Written byMichael Dean AufmuthAgency Principal, Elite FI Partners
Operational review byEmilia AufmuthAgency Principal, Elite FI Partners
Before launch, compliance teams should verify the product’s legal structure, optional status, approved forms and language, eligibility and pricing controls, third-party responsibilities, employee authority, member documents, complaint and servicing paths, monitoring, change control, and evidence of end-to-end testing.
Compliance review should evaluate the complete lifecycle—not only the disclosure. The member conversation, technology workflow, contract, cancellation, refund, claim support, complaint handling, reporting, and provider changes all affect program risk.
Product and legal-structure questions
- What is the product under the contract and applicable law?
- Who is the obligor, provider, administrator, insurer, or backing party?
- Which forms, jurisdictions, assets, terms, and member situations are approved?
- What coverage, exclusions, limits, eligibility, cancellation, refund, and service rules are material?
- Which statements require legal or product-owner approval?
Member communication and choice questions
- Is the product clearly described as voluntary?
- Can the member decline without affecting loan approval or terms?
- Are total cost and financing effects shown accurately?
- Are important limitations presented before the decision?
- Are acceptance, decline, and document delivery retained?
- Can employees escalate questions rather than improvising?
Workflow and control questions
- Do eligibility, pricing, role, access, and jurisdiction controls prevent invalid contracts?
- Are common, boundary, correction, cancellation, and failure scenarios tested?
- Can records be reconciled across lending, contracting, provider, and accounting systems?
- Who can approve exceptions, suspend activity, or stop the program?
- How are changes evaluated, tested, approved, and communicated?
Post-closing service questions
- Where can members retrieve documents and support contacts?
- Who owns claims guidance, repair authorization, total-loss support, cancellations, refunds, and complaints?
- What timelines, evidence, status reporting, and escalation standards apply?
- How are unresolved cases and recurring member harm identified?
Governance and evidence questions
Before approval
Retain due diligence, legal review, decisions, conditions, forms, procedures, and test evidence.
At launch
Confirm trained roles, approved configurations, support paths, reporting, limits, and stop authority.
After launch
Review member and control indicators, provider performance, complaints, exceptions, changes, and corrective actions.
Official sources and further reading
These primary sources inform the program principles in this guide. They do not replace advice from the credit union’s own legal and compliance professionals.