Market code of conduct procedures
the credit union will follow the master policy on market code of conduct developed by CCU a effective 2020 the credit union will follow the basic principles of business practice customer service Excellency fair treatment and fair sales practices full access to banking services for fundamental financial services transparency and disclosure through use of plan language communications and fair complaint handling.
key procedure are as follows:
1 annually all steps are to receive a copy of credit unions market code of conduct policy and procedure
2 at least quarterly management meeting will be held to review key aspects of the code with all staff and discuss issues including how the credit union can do better.
3 annually the credit union will complete a self-assessment documenting the status of compliance with its code of market conduct this will include an action plan to correct weaknesses the document will be presented to the board.
4. management will ensure the reference to the code of conduct is included in the business plan under the heading of ways to ensure fair treatment as part of corporate culture or mission statement.
5. The board self assessment will include a session on compliance with the market code of conduct
6. the credit union will have a policy on protection of personal information and will annually confirm compliance with the PIPEDA act.
7. the cybersecurity framework will be adopted that assign responsibility for monitoring and overseeing effectiveness of the cybersecurity plan risk areas are to be identified and mitigated where possible or through use of compensating controls
8. a whistle blowing policy will be developed and communicated to staff board and the membership this may involved a suggestion box or a locked comments box only to be opened by the audit committee or internal auditor
9. the credit union will have add HR policy against discrimination by race sex gender and unfair treatment of members
10. the credit union will have a sales policy that indicates fair dealings are to occur without undue pressures tight selling unethical activity misrepresent patient of facts to members or conflict of interest
11. the HR policy will include a separate session on conflict of interest to be followed by all staff and board
12. Debt collection practices must be free of threats intimidation or unfair treatment
13. the credit union must not advise bank or banking without emphasizing that they are a credit union and not a bank her session 4.7 point one of the MCC
14. any products involving preferential pricing via rate or special waived fees must be transparent to all members the reason for the advantage must be reasonable and communicated
15. Express consent from members must be obtained for all changes made to agreements where the change was not previously documented this is to be verified by a supervisor
16. any digital product offering is to include her website the same reasonable person and fair treatment options for all transparency of information
17. all potential customers are to be granted fair access to all fundamental financial services
18. identification will be required for all new accounts following the FINTRAC filing requirements
19. The credit union will ensure all staff are trained on new accounts procedures following Finn track rules and credit rating lack of a job or a previous bankruptcy will not be used as reason to decline membership the new account procedure will not involve a loan approval the credit union should document the reason for the Denny and ensure it meets the session 3.2 exception list in the master policy the member must then be informed of the decline the second staff member is to verify the decline.
20. The membership must be treated fairly with respect to holds and the cashing of cheques. Limitations should be made available on a fact or account summary sheet that is available to the membership. staff are to be trained on those issues.
21. Low fee or no fee deposits should be offered to some members who are disadvantaged eligibility criteria for those accounts should be considered appropriate and fair any fee charges should also be considered appropriate and fair.
22. any limitations on access to funds or increases in holes should be fair reasonable and documented in all cases members are to be informed of any variations or restrictions to access must agree to section 3.5.2 of the MCC policy
23. Staff must be informed that government checks must be cashed if less than 1500 and if acceptable ID is provided and verifiable unless there is some evidence of fraud or tampering of the cheques or money order.
24. all new accounts for shares product advertisements and specials must be checked for plain language ease of understanding documented risk to the members and a lack of obscure or hidden statements as well all require legal information must be disclosed.
25. staff must be knowledgeable on all products and services and be available to respond to questions staff may be tested periodically on product knowledge.
26. all product circulars and brochures should receive a secondary check for planned language and accuracy.
27. the credit union should design A product fact sheet for all key products that will list key features in plain language.
28. members should receive turns and conditions for key products including a statement of activity. Additional statement may include a fee.
29. Should be provided for rate and service charge changed.
30. mortgage holders are to receive a cost of borrowing statement as well as a explanation of any penalties charged.
31. when any change to a fee global raid product benefit or service occurs the credit union will ensure that notice period to members meet the section 4.6 point one policy limitations. (i.e. 30 days)
32. the credit union will develop a complaint handling policy for resolving complaints the policy will document the name of the complaints officer and deputy the process of handling complaints include conflict resolution and escalation to a third party auditor or apartment the policy will be made available to members via the website or by in branch request record keeping of complaints follow up and resolution to the board will be made this procedure will be reviewed annually.