reviewing with the outside fiduciary that I mentioned previously.

In addition – and this should go without saying – it is incumbent upon the relevant credit union executive to read all communiques from the third-party fiduciary, and to ask and follow through on any questions or concerns.

None of these duties should be particularly onerous, especially if you have chosen a reputable external fiduciary. When considering such a company – as you should with all outside vendors – “test drive the car”: Find out all you can about several different ones, ask lots of questions, and make as informed a final decision as possible.

Learn more from Rich by watching the recorded webinar: “Innovative Retirement Plan Design for Maximum Results.”

About Rich Rausser:
Richard W. Rausser has over 25 years of experience in the retirement benefits field. He is Senior Vice President of Client Services at Pentegra Retirement Services, a leading provider of retirement planning services to financial institutions and organizations nationwide, founded by the Federal Home Loan Bank System in 1943. Rich oversees Pentegra’s consulting, marketing and communications and actuarial service groups at Pentegra. He is a frequent speaker on retirement benefit topics; a Certified Pension Consultant (CPC); a Qualified Pension Administrator (QPA); a Qualified 401(k) Administrator (QKA); and a member of the American Society of Pension Professionals and Actuaries (ASPPA).

Pentegra_Logo_FinalPentegra is the NAFCU Preferred Partner for Qualified Retirement Plans for Credit Union Employees

3 Critical Stages of Third-Party Vendor Management

By Vanessa Stanfield, Insurance Solutions powered by Affinion

Did you know your credit union could be responsible for the performance of your vendors? No credit union wants to encounter regulatory trouble or face reputational risk; especially as a result of vendor activities. It’s because of that fact that vendor management due diligence is a topic of increasing importance.

But what is the right way to go about choosing  third party vendor? The National Credit Union Administration (NCUA) has provided clear direction regarding vendor due diligence. Additionally, the NCUA has deemed the following areas as critical in third-party vendor management: Risk Assessment & Planning, Due Diligence, and Risk Measurement, Monitoring and Control.

Risk Assessment & Planning

Risk Assessment

Prior to engaging a third-party relationship, assess the current risks and document how the vendor will relate to your credit union’s strategic plan. When conducting a comprehensive risk assessment, the key areas of focus are: credit, interest rate, liquidity, transaction, compliance, strategy, and reputational risk. In this discovery phase, your credit union can identify the current risks and establish expectations of the new relationship.

Due Diligence

There are four fundamental due diligence elements to consider when choosing a vendor: organizational, business model, financial health, and program risks. In these areas, your credit union can assess what degree of due diligence is required.

But remember- not all vendors are created equal. More complex vendor relationships with more risk will typically require increased due diligence; less complexity and risk means less rigorous due diligence. For a comprehensive report and the five key due diligence questions you need to ask your vendors, read the full whitepaper here.

Risk Measurement, Monitoring and Control

Credit unions must be able to continually measure performance and risk throughout the relationship with the vendor. To do this, your credit union should clearly outline the vendor’s responsibilities and policies before taking on the vendor. In the end, this will allow for proper vendor performance management so that you can ensure expectations are being met.

Credit unions should not think of vendors as a third party, but as an extension of their organization. Because of this, it is important to consider the three critical areas above when deciding on a vendor. As the NCUA has conveyed, the utilization of vendors does not in any way diminish the credit union’s level of responsibility and for that reason, credit unions should carefully select their vendors.

What Should We Ask Our Vendors?

To be confident that the vendor’s management programs are the right fit, credit unions must discuss the vendor in great detail and ask the hard questions. Failure to conduct thorough due diligence and effectively monitor these vendors place the credit union at risk. Again, not all vendor relationships call for the same level of due diligence and ongoing monitoring, but in order to determine what level is necessary there are key questions that your credit union must contemplate.

For an in-depth look at the five key due diligence questions that credit unions must ask when selecting a third-party vendor, read the full whitepaper here.

InsuranceSolution_4CAffinion is the NAFCU Services Preferred Partner for AD&D Insurance

Adding LIFE To Your Credit Union

By Bryan Clagett, Chief Marketing Officer, Geezeo

Your members’ expectations evolve as they become more acclimated to technology, more financially stressed, and overburdened with life’s pace and demands. In case you have not noticed, the world is changing. Newly emerging competition is developing new bank-like products, and the definition of banking is evolving right before our eyes.

It’s time we step back and reevaluate how credit unions can provide more value.

Declaring you’re the financial partner for life is just not compelling, unless you have strong actions to back it up. Too often we forget that credit unions are enablers, and in fact have the ability to enable members to get the things they want and do the things they want to do.

With all the advances in technology, some things have not changed—like the basic needs of a household to address fundamental financial requirements, milestones, challenges and obligations. Life and money are inextricably linked whether we like it or not (or are willing to admit).

Importance of an Emotional Connection

The key for the credit union is to remain remarkably relevant throughout the “member” journey and to be there with logical products and services when members (or their households) could use them the most. Credit unions are missing very logical point-of-purchase opportunities, while not associating their products with the specific needs of a member at a specific, relevant time.

Don’t lose sight of the fact that people have an emotional connection to money and, perhaps more importantly, things and events. Emotion is a primary differentiator between transactions and a true relational connection, which (in my opinion) is the foundation of an engagement banking strategy.

How can you help a family prepare for a child’s education? How can you help a young couple get their first home? Can we help a couple plan a wedding? What’s the best way for me to get a car for my son? How do we help a family with a medical emergency? Can a bank resolve a small business’s cash crunch? In all of these examples, there are financial considerations and ramifications—and all present opportunities to credit unions.

Engagement Opportunities for Credit Unions

We need to put some LIFE into banking. LIFE is my acronym for “life infused financial experiences.” Milestones, like the examples above, represent obvious opportunities for credit unions to engage members and offer very relevant solutions while building deeper relationships and new levels of trust.

Life_weddingapp_geezeoWe have the data, the systems, the channels, and the people; we simply need to make sure we have the right solutions and services in place that will build systems and triggers that bring credit unions and their solutions to the forefront at the ideal time of need.

Now let’s try to put some ROI or business rationale around this. Bain and Company reports that members who are “emotionally connected” purchase 47% more than those who are simply “satisfied.” Members with a strong, committed relationship are 49% more likely to remain a member and twice as likely to recommend a retailer to friends and family. Bain also found companies that are loyalty leaders, grow revenue twice as fast as their competition and at a lower cost.

We should not fear disruption in the banking industry. However, we should recognize that life is disruptive, so we should find ways to reduce members’ financial pains. Credit unions have the chance to reduce friction while forming deeper emotional connections with members through recognizing and cultivating life infused financial experiences. This is a real opportunity for financial institutions and one that most industry disruptors don’t have the infrastructure or understanding to leverage.

Geezeo-A-Z-LogoGeezeo is the NAFCU Services Preferred Partner for Personal Financial Management (PFM). For more More educational resources and contact information are available at

Cybersecurity Ratings: The Third Party Cyber Risk Management Solution

BitSight Cyber Lock

So, you have identified your top partners.  You have thoroughly evaluated their cybersecurity services in order to keep your members’ financial data safe and secure. But before you sit back and relax, you have to ask yourself “what about tomorrow?”

The Pitfalls of Traditional Evaluation Methods for Cybersecurity

Traditional methods of evaluating your partners may include detailed questionnaires and conversations, audits, and maybe you have even conducted some vulnerability scans. These are all sound methods for establishing whether your partners are on the right track, but they are only a start.

  • One-time snapshot. The problem with this type of evaluation method is it only gives you a snapshot of the organization at one small point in time. It would be the equivalent of checking the locks on your doors once and then not doing it again in the future.
  • Expensive. Numerous questionnaires and audits can become very costly very quickly. If you are a small credit union, it may not seem practical to spend the cash or the manpower on these efforts.
  • Regulation struggle. In addition to an ethical obligation to your members, regulators are creating new legal obligations aimed at third party risk management plans. The sooner you can get in front of this issue, the easier it will be.

Vendors, especially high priority ones that have direct access to your network or your most sensitive data, really need to be monitored for their security practices all the time. This may seem daunting or even impossible, but it doesn’t have to be. The key to locking up holes in your partners’ security is through security rating and monitoring solutions.

How Cybersecurity Ratings Work

Cybersecurity ratings work essentially like a credit rating company issuing a FICO score, but instead it issues a security rating. For example, companies can be rated on a scale from 250 to 900. A high number indicates a strong security performance and a lower security risk.

A security rating platform gathers and analyzes publicly available information and noted incidents to create its security rating. It considers things like spam propagation, malware propagation, botnet infections, and then calculates a rating. You will also be able to see where the infections and incidents relating to a company’s security are occurring.

Utilizing Ratings as a Resource

BitSightRatings2Cybersecurity ratings can be a very useful tool in prioritizing which vendors require the most attention from your credit union. A company with a consistently high score probably doesn’t need a tremendous amount of your effort, so you can allocate your time and budget to the vendors that are creating greater risks for you and your members.

In addition, this rating can be a valuable resource when having a more sophisticated conversation with your vendors about cybersecurity. If you are grappling with what questions to ask or what risk vectors you should be focused on, the security rating information can give you a road map to do that.

web logo.bitsightNAFCU Services and BitSight Technologies have partnered to provide an independent security monitoring service that provides continuous data on outside vendors’ security practices. If you would like to learn more about BitSight’s solutions for credit unions, or formulating a third party risk management plan, you can check out our webinar here.

Cybersecurity Awareness Month: Confronting the Scariest Threats to Your Credit Union


October is National Cybersecurity Awareness Month which means it’s an excellent time to make sure there aren’t any unseen forces within your credit union that have nefarious plans for your members’ money.

Earlier this year, Wired Magazine wrote about the biggest cybersecurity threats for 2015. Three of these are indeed scary prospects for the credit union industry, but the key is to make sure you are doing everything you can to prevent these scenarios:

  • Data Destruction: Malware exists that erases data and boot records, so it is vitally important to make sure you have an excellent data backup plan.
  • Bank Card Breaches: This is a threat that isn’t going away any time soon, so it is important to be moving towards tokenization technologies to prevent this. NAFCU has partnered with MasterCard to help credit unions move towards this. For more information you can check out this webinar from earlier this year here.
  • Third Party Breaches: The data breach at Target stores is an excellent example of why you need a strong Third Party Risk Management Plan. For more information on this, check our recent webinar or blog posts here or here.

The costs of cyber threats are no joke to financial institutions big or small. According to the National Small Business Association, 44 percent of small businesses have been the victims of a cyber-attack. Clearly, it is worth the investment to review how sound your security is. The following tips from the Department of Homeland Security are an excellent place to start.

Cyberattack Prevention Tips and Practices

  • Have a plan. According to, 59% of small and medium size businesses in the United States do not have a plan that outlines procedures for responding and reporting data breach losses.  A number of these plans are covered in various compliance frameworks that may already exist, but as shelf ware.  If this describes you, now is the time to formulate both short and long term plans.
  • Utilize the latest software. Make sure you have antivirus and antispywear and update it regularly.
  • Educate. Make sure that all of your employees are aware Cybersecurity_KCGof cyber threats and educate them on the steps they must take to help combat these attacks.
  • Invest in data loss protection software, use encryption technologies to protect data in transit, and use two-factor authentication where possible.
  • Passwords. Use strong passwords throughout your organization and have employees change them regularly.

Who Should You Call?

What should you do if you’re unsure if your organization is prepared to navigate this threat landscape? If you are not sure where your cyber security threats may lie or even where you should be looking, consider going to an outside vendor. NAFCU and Knowledge Consulting Group (KCG) have partnered to provide comprehensive cybersecurity solutions.

KCG provides expert services in penetration testing and cybersecurity advisory services. Their tests offer simulation of potential attack vectors and scenarios most likely to impact the overall credit union environment, from IT systems to social engineering. They provide risk management, governance, operations, and compliance services to help credit unions navigate the complexities of the evolving cybersecurity landscape.

So take an inventory of your practices, make a plan, and evaluate where your weak spots are.

Knowledge Consulting Group is a subsidiary of ManTech International. For more detailed information on penetration testing or cybersecurity advisory services, visit KCG’s preferred partner page.