POLICY and PROCEDURE S MANUAL: Version - A friendly Credit ...€¦ · POLICY and PROCEDURE Version...

Swan Policy and Procedures Manual: Final Version 2.

POLICY and PROCEDURE

Version 2.0 of the manual was agreed at the board meeting held on 15 July 2015.Updates marked in red (paragraphs held on 19 November 2015.

CHAPTER 1 – GOVERNANCE AND ROLES

Introduction ................................

Aims and Objectives ................................

Policies and Procedures ................................

Organisation and structure of

Directors and Officers ................................

Identification and Control of Risks

Volunteers ................................

CHAPTER TWO – GENERAL MANAGEMENT

Qualification for admission to membership

Junior savers ................................

Committee of Management/Board

Monitoring Policy and Procedures

Conflicts of Interest ................................

Officer Functions ................................

Confidentiality ................................

Arrangement for succession

Internal Disputes ................................

Information Points ................................

Meetings of the Board of Directors

Monies Received ................................

Annual General Meetings ................................

Marketing and Branding. ................................

CHAPTER THREE – FINANCIAL MANAGEMENT

Designated Bank................................

Payments by the Credit Union

Payments to Members ................................

Payments by members to the Credit Union

Liquidity policy ................................

General Reserves ................................

Dividends ................................

Interest Rebate ................................

CHAPTER FOUR – SHARE AND DEPOSIT ACCOUNTS

Opening an Account ................................

Closing an Account ................................

edures Manual: Final Version 2.1 November 2015

POLICY and PROCEDURES MANUAL: Version

of the manual was agreed at the board meeting held on 15 July 2015.(paragraphs 72A and 91) were agreed at the Board meeting

19 November 2015.

CONTENTS

GOVERNANCE AND ROLES ................................................................

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Organisation and structure of Swan CU ................................................................

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Identification and Control of Risks ................................................................................................

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GENERAL MANAGEMENT ................................................................

Qualification for admission to membership ................................................................

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Committee of Management/Board ................................................................................................

Monitoring Policy and Procedures ................................................................................................

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Arrangement for succession ................................................................................................

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Meetings of the Board of Directors ...............................................................................................

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FINANCIAL MANAGEMENT ................................................................

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Payments by the Credit Union ................................................................................................

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Payments by members to the Credit Union ................................................................

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SHARE AND DEPOSIT ACCOUNTS ..............................................................

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sion 2.1

of the manual was agreed at the board meeting held on 15 July 2015. at the Board meeting

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Dormant Accounts ................................

Share Withdrawals ................................

CHAPTER FIVE – LOAN POLICY

Credit Committee ................................

Interest rates ................................

Life Insurance cover................................

Basis of loans ................................

Length of Loans ................................

Credit Committee ................................

Credit Control Policy ................................

Provisioning ................................

CHAPTER SIX – MONEY LAUNDERING

CHAPTER SEVEN – INTERNAL AUDIT

CHAPTER EIGHT – OTHER C

Training ................................

Information Technology ................................

Disaster Recovery and Business Continuity

Complaints Policy ................................

Equal Opportunities ................................

Death of a Member ................................

Annex 1: Procedures for Volunteers

Annex 2: Procedures for New Members

Annex 3: Procedures for Information Points

Annex 4: Complaints Procedures

Annex 5: A guide to the use of

Annex 6: Interest rates from December 2014


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LOAN POLICY ................................................................................................

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MONEY LAUNDERING ................................................................

INTERNAL AUDIT ................................................................

OTHER CU POLICIES ................................................................

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Disaster Recovery and Business Continuity ................................................................

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Annex 1: Procedures for Volunteers ................................................................................................

for New Members ................................................................

Annex 3: Procedures for Information Points ................................................................

Annex 4: Complaints Procedures................................................................................................

Annex 5: A guide to the use of personal information by Swan Credit Union ................................

Annex 6: Interest rates from December 2014 ................................................................

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Acronyms Used in this Document

CC Credit Committee

CCJ County Court Judgment

CRA Credit Reference Agencies

CRED The PRA/FCA regulatory manual for credit unions

CU Credit Union

CUS Credit Union Solutions Ltd, who provide back office services

FCA Financial Conduct Authority

FPA Fraud Prevention Agencies

MLRO Money Laundering Reporting Officer

P&P Policy and Procedures

PRA Prudential Regulatory Authority

SC Supervisory Committee

SOCA Serious Organised Crime Agency

SWAN Swan Credit Union Ltd

Terms used in this Document

Management Committee/Boarddocument. Company legislarequirements refer to the Committee of Management.

Loan officer – The person who has delegated authority to grant loans.Swan this is CUS Ltd.

Information Points – Partner organisations who have agreed to provide and advice on Swan Credit USwan Credit Union.

Administrator – An employee dealSwan this refers to staff of CUS Ltd.

Finance Officer - An employee dealing with the accounts and finances of the Credit Union. In the case of Swan this refers to staff of CUS Ltd.

Membership Officer - An empcase of Swan this refers to staff of CUS Ltd.


Acronyms Used in this Document

dit Committee

County Court Judgment

Credit Reference Agencies

The PRA/FCA regulatory manual for credit unions

Credit Union Solutions Ltd, who provide back office services

Financial Conduct Authority

Prevention Agencies

Money Laundering Reporting Officer

Policy and Procedures

Prudential Regulatory Authority

Supervisory Committee

Serious Organised Crime Agency

Swan Credit Union Ltd

used in this Document

Committee/Board – These terms are used interchangeably in this document. Company legislation refers to a Board of Directors. Regulatory requirements refer to the Committee of Management.

The person who has delegated authority to grant loans.

Partner organisations who have agreed to provide and advice on Swan Credit Union matters; or volunteer staffed points of contacts for

An employee dealing with routine administration. In the case of Swan this refers to staff of CUS Ltd.

An employee dealing with the accounts and finances of the Credit Union. In the case of Swan this refers to staff of CUS Ltd.

An employee dealing with membership applications. In the case of Swan this refers to staff of CUS Ltd.

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Credit Union Solutions Ltd, who provide back office services

These terms are used interchangeably in this irectors. Regulatory

The person who has delegated authority to grant loans. In the case of

Partner organisations who have agreed to provide information staffed points of contacts for

ing with routine administration. In the case of

An employee dealing with the accounts and finances of the Credit

loyee dealing with membership applications. In the


CHAPTER 1

Introduction

1. All credit unions are required under CRED.2.2.6implement an up-to-date and fully CREDS goes on to specify that this manual should cover all aspects of the credit union's operations, including matters such as:

(1) cash handling and disbursements;

(2) collection procedures;

(3) lending, including large exposures;

(4) arrears management;

(5) provisioning (see CREDS 7.5);

(6) liquidity management (see CREDS 6);

(7) financial risk management;

(8) money laundering prevention;

(9) internal audit;

(10) information technology;

(11) business continuity, otherwise known as disaster recovery

(12) marketing;

(13) training;

(14) connected persons and managing conflicts of interest

(15) complaints handling

2. This document aims to meet this requirement and will be continually kept up to date by the Board and Company Secretary. It and format as the separate Swan of policies and procedures of direct interest to our members. Key elements of our control procedures are also

Aims and Objectives

3. The objectives of Swan Cthe aims of Swan Credit Union are:

a. To develop a sustainable and selfcontrolled by its mem

b. To enable members to appreciate the principle of mutual help.

c. To enable members to discover the advantages of saving.

d. To enable members to borrow at fixed and affordable rates of interest.

e. To provide other financial services as de

Policies and Procedures

4. The Rules of Swan Credit Union can only be modified by a general meeting of members. Policies however are established, agreed and modified by the Board. The latest version of the Rules was approved by the


CHAPTER 1 – GOVERNANCE AND ROLES

ions are required under CRED.2.2.6 to establish, maintain, and date and fully documented policies and procedures manual

CREDS goes on to specify that this manual should cover all aspects of the credit union's operations, including matters such as:

(1) cash handling and disbursements;

(2) collection procedures;

g large exposures;

(4) arrears management;

(5) provisioning (see CREDS 7.5);

(6) liquidity management (see CREDS 6);

(7) financial risk management;

(8) money laundering prevention;

(10) information technology;

continuity, otherwise known as disaster recovery

(14) connected persons and managing conflicts of interest;

(15) complaints handling.

aims to meet this requirement and will be continually kept up to the Board and Company Secretary. It follows the same chapter heading

separate Swan Systems and Control Manual, but concentrates of policies and procedures of direct interest to our members. Key elements of our

rocedures are also included for completeness.

The objectives of Swan Credit Union are set out in rule 3. Within these objectives, he aims of Swan Credit Union are:

To develop a sustainable and self-financing financial co-operative, controlled by its members in a democratic way.

To enable members to appreciate the principle of mutual help.

To enable members to discover the advantages of saving.

To enable members to borrow at fixed and affordable rates of interest.

To provide other financial services as decided by the elected Board.

The Rules of Swan Credit Union can only be modified by a general meeting of members. Policies however are established, agreed and modified by the Board. The latest version of the Rules was approved by the AGM in March 2014

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to establish, maintain, and documented policies and procedures manual.

CREDS goes on to specify that this manual should cover all aspects of the credit

continuity, otherwise known as disaster recovery;

aims to meet this requirement and will be continually kept up to follows the same chapter heading

, but concentrates of policies and procedures of direct interest to our members. Key elements of our

redit Union are set out in rule 3. Within these objectives,

operative,

To enable members to appreciate the principle of mutual help.

To enable members to discover the advantages of saving.

To enable members to borrow at fixed and affordable rates of interest.

cided by the elected Board.

The Rules of Swan Credit Union can only be modified by a general meeting of members. Policies however are established, agreed and modified by the Board.

AGM in March 2014.


5. Policies help establish clear and wellpurpose and direction to those who carry out operational procedures. Policies limit authority in certain situations. Careful thought has been given to the foused, their practicality and common sense. Policies cannot be changed by staff or other committees and must always be followed unless changed by the Board.

6. The establishment of policies is the sole responsibility of the Board of Directors, acting in its collective role as the Credit Union’s guardian. The implementation of policy is usually carried out by staff and designated volunteers appointed by the Board of Directors.

7. Policies are part of the official records of the Credit Union. They will bas and when necessary but not less than once a year. All policies must be in accordance with the Rules of the Credit Union.

8. Operational procedures explain how the policies are implemented in practice. They can be written by staff or by codecisions on procedures to others if it wishes.are not delegated, and are agreed by the Board and included in various Annexes to this policy and procedures manual.

Organisation and structure

9. Our original name of Milton Keynes Credit Union Ltd was registered under the Industrial and Provident Societies Act with effect from 16 November 2005, registration number: 724C. It was granted permission by the Financial Services Authority under part IV of the Financial Services and Markets Act (2000) as an authorised person with effect from 21 November 2005. The FRN reference number is 417717.

10. The Financial Conduct AUnion Ltd and a change of its coThame on 12 September 2013.common bond to cover the whole of South Oxfordshire in September 2014.

11. Swan is governed by an elected Board of Directors also referred to by the regulators as a Committee of Management.

12. Administration, record keeping and member services are currently subcontracted to a back office cooperative called Credit Union Solutions As part of our contract with CUS they are obliged to hold qmeetings with client Credit Uservices provided.

13. Our back office service providers meetings every quarter to ensure that Board members have an opportunity to question them about services provided and discuss potential new developments.

Directors and Officers

14. Rule 107 requires a minimum of 5 members. 11 members. Swan CU will aim to have at least one member of the Board from the areas served by Aylesbury Vale Community Bank and one from Thame Community Bank. A minimum of three will be from the branch area of MK Community Bank. Election to these posts willwith Swan Credit Union


Policies help establish clear and well-defined instructions for action to give purpose and direction to those who carry out operational procedures. Policies limit authority in certain situations. Careful thought has been given to the foused, their practicality and common sense. Policies cannot be changed by staff or other committees and must always be followed unless changed by the Board.

The establishment of policies is the sole responsibility of the Board of Directors, ng in its collective role as the Credit Union’s guardian. The implementation of

policy is usually carried out by staff and designated volunteers appointed by the

Policies are part of the official records of the Credit Union. They will bas and when necessary but not less than once a year. All policies must be in accordance with the Rules of the Credit Union.

Operational procedures explain how the policies are implemented in practice. They can be written by staff or by committees, and the Board may delegate decisions on procedures to others if it wishes. At present operational procedures are not delegated, and are agreed by the Board and included in various Annexes to this policy and procedures manual.

Organisation and structure of Swan CU

Milton Keynes Credit Union Ltd was registered under the Industrial and Provident Societies Act with effect from 16 November 2005, registration number: 724C. It was granted permission by the Financial Services

part IV of the Financial Services and Markets Act (2000) as an authorised person with effect from 21 November 2005. The FRN reference

The Financial Conduct Authority agreed to a name change to Swan Credit Union Ltd and a change of its common bond to include Aylesbury Vale and Thame on 12 September 2013. The FCA subsequently agreed to extend our common bond to cover the whole of South Oxfordshire in September 2014.

Swan is governed by an elected Board of Directors also referred to by the regulators as a Committee of Management.

Administration, record keeping and member services are currently subcontracted to a back office cooperative called Credit Union Solutions As part of our contract with CUS they are obliged to hold quarterly stake

with client Credit Unions to inform and discuss developments in the

Our back office service providers will be invited to attend Swan Boarevery quarter to ensure that Board members have an opportunity to

question them about services provided and discuss potential new developments.

requires a minimum of 5 members. Board policy is for a maximum of members. Swan CU will aim to have at least one member of the Board from

Aylesbury Vale Community Bank and one from Thame Community Bank. A minimum of three will be from the branch area of MK Community Bank. Election to these posts will follow standard procedures in line

Union Rules.

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defined instructions for action to give purpose and direction to those who carry out operational procedures. Policies limit authority in certain situations. Careful thought has been given to the form of words used, their practicality and common sense. Policies cannot be changed by staff or other committees and must always be followed unless changed by the Board.

The establishment of policies is the sole responsibility of the Board of Directors, ng in its collective role as the Credit Union’s guardian. The implementation of

policy is usually carried out by staff and designated volunteers appointed by the

Policies are part of the official records of the Credit Union. They will be reviewed as and when necessary but not less than once a year. All policies must be in

Operational procedures explain how the policies are implemented in practice. oard may delegate

At present operational procedures are not delegated, and are agreed by the Board and included in various Annexes

Milton Keynes Credit Union Ltd was registered under the Industrial and Provident Societies Act with effect from 16 November 2005, registration number: 724C. It was granted permission by the Financial Services

part IV of the Financial Services and Markets Act (2000) as an authorised person with effect from 21 November 2005. The FRN reference

uthority agreed to a name change to Swan Credit mmon bond to include Aylesbury Vale and

agreed to extend our common bond to cover the whole of South Oxfordshire in September 2014.

Swan is governed by an elected Board of Directors also referred to by the

Administration, record keeping and member services are currently sub-contracted to a back office cooperative called Credit Union Solutions Ltd (CUS).

uarterly stakeholder nions to inform and discuss developments in the

invited to attend Swan Board every quarter to ensure that Board members have an opportunity to

question them about services provided and discuss potential new developments.

Board policy is for a maximum of members. Swan CU will aim to have at least one member of the Board from

Aylesbury Vale Community Bank and one from Thame Community Bank. A minimum of three will be from the branch area of MK

follow standard procedures in line


15. The Board will decide which directors and officers should perform which functions at least once per year. Where there are vacancies these functions will be carried out temporarily by someonemembers have collective responsibility for good governance, meeting legal and regulatory requirements.

16. The minimum roles and responsibilitiesrequired by the regulators

• Chair/President - Strategy, Business Plan, annual Risk reviews. To chair the Board of Directors monthly meetings and to act as the senior representative of the Credit Union with external organisations.

• Treasurer - To oversesign off the quarterly and annual return of financial accounts; To ensure financial audit requirements are metInformation to the Board, To exercise control of all expenditure, to maintaoversight and management of b

• Company Secretary, Legal & Regulatory Issues, PRA authorisations, recruitment of volunteers and Board members.

• Vice Chair - Deputising

• Credit Committee (1 person) Board on loan products, quarterly loan report to Board, approval ofdelegated loans.

17. Other roles and responsibilities relating to control separate Systems and Control Manual

Identification and Control of

18. The Board is collectively responsible for identification, management and review of all kinds of risks to the Credit Ufinancial, operational, reputational and external risks. The Chair of the Board will take lead responsileast once per year and more often when necessary.

19. Risks are identified and reviewed at the annual Board strategy meeting and subsequently documented in the annuthese risks is covered in our separate

Volunteers

20. All volunteers will be Credit Union members. All members will be informed at the time they join that opportunities exist for members to play a part in the running of the Creditmay exist within the Credit Union, and will be encouraged to participate in the running of their Credit Union.

21. Reasonable volunteer expenses will be payable.

Procedures to be followed for the


The Board will decide which directors and officers should perform which e per year. Where there are vacancies these functions will

be carried out temporarily by someone appointed by the Chair. All Bmembers have collective responsibility for good governance, meeting legal and regulatory requirements.

roles and responsibilities relating to the control functionsby the regulators are as follows:

Strategy, Business Plan, annual Risk reviews. To chair the Board of Directors monthly meetings and to act as the senior representative of the Credit Union with external organisations.

To oversee the financial affairs of the Credit Union. To check and sign off the quarterly and annual return of financial accounts; To ensure financial audit requirements are met; to present monthly Managemen

oard, To exercise control of all expenditure, to maintad management of bad debts.

Company Secretary, Legal & Regulatory Issues, PRA authorisations, recruitment of volunteers and Board members.

Deputising for and assisting the Chair.

Credit Committee (1 person) - Oversight of lending decisions, pucts, quarterly loan report to Board, approval of

ther roles and responsibilities relating to control functions are set oand Control Manual.

Identification and Control of Risks

The Board is collectively responsible for identification, management and w of all kinds of risks to the Credit Union business. These include

financial, operational, reputational and external risks. The Chair of the Board will take lead responsibility for this and ensure that these risks are reviewed as least once per year and more often when necessary.

Risks are identified and reviewed at the annual Board strategy meeting and subsequently documented in the annual business plan. The management of

is covered in our separate Systems and Control Manual

All volunteers will be Credit Union members. All members will be informed at the time they join that opportunities exist for members to play a part in the running of the Credit Union. They will be kept informed of vacancies which may exist within the Credit Union, and will be encouraged to participate in the running of their Credit Union.

Reasonable volunteer expenses will be payable.

to be followed for the recruitment of volunteers are set out in

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The Board will decide which directors and officers should perform which e per year. Where there are vacancies these functions will

. All Board members have collective responsibility for good governance, meeting legal and

the control functions

Strategy, Business Plan, annual Risk reviews. To chair the Board of Directors monthly meetings and to act as the senior representative of

nion. To check and sign off the quarterly and annual return of financial accounts; To ensure

onthly Management oard, To exercise control of all expenditure, to maintain

Company Secretary, Legal & Regulatory Issues, PRA authorisations,

f lending decisions, policy advice to ucts, quarterly loan report to Board, approval of non-

are set out in our

The Board is collectively responsible for identification, management and nion business. These include

financial, operational, reputational and external risks. The Chair of the Board bility for this and ensure that these risks are reviewed as

Risks are identified and reviewed at the annual Board strategy meeting and The management of

and Control Manual.

All volunteers will be Credit Union members. All members will be informed at the time they join that opportunities exist for members to play a part in the

Union. They will be kept informed of vacancies which may exist within the Credit Union, and will be encouraged to participate in the

are set out in Annex 1.


Confidentiality

22. The confidentiality of all financial and personal information about members and their account is guaranteed by the Credit Union Board and by its policies and procedures. All staff and voluntbe required to sign a confidentiality statement. We are signed up to the requirements of the Data Protection Act via our annualInformation Commissioner.

CHAPTER TWO


23. The qualification for admission toaccordance with Rule

24. In accordance with Ruleto membership once it has beequalification, have completed and submitted a membership application form, have provided sufficient evidence to prove their identity and address, and have purchased a minimum of a £1 share. membership fee is provided for under rule 17, but Board policy is not to charge these fees.

25. New corporate members must be approved by the Chair or Secretary to confirm that their membership is consistent with our stance as an ethical organisation. If there is any doubt then the application should be referred to the Board for a decision.

Procedures: Annex 2 sets out the members.

26. Rules 11 and 12 set out subsequently move outside of our common bond area (

Junior savers

27. The Credit Union will accept members under 16 as Junior Savers (in accordance with RuleSavers will not be eligible for loans. the level of interest to be paid to junior savers.

Committee of Management

28. Ultimate responsibility for safeguarding members’ funds and for the effective running of the Credit Union rests Management), whose responsibilities are set out in

29. To ensure all members of the Committee of Mto as the “Committee”) responsibilities, regular


The confidentiality of all financial and personal information about members and their account is guaranteed by the Credit Union Board and by its policies and procedures. All staff and volunteers with access to such infor

a confidentiality statement. We are signed up to the requirements of the Data Protection Act via our annual subscription to the

ommissioner.

CHAPTER TWO – GENERAL MANAGEMENT


The qualification for admission to membership of Swan Credit UnioRules 7 and 8.

Rule 17, applicants for membership will only be admitted to membership once it has been determined that they fulfil the common bond qualification, have completed and submitted a membership application form, have provided sufficient evidence to prove their identity and address, and

purchased a minimum of a £1 share. An entrance fee or amembership fee is provided for under rule 17, but Board policy is not to

New corporate members must be approved by the Chair or Secretary to confirm that their membership is consistent with our stance as an ethical

there is any doubt then the application should be referred to the Board for a decision.

sets out the procedures to be followed for signing up new

set out the procedures relating to members who ve outside of our common bond area (non-qualify members

The Credit Union will accept members under 16 as Junior Savers (in Rules 13 and 14) and will allow deposits up to £5

Savers will not be eligible for loans. The Board will from time to time determine the level of interest to be paid to junior savers.

Committee of Management/Board

Ultimate responsibility for safeguarding members’ funds and for the effective running of the Credit Union rests with the Board of Directors (Committee of

, whose responsibilities are set out in Rule 122.

To ensure all members of the Committee of Management (hereinafter referred to as the “Committee”) have a clear understanding of their roles and responsibilities, regular refresher training will be organised and trainin

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The confidentiality of all financial and personal information about members and their account is guaranteed by the Credit Union Board and by its policies

access to such information will a confidentiality statement. We are signed up to the

subscription to the

Credit Union shall, in

, applicants for membership will only be admitted n determined that they fulfil the common bond

qualification, have completed and submitted a membership application form, have provided sufficient evidence to prove their identity and address, and

An entrance fee or annual membership fee is provided for under rule 17, but Board policy is not to

New corporate members must be approved by the Chair or Secretary to confirm that their membership is consistent with our stance as an ethical

there is any doubt then the application should be referred to

procedures to be followed for signing up new

members who qualify members).

The Credit Union will accept members under 16 as Junior Savers (in ) and will allow deposits up to £5,000. Junior

The Board will from time to time determine

Ultimate responsibility for safeguarding members’ funds and for the effective Directors (Committee of

.

(hereinafter referred have a clear understanding of their roles and refresher training will be organised and training will be


arranged for all new Cappointment.


30. The Committee is required to operate within a legislative framework and so will need to monitor any changes in legislation and propose amendments to Credit Union Rules as appropriate. They will also monitor the effectiveness of procedures outlined in this Policy and Procedures Manual and will make amendments and additions as necessary so as tof the Credit Union in the best interests of its members. this are set out in our separate policy and procedures must be consistent with the Credit Union’s own and with current legislation. Any changes in policy will need to be agreed by a majority at a full and

Conflicts of Interest

31. In order to avoid accusations of preferential treatment or bias, all committee members will be required to declare any potential conflicts of described in Rules 135 and 136,questions affecting their own financial interests, or those of a close relative, are to be considered. Furthermore ancorporately or committee members individually will be considered to be a serious breach of the suspended and dealt with as defined under

32. The Secretary will maiBoard members.

33. To minimise the risk of one committee member influencing another member unduly, as far as is possible relatives or others in close relationships should not sit on the same committeeinterests of the Credit Union for this to happen, the related members in question should not constitute a majority on that committee.

Officer Functions

34. The Committee will ensure that job descriptionsthat all officers are made fully aware of their responsibilities. The Secretary and Training Officer will be responsible for supporting new officers in their role and arranging additional training for thewhen needed.

35. The Committee will review job descriptions on a regular basis, and no less than once a year, to ensure the workload and responsibilities expected of each member are realistic. Should changes in job descriptions be required, it is the responsibility of the Committee to ensure that all the essential roles and functions of the Credit Union are covered and incorporated into job descriptions.

36. The Committee will ensure that the apportionment and oversight functions are clearly allocated, with reapportioned. This function will normally be allocated to one or two people, but


arranged for all new Committee members within 6 months of their


The Committee is required to operate within a legislative framework and so monitor any changes in legislation and propose amendments to

s as appropriate. They will also monitor the effectiveness of procedures outlined in this Policy and Procedures Manual and will make amendments and additions as necessary so as to ensure the smooth running of the Credit Union in the best interests of its members. The procedures for this are set out in our separate Systems and Control Manual. policy and procedures must be consistent with the Credit Union’s own and with current legislation. Any changes in policy will need to be agreed by a

and quarate meeting of the management committee.

In order to avoid accusations of preferential treatment or bias, all committee will be required to declare any potential conflicts of

s 135 and 136, and withdraw from any discussion where questions affecting their own financial interests, or those of a close relative, are to be considered. Furthermore any attempt to influence the committee corporately or committee members individually will be considered to be a serious breach of the Rules of the Credit Union and the officer may be

nd dealt with as defined under Rule 132.

The Secretary will maintain a register of potential conflicts of interest

o minimise the risk of one committee member influencing another member unduly, as far as is possible relatives or others in close relationships should not sit on the same committee; however if it is deemed to be in the best interests of the Credit Union for this to happen, the related members in question should not constitute a majority on that committee.

The Committee will ensure that job descriptions for all roles are in place and that all officers are made fully aware of their allocated roles and

. The Secretary and Training Officer will be responsible for supporting new officers in their role and arranging additional training for the

The Committee will review job descriptions on a regular basis, and no less than once a year, to ensure the workload and responsibilities expected of each member are realistic. Should changes in job descriptions be required, it

sibility of the Committee to ensure that all the essential roles and functions of the Credit Union are covered and incorporated into job

The Committee will ensure that the apportionment and oversight functions are clearly allocated, with records showing how those responsibilities have been apportioned. This function will normally be allocated to one or two people, but

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ommittee members within 6 months of their

The Committee is required to operate within a legislative framework and so monitor any changes in legislation and propose amendments to

s as appropriate. They will also monitor the effectiveness of procedures outlined in this Policy and Procedures Manual and will make

o ensure the smooth running The procedures for

. Any changes in policy and procedures must be consistent with the Credit Union’s own Rules and with current legislation. Any changes in policy will need to be agreed by a

meeting of the management committee.

In order to avoid accusations of preferential treatment or bias, all committee will be required to declare any potential conflicts of interest as

and withdraw from any discussion where questions affecting their own financial interests, or those of a close relative,

y attempt to influence the committee corporately or committee members individually will be considered to be a

s of the Credit Union and the officer may be

of potential conflicts of interest for all

o minimise the risk of one committee member influencing another member unduly, as far as is possible relatives or others in close relationships should

; however if it is deemed to be in the best interests of the Credit Union for this to happen, the related members in

are in place and and

. The Secretary and Training Officer will be responsible for supporting new officers in their role and arranging additional training for them

The Committee will review job descriptions on a regular basis, and no less than once a year, to ensure the workload and responsibilities expected of each member are realistic. Should changes in job descriptions be required, it

sibility of the Committee to ensure that all the essential roles and functions of the Credit Union are covered and incorporated into job

The Committee will ensure that the apportionment and oversight functions are cords showing how those responsibilities have been

apportioned. This function will normally be allocated to one or two people, but


arrangements will be kept under constant review to ensure that they are operating effectively and changes made if necessary.

37. The Committee will also ensure that roles and responsibilities are properly segregated so that in general no one individual will be in a position to initiate, control and process a financial transaction. If such a situation is unavoidable then cross checks in the form of a second signature after the financial transaction will be put in place.

Confidentiality

All committee members, officers and volunteers will protect the confidentiality of member records and of CU financial transactions.

Procedures: See Annex 5


38. It is the duty of the Boardof key post holders including the Chair, Secretary, Treasurer, and Money Laundering Officer in their absence.

39. A three month period of notiofficer. This allows time to find a replacement and to train new officers. If an officer is unable to give notice then the Board will fill the vacancy on a temporary basis until the AGM, from one of their nu

40. The Credit CommitteeBoard Representativemember of the Credit Union to assist the Credit Committee if absent for a long period

41. It will be the Supervisory Committee’s Committee from the Credit Union membershipfilled within two months.

42. Vacancies on the Board or copting an experienced volunteeCU will in general be asked to shadow such positionbefore becoming Board or c

Internal Disputes

43. The Credit Union will address internal disputes through the application of the Complaints Policy set out in this manual and through the application of the Credit Union’s Rulessystems and controls.

Information Points

44. There will be public Information PointsBond area as required and as staffed by trained volunteers or trained members of the host organisation.

The Procedures and Services Available at these information points are set out in Annex 3.


arrangements will be kept under constant review to ensure that they are operating effectively and changes made if necessary.

The Committee will also ensure that roles and responsibilities are properly segregated so that in general no one individual will be in a position to initiate, control and process a financial transaction. If such a situation is unavoidable

in the form of a second signature after the financial transaction will be put in place.

All committee members, officers and volunteers will protect the confidentiality of member records and of CU financial transactions.

nnex 5.


Board to ensure that a deputy is able to carry out the roleof key post holders including the Chair, Secretary, Treasurer, and Money

in their absence.

A three month period of notice should be given before the resignation of any officer. This allows time to find a replacement and to train new officers. If an officer is unable to give notice then the Board will fill the vacancy on a temporary basis until the AGM, from one of their number.

The Credit Committee will maintain a membership of at least Board Representative. The Directors may by resolution designate another member of the Credit Union to assist the Credit Committee if absent for a long period of time.

Supervisory Committee’s responsibility to fill any vacancy Committee from the Credit Union membership. Any such vacancy should be filled within two months.

Vacancies on the Board or committees, between AGMs will be filled opting an experienced volunteer. Suitable recruits without experience of the

will in general be asked to shadow such positions for a period ofbefore becoming Board or committee members.

The Credit Union will address internal disputes through the application of the Complaints Policy set out in this manual and through the application of the

s. Details are given in the separate documentation on systems and controls.

Information Points for the Credit Union within the Common Bond area as required and as agreed by the Board. All Information Pointsstaffed by trained volunteers or trained members of the host organisation.

and Services Available at these information points are set out in

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arrangements will be kept under constant review to ensure that they are

The Committee will also ensure that roles and responsibilities are properly segregated so that in general no one individual will be in a position to initiate, control and process a financial transaction. If such a situation is unavoidable

in the form of a second signature after the financial

All committee members, officers and volunteers will protect the confidentiality of

to ensure that a deputy is able to carry out the roles of key post holders including the Chair, Secretary, Treasurer, and Money

ce should be given before the resignation of any officer. This allows time to find a replacement and to train new officers. If an officer is unable to give notice then the Board will fill the vacancy on a

will maintain a membership of at least one including the The Directors may by resolution designate another

member of the Credit Union to assist the Credit Committee if the officer is

responsibility to fill any vacancy on their . Any such vacancy should be

ommittees, between AGMs will be filled by co-Suitable recruits without experience of the

s for a period of time

The Credit Union will address internal disputes through the application of the Complaints Policy set out in this manual and through the application of the

. Details are given in the separate documentation on

for the Credit Union within the Common Information Points will be

staffed by trained volunteers or trained members of the host organisation.

and Services Available at these information points are set out in



45. The Board of Directors (Committee of Management) is required to meet monthly. The Secretary will notify Odate, venue or of any special meetings. The Secretary will be charged with the responsibility of making accommodation arrangements, together with the provision of minutes, reports and information required by the Board.

46. At its first meeting after thedate for the remainder of the financial year.

47. Members of the Supervisory Committee have an open invitation to attend monthly Board meetings. From time to time, the President (Chair), in consultation with the Board, may invite guest speakers to Board meetings to share experiences with the elected officers.

48. Directors who are unable to attend meetings of the BoSecretary in sufficient time in advance of the meeting.

Monies Received

49. Monies received from members shall be by Standing Order, cheque, cashPayPoint) or any other appropriate payment system with the agreement of the Board. The Treasurer will

50. CUNA Mutual Insurance Society paymentsbeneficiary, but will also be reported to the Board of Directors.

Annual General Meetings

51. The Secretary will coan organising committee for this purpose.January and March of each year, depending on the availability of audited accounts.

52. The Secretary will present recommendations for the Annual General Meeting, which will include:

• Date, time and venue.

• The agenda.

• Guest speaker, if there is to be one.

• Refreshments.

• Public address facilities if required.

• Budget requirements.

• Publicity.

53. Prior to the AGM the Board may appoint a nominating committee of three members to ensure there is at least one candidate for each vacancy on the Board of Directors, Credicommittee will automatically dissolve at the close of the AGM.

54. Ballot forms shall be prepared by the Secretary prior to the date of the AGM.



The Board of Directors (Committee of Management) is required to meet hly. The Secretary will notify Officers and Directors of any cha

or of any special meetings. The Secretary will be charged with the responsibility of making accommodation arrangements, together with the provision of minutes, reports and information required by the Board.

At its first meeting after the AGM, the new Board will agree a regular meeting date for the remainder of the financial year.

Members of the Supervisory Committee have an open invitation to attend monthly Board meetings. From time to time, the President (Chair), in

he Board, may invite guest speakers to Board meetings to share experiences with the elected officers.

Directors who are unable to attend meetings of the Board should notify the Secretary in sufficient time in advance of the meeting.

received from members shall be by Standing Order, cheque, cashor any other appropriate payment system with the agreement of the

Board. The Treasurer will oversee monies received from other sources.

Mutual Insurance Society payments will be processed to the beneficiary, but will also be reported to the Board of Directors.

The Secretary will co-ordinate the arrangements for the AGM and may appoint an organising committee for this purpose. The AGM will be held bJanuary and March of each year, depending on the availability of audited

he Secretary will present recommendations for the Annual General Meeting,

Date, time and venue.

Guest speaker, if there is to be one.

Refreshments.

Public address facilities if required.

Budget requirements.

Prior to the AGM the Board may appoint a nominating committee of three members to ensure there is at least one candidate for each vacancy on the Board of Directors, Credit and Supervisory Committees. The nominating committee will automatically dissolve at the close of the AGM.

Ballot forms shall be prepared by the Secretary prior to the date of the AGM.

of 29

The Board of Directors (Committee of Management) is required to meet fficers and Directors of any change of

or of any special meetings. The Secretary will be charged with the responsibility of making accommodation arrangements, together with the provision of minutes, reports and information required by the Board.

AGM, the new Board will agree a regular meeting

Members of the Supervisory Committee have an open invitation to attend monthly Board meetings. From time to time, the President (Chair), in

he Board, may invite guest speakers to Board meetings to

ard should notify the

received from members shall be by Standing Order, cheque, cash (via or any other appropriate payment system with the agreement of the

monies received from other sources.

will be processed to the beneficiary, but will also be reported to the Board of Directors.

ordinate the arrangements for the AGM and may appoint The AGM will be held between

January and March of each year, depending on the availability of audited

he Secretary will present recommendations for the Annual General Meeting,

Prior to the AGM the Board may appoint a nominating committee of three members to ensure there is at least one candidate for each vacancy on the

t and Supervisory Committees. The nominating committee will automatically dissolve at the close of the AGM.

Ballot forms shall be prepared by the Secretary prior to the date of the AGM.


Marketing and Branding.

55. Only the Board of Directors has authority to anames, subject to approval from the FCA where requiredgeographic trading names are:

• MK Community Bank

• Thame Community Bank

• Didcot Community Bank

• Aylesbury Vale Community Bank

56. All publicity materials will follow a common design template including a singtelephone number, email and FThere will be a board member appointed with responsibility for external publicity whom will be responsible for approving marketing material for use.

57. There will be a single company website pUnion. Local domain names may These sites will link directly to the main single website. No content will be displayed on the satellite sites.names locally advertised will be owned and managed bywhole.

CHAPTER THREE

Designated Bank

58. The Credit Union’s current account(s) will be held with the Co


59. The detailed control procedures and separation of functions for made by the Credit Union

Payments to Members

60. Payments to members must be made by cheque wisignatures, by electronic bank transfer

61. Should another person wipermission from the member and verification of the recipient’s identity will be required before any such payment will be made.

62. Payments to members not collected within three weeks of authorisation will be cancelled. Payments issued to members and not cashed within 60 days may be cancelled. Payments made by cheque and lost in transit will be cancelled by telephone and confirmed in writing by the Treasurer to the Bank.

63. Members will be required to sign the relevant docAgreement before the


he Board of Directors has authority to approve local geographic trading , subject to approval from the FCA where required. The current local

geographic trading names are:

MK Community Bank, a branch of Swan Credit Union;

Thame Community Bank, a branch of Swan Credit Union;

ty Bank, a branch of Swan Credit Union; and

Aylesbury Vale Community Bank, a branch of Swan Credit Union

All publicity materials will follow a common design template including a singtelephone number, email and Facebook address for customer enquiries. here will be a board member appointed with responsibility for external

publicity whom will be responsible for approving marketing material for use.

There will be a single company website providing information about the Credit nion. Local domain names may be used to reflect the trading names in use.

These sites will link directly to the main single website. No content will be displayed on the satellite sites. The rights to the main website and all domain names locally advertised will be owned and managed by the company as a

CHAPTER THREE – FINANCIAL MANAGEMENT

The Credit Union’s current account(s) will be held with the Co


The detailed control procedures and separation of functions for made by the Credit Union are set out in our Systems and Control Manual

Payments to members must be made by cheque with duly authorised by electronic bank transfer or by pre-paid debit card

Should another person wish to receive a member’s payment, written permission from the member and verification of the recipient’s identity will be required before any such payment will be made.

Payments to members not collected within three weeks of authorisation will be . Payments issued to members and not cashed within 60 days may

be cancelled. Payments made by cheque and lost in transit will be cancelled by telephone and confirmed in writing by the Treasurer to the Bank.

Members will be required to sign the relevant documentation, i.e. Loan Agreement before the funds are released. Requests for share withdrawals

of 29

pprove local geographic trading . The current local

;

, a branch of Swan Credit Union; and

, a branch of Swan Credit Union.

All publicity materials will follow a common design template including a single acebook address for customer enquiries.

here will be a board member appointed with responsibility for external publicity whom will be responsible for approving marketing material for use.

roviding information about the Credit be used to reflect the trading names in use.

These sites will link directly to the main single website. No content will be The rights to the main website and all domain

the company as a

FINANCIAL MANAGEMENT

The Credit Union’s current account(s) will be held with the Co-operative Bank.

The detailed control procedures and separation of functions for payments and Control Manual.

th duly authorised paid debit card.

sh to receive a member’s payment, written permission from the member and verification of the recipient’s identity will be

Payments to members not collected within three weeks of authorisation will be . Payments issued to members and not cashed within 60 days may

be cancelled. Payments made by cheque and lost in transit will be cancelled by telephone and confirmed in writing by the Treasurer to the Bank.

umentation, i.e. Loan Requests for share withdrawals


made online via the secure membersthey are made to a bank acco

64. Cheques for members to cash will be made out to the member and opened by writing ‘Pay to Cash’ across the tramlines and signed by both signatories to the cheque. An agreement will be reached with a bank or post osuch cheques. The Bank or Post Office willidentity before cashing such cheques.


65. Members will be able to make payments to as Direct Debit, Standing Order, Payroll Deductionsof PayPoint.

66. All members have the right to request a Pay Point card in which to make cash payments. No cash will be handled at

Liquidity policy

67. The Treasurer and Finvestments, deposit and current accounts to ensure that the minimum liquidity requirements under CRED

General Reserves

68. It is the intention of the Board to increase10% of total assets in the shortest possible time.

Dividends

69. The Board of Directorsaccordance with rulesdividend rate equivalent to the best available savings accounts provided by other financial institutions,

Interest Rebate

70. If after the application of transfers to the dividend, an un-appropriated surplus exists, the Board will consider the payment of a rebate on loan interest paymeninterest paid during the year.

CHAPTER FOUR

Opening an Account

71. There is no charge for joining encouraged to save a minimum of £10 per month but not required to do Every member properly accepted onto the registry of members will be given a regular share account with a unique number. If the member leaves and rejoins


via the secure members’ area do not require signature, provided they are made to a bank account previously notified to the Credit

embers to cash will be made out to the member and opened by writing ‘Pay to Cash’ across the tramlines and signed by both signatories to the cheque. An agreement will be reached with a bank or post o

The Bank or Post Office will require members to show proof of identity before cashing such cheques.


Members will be able to make payments to Swan Credit Union byDirect Debit, Standing Order, Payroll Deductions and cash through th

All members have the right to request a Pay Point card in which to make cash cash will be handled at Information Points.

The Treasurer and Finance Officer will manage the Credit Union’s deposit and current accounts to ensure that the minimum

quirements under CREDS are met.

It is the intention of the Board to increase reserves to a minimum equivalent to 10% of total assets in the shortest possible time.

he Board of Directors will consider the payment of dividendsaccordance with rules 71-75. It is the intention of the Board to reach a dividend rate equivalent to the best available savings accounts provided by

tutions, up to the maximum allowed in our

If after the application of transfers to the Reserves and the payment of a appropriated surplus exists, the Board will consider the

payment of a rebate on loan interest payments (rule 76) of up to 15% of interest paid during the year.

CHAPTER FOUR – SHARE AND DEPOSIT ACCOUNTS

re is no charge for joining Swan Credit Union. New members are encouraged to save a minimum of £10 per month but not required to do Every member properly accepted onto the registry of members will be given a regular share account with a unique number. If the member leaves and rejoins

of 29

’ area do not require signature, provided redit Union.

embers to cash will be made out to the member and opened by writing ‘Pay to Cash’ across the tramlines and signed by both signatories to the cheque. An agreement will be reached with a bank or post office to cash

require members to show proof of

Credit Union by means such and cash through the use

All members have the right to request a Pay Point card in which to make cash

will manage the Credit Union’s deposit and current accounts to ensure that the minimum

eserves to a minimum equivalent to

s to members in It is the intention of the Board to reach a

dividend rate equivalent to the best available savings accounts provided by up to the maximum allowed in our Rules.

and the payment of a appropriated surplus exists, the Board will consider the

of up to 15% of

SHARE AND DEPOSIT ACCOUNTS

Credit Union. New members are encouraged to save a minimum of £10 per month but not required to do so. Every member properly accepted onto the registry of members will be given a regular share account with a unique number. If the member leaves and rejoins


they will retain their original number. No account will be opened until the member has purchased th

72. Every member will be alloSwan Credit Union accountinternet. Paper copies of statements will be issued at least once per year allowing members to verify their balances.

72A. The maximum value of FCA/PRA regulations (currently £15,000)

Procedures for signing up new members are set out in

Closing an Account

73. The Credit Union reserves the right to ask for up to 60 days’ notice before a member withdraws their shares.

74. The Treasurer or Credit Commshares (shares that cannot be withdrawn because of a loan) to meet a member’s liability or shares held as a guarantee for another member’s loan.

Dormant Accounts

75. Rules 30-34 cover Dormant accounts. The Board andthat the annual fee for such accounts should be £5.00. this purpose are those accounts with shares of had no activity within them for the last twelve inclusive monthssubsequently the Treasurer

76. All dormant account holderscharge would be made unless they reactivate their account within a 6 period. If during that period the accouncharged. If there are insufficient funds in the account to meet this charge the account would be closed.

77. The Credit Union will not take this action against members who hold a small share balance, but who contribute in sthe Credit Union. The Credit Union does not wish to penalise those who play a part in the life of the Credit Union, but wants the right to take action where the costs of operating an account exceed a member’s share bathere is no activity.

Share Withdrawals

78. Members can withdraw all or part of their shares provided that it does not take the member outside the 5 working days. However the Board of Directors reserves the right to ask for up to 60 days notice, if there is a heavy demand for share withdrawals.

79. Share withdrawals can be made withdrawal form or through the secure online member’s area on the Credit Union website. If members to do not have access to the internet then they can visit one of ourprovided with internethardcopy.


they will retain their original number. No account will be opened until the member has purchased the minimum of a £1 share.

Every member will be allowed to check the balance and transactions of accounts during normal business hours by telephone or

Paper copies of statements will be issued at least once per year members to verify their balances.

value of shares permitted will be as specified in the latest FCA/PRA regulations (currently £15,000).

for signing up new members are set out in Annex 2.

The Credit Union reserves the right to ask for up to 60 days’ notice before a member withdraws their shares.

The Treasurer or Credit Committee may authorise the writing-shares (shares that cannot be withdrawn because of a loan) to meet a member’s liability or shares held as a guarantee for another member’s loan.

34 cover Dormant accounts. The Board and members have agreed that the annual fee for such accounts should be £5.00. Dormant accounts

are those accounts with shares of less than £50.00had no activity within them for the last twelve inclusive months

Treasurer has deemed as such.

ll dormant account holders will be notified once per year, advising them that a charge would be made unless they reactivate their account within a 6 period. If during that period the account is not re-activated a fee

there are insufficient funds in the account to meet this charge the account would be closed.

The Credit Union will not take this action against members who hold a small share balance, but who contribute in some way to the life and development of the Credit Union. The Credit Union does not wish to penalise those who play a part in the life of the Credit Union, but wants the right to take action where the costs of operating an account exceed a member’s share balance and where

Members can withdraw all or part of their shares provided that it does not take the Loan Policy. Share withdrawals will usually take up to

5 working days. However the Board of Directors reserves the right to ask for up to 60 days notice, if there is a heavy demand for share withdrawals.

can be made either by completion of the printethrough the secure online member’s area on the

Credit Union website. If members to do not have access to the internet then our Information Points during opening ho

provided with internet access to complete the online share withdrawal form or

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they will retain their original number. No account will be opened until the

check the balance and transactions of their by telephone or

Paper copies of statements will be issued at least once per year

will be as specified in the latest

The Credit Union reserves the right to ask for up to 60 days’ notice before a

-off of pledge shares (shares that cannot be withdrawn because of a loan) to meet a member’s liability or shares held as a guarantee for another member’s loan.

members have agreed Dormant accounts for

.00, which have had no activity within them for the last twelve inclusive months, and which

, advising them that a charge would be made unless they reactivate their account within a 6 weeks

activated a fee would be there are insufficient funds in the account to meet this charge the

The Credit Union will not take this action against members who hold a small ome way to the life and development of

the Credit Union. The Credit Union does not wish to penalise those who play a part in the life of the Credit Union, but wants the right to take action where the

lance and where

Members can withdraw all or part of their shares provided that it does not take Share withdrawals will usually take up to

5 working days. However the Board of Directors reserves the right to ask for up to 60 days notice, if there is a heavy demand for share withdrawals.

either by completion of the printed share through the secure online member’s area on the Swan

Credit Union website. If members to do not have access to the internet then during opening hours, and will be

to complete the online share withdrawal form or


80. Members with outstanding loans of more than the value of their shares be eligible to withdraw their sharespermitted within the limits of loan policy.

More details are set out in our s

CHAPTER FIVE

Credit Committee

81. All Loan decisions up to a maximum value of £2,500 less than 70) are delegated to Credit Union Solutionsinformation on loan decisions.

82. The Credit Committee, subject to business, must meet or otherwise confer at least once a month and more frequently if necessary. If tapprove then a meeting will not be necessary.

83. The Credit Committee will have a strategic role in monitoring lending decisionsand process as well as proactively analysing the data to make recommendations to the Board on improvements toas well as informing marketing

84. The normal turnaround receipt of application to approval, but funds will not be issued until a signed loan agreement has been received. A receiving payment in advance of this period. IfPolicy, more time will be required as it wouldBoard of Directors for approval.

85. In the case of a genuine personal ospeed up the process, but this cannot be guaranteed.

Interest rates

86. Interest will be charged at rates between 1% and 3% per month on the outstanding loan balance calculated on a daily basper year by the Board.

Details of current interest rates are set out in our separate Systems and Control Manual

87. Interest on loans in arrears by more than 3 months will be frozen. If the member starts repaying before accrued will be added back to their account

Life Insurance cover

88. Loans will be covered by the current Loan Protection Insurance limit, and be available free of charge to members under the age of 69. Upon death of the member the loan balance up to that amount will be cleared if the member was eligible for cover when the loan was granted.


with outstanding loans of more than the value of their shares be eligible to withdraw their shares. However share to loan transfers are permitted within the limits of loan policy.

More details are set out in our separate Systems and Control Manual

CHAPTER FIVE – LOAN POLICY

up to a maximum value of £2,500 (if the memless than 70) are delegated to Credit Union Solutions, who will provide monthly information on loan decisions.

The Credit Committee, subject to business, must meet or otherwise confer at least once a month and more frequently if necessary. If there are no loans to approve then a meeting will not be necessary.

The Credit Committee will have a strategic role in monitoring lending decisionsand process as well as proactively analysing the data to make recommendations to the Board on improvements to lending policy or practices, as well as informing marketing.

turnaround time for processing of loan applications is 7receipt of application to approval, but funds will not be issued until a signed loan agreement has been received. A member should place no reliance on receiving payment in advance of this period. If the loan falls outside Loans

more time will be required as it would need to be submitted to the Board of Directors for approval.

In the case of a genuine personal of family emergency, we will endeavour to speed up the process, but this cannot be guaranteed.

Interest will be charged at rates between 1% and 3% per month on the outstanding loan balance calculated on a daily basis and reviewed at least onper year by the Board.

Details of current interest rates are set out in Annex 6. Proceduresand Control Manual.

Interest on loans in arrears by more than 3 months will be frozen. If the member starts repaying before court action is initiated then the frozen interest accrued will be added back to their account.

Loans will be covered by the current Loan Protection Insurance limit, and free of charge to members under the age of 69. Upon death of the

member the loan balance up to that amount will be cleared if the member was when the loan was granted.

of 29

with outstanding loans of more than the value of their shares will not However share to loan transfers are

and Control Manual.

(if the member is aged who will provide monthly

The Credit Committee, subject to business, must meet or otherwise confer at here are no loans to

The Credit Committee will have a strategic role in monitoring lending decisions and process as well as proactively analysing the data to make

lending policy or practices,

time for processing of loan applications is 7 days from receipt of application to approval, but funds will not be issued until a signed

member should place no reliance on the loan falls outside Loans

need to be submitted to the

f family emergency, we will endeavour to

Interest will be charged at rates between 1% and 3% per month on the is and reviewed at least one

Procedures are set out in

Interest on loans in arrears by more than 3 months will be frozen. If the court action is initiated then the frozen interest

Loans will be covered by the current Loan Protection Insurance limit, and will free of charge to members under the age of 69. Upon death of the

member the loan balance up to that amount will be cleared if the member was


89. Members aged 70 or abovebe one of the factors considered by the Credit Cor not to grant the loan.

Basis of loans

90. No loan will be considered without a completed Loan Application form and no loan will be issued without a signed Loan Agreementto regular savers rather than those who make lump sum payments.

91. The maximum loans available will beregulations (currently £by the PRA.

92. Members can apply to borrow up to thrloans subject to credit checks and bank statements and history of Credit Committee may apply specific loans if it considers it prudent to do so.

93. For all loan applications for over £1,with a credit reference agenc

94. All members granted loans will be expected to continue to save something on a regular basis, in addition to repayment of their loan.

95. The Credit Committee substantiate the statements made on the application form and if necessary will make further enquiries on the financial status of the applicant.

96. Members can re-finance or ‘top up’ their loans within policy ucircumstances:

• The top-up loan does not take the member outside loan policy.

• There have been no significant missed payments.

• If the top-up loan moves the total outstanding amount into another interest rate band then the higher rate will

97. Paper copies of loan members to verify their balances.

Length of Loans

98. All unsecured loans must and not exceeding 60guarantor) may be repaid over ten

99. All guarantors must be members of the Credit Union and that part of their shares used as guarantee cannot be withdrawn during the guarantee period.Other type of security will not be acceptable.

Credit Committee

100. Decisions on the issuing of loans will be subject to the availability of funds and Credit Committee or appropriate reasonable, provident & productive purpose will be


Members aged 70 or above will not be covered by life insurance, and the factors considered by the Credit Committee in deciding whether

or not to grant the loan.

No loan will be considered without a completed Loan Application form and no loan will be issued without a signed Loan Agreement. Preference will be given to regular savers rather than those who make lump sum payments.

The maximum loans available will be as specified in the latest FCA/PRA £15,000), subject to the maximum net exposure permitted

Members can apply to borrow up to three times their savings (shares) for loans subject to credit checks and bank statements and history of Credit Committee may apply a savings to loan ratios of less than 3:1specific loans if it considers it prudent to do so.

applications for over £1,000, we will in most cases with a credit reference agency.

All members granted loans will be expected to continue to save something on a regular basis, in addition to repayment of their loan.

The Credit Committee or Loan Officer may also request more evidence to substantiate the statements made on the application form and if necessary will make further enquiries on the financial status of the applicant.

finance or ‘top up’ their loans within policy under the following

up loan does not take the member outside loan policy.

There have been no significant missed payments.

up loan moves the total outstanding amount into another interest rate band then the higher rate will be charged.

loan statements will be issued at least once per year allowing members to verify their balances.

must be repaid over a period of not less than 12 months not exceeding 60 months. Loans with security (including these rantor) may be repaid over ten years (maximum).

All guarantors must be members of the Credit Union and that part of their shares used as guarantee cannot be withdrawn during the guarantee period.

ty will not be acceptable.

Decisions on the issuing of loans will be subject to the availability of funds and or appropriate approval. Only loans for legal, personal,

reasonable, provident & productive purpose will be considered.

of 29

will not be covered by life insurance, and this will ommittee in deciding whether

No loan will be considered without a completed Loan Application form and no . Preference will be given

to regular savers rather than those who make lump sum payments.

as specified in the latest FCA/PRA , subject to the maximum net exposure permitted

ee times their savings (shares) for all loans subject to credit checks and bank statements and history of saving. The

of less than 3:1 for

in most cases conduct checks

All members granted loans will be expected to continue to save something on

may also request more evidence to substantiate the statements made on the application form and if necessary will make further enquiries on the financial status of the applicant.

nder the following

up loan does not take the member outside loan policy.

up loan moves the total outstanding amount into another

statements will be issued at least once per year allowing

of not less than 12 months including these having a

All guarantors must be members of the Credit Union and that part of their shares used as guarantee cannot be withdrawn during the guarantee period.

Decisions on the issuing of loans will be subject to the availability of funds and approval. Only loans for legal, personal,

considered.


101. The Credit Committee may refer loan aLoans to other Credit Unions will always be considered by the Board.

102. Applications of loans related persons are cove

Details of the procedures for dealing with loan appseparate Systems and Control

Credit Control Policy

103. Delinquency (Bad Debt) can erode the assets of the Credit Union and devalue the share holding of members. It is the responsibility of the Board to ensure that delinquent loans are pursued and dealt with.

104. The CU will endeavour to take account of member percircumstances when dealing with loans in arrears and will be as flexible as possible within the constraints of protecting the interests of its members as a whole.

Our agreed procedures for dealing with loans in arrearsSystems and Control Manual

Provisioning

105. In accordance with FCAprovision of 35% of the net liability of delinquent loans over 3 months and up to 12 months and 100% provision of the net liability of deamount is 12 months or more in arrears. the optional higher rates recommended by FCAmonths in arrears and 80% for loans 9

106. An additional provision of 2% will be made on all other unsecured loans.

107. Loans will be automatically written off when they become 12 months in arrears and provisioning reduced accordingly.

CHAPTER SIX

108. It is a requirement in law and the policy of the Creditfinancial regime, which will deter the illegal use of the Credit Union as a place to hide illicit gains. All new members will be alerted to the existence of this policy via publicity and training for volunteers.

109. The Credit Union will appwhose name will remain confidential to the Board.

110. This officer will be empowered to review bank statements of the Credit Union without notice to other officers. The MLROunexpected (upward) changes in levels of savings and one off or periodic large deposits to savings or early repayment of loans. The MLRO will be


The Credit Committee may refer loan applications to the Board of Directors. Loans to other Credit Unions will always be considered by the Board.

of loans from Directors, Officers of the Credit Union and any are covered by rules 63 to 65.

for dealing with loan applications are set out in ouontrol Manual.

Delinquency (Bad Debt) can erode the assets of the Credit Union and devalue the share holding of members. It is the responsibility of the Board to ensure that delinquent loans are pursued and dealt with.

The CU will endeavour to take account of member personal and financial circumstances when dealing with loans in arrears and will be as flexible as possible within the constraints of protecting the interests of its members as a

agreed procedures for dealing with loans in arrears are set out in ouand Control Manual.

accordance with FCA Rules, the Credit Union will make a minimum provision of 35% of the net liability of delinquent loans over 3 months and up to 12 months and 100% provision of the net liability of delinquent loans where the amount is 12 months or more in arrears. The Board have decided to also apply

higher rates recommended by FCA as follows: 60% for loans 3in arrears and 80% for loans 9-12 months in arrears.

sion of 2% will be made on all other unsecured loans.

Loans will be automatically written off when they become 12 months in arrears visioning reduced accordingly.

CHAPTER SIX – MONEY LAUNDERING

It is a requirement in law and the policy of the Credit Union to create a financial regime, which will deter the illegal use of the Credit Union as a place to hide illicit gains. All new members will be alerted to the existence of this policy via publicity and training for volunteers.

The Credit Union will appoint a Money Laundering Reporting Officer (MLRO), hose name will remain confidential to the Board.

This officer will be empowered to review bank statements of the Credit Union without notice to other officers. The MLRO will in particular take note of unexpected (upward) changes in levels of savings and one off or periodic large deposits to savings or early repayment of loans. The MLRO will be

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pplications to the Board of Directors. Loans to other Credit Unions will always be considered by the Board.

from Directors, Officers of the Credit Union and any

set out in our

Delinquency (Bad Debt) can erode the assets of the Credit Union and devalue the share holding of members. It is the responsibility of the Board to ensure

sonal and financial circumstances when dealing with loans in arrears and will be as flexible as possible within the constraints of protecting the interests of its members as a

are set out in our separate

the Credit Union will make a minimum provision of 35% of the net liability of delinquent loans over 3 months and up to

linquent loans where the The Board have decided to also apply

as follows: 60% for loans 3-6

sion of 2% will be made on all other unsecured loans.

Loans will be automatically written off when they become 12 months in arrears

Union to create a financial regime, which will deter the illegal use of the Credit Union as a place to hide illicit gains. All new members will be alerted to the existence of this

dering Reporting Officer (MLRO),

This officer will be empowered to review bank statements of the Credit Union will in particular take note of

unexpected (upward) changes in levels of savings and one off or periodic large deposits to savings or early repayment of loans. The MLRO will be


empowered to seek clarification from any member of the Credit Union in the course of investigating any relevant matter.

111. If any member or volunteer of the Credit Union has any concern that the funds being provided to, or from, the Credit Union are from, or for, illegal activities, those concerns must be detailed in writing to the MLRoffice of the Credit Union. Any information supplied will be dealt with in the strictest confidence.

112. Where the MLRO has any cause for concern, he/she is required to report the matter directly to the Serious Organised Crime Office (SOCO)Directors will be advised without any names being divulged.

113. Directors will report annually to the Annual General Meeting on work of the MLRO.

CHAPTER SEVEN

114. The Board of Directors (Management Committee) will be responsible fseeing that Internal Control systems are in place to ensure:

a) That the books of account and records (including computer records) fairly reflect the Credit Union’s affairs with respect to its transactions, assets and liabilities.

b) That the Credit Union’s a

c) Supervision of the Credit Union’s cash holdings, receipts and payments.

d) There are limited opportunities to defraud the Credit Union.

115. The three principal elements of Internal Control are a Plan of Organisation (with a proper functioning Board of Directors, Credit Committee, Supervisory Committee and Annual Meeting of Members), Operational Control bBoard of Directors, and

116. The Committee responsible for Internal Audit is the Supervisory Committee, which will be appointed at the Annual General Meeting and will report on a regular basis to the Board of Directors, the members and the external Auditor as and when they consider appropriate.

117. Members of the Supervisory Committee cannot be involved in any type of operational practice. They will have no executive power, and cannot set policy, but they will have responsibility for ensuring that agreed policies are implemented. They also have a responsibility to confirm that records and FSA returns are accurate and up tofrom which they were written up and to confirm their validity.

118. At the AGM the Supervisory Committee will report to members reflecting the work carried out during the financial year.

119. If the Supervisory Committee reBoard approval will be sought for any necessary expenditure incurred.


empowered to seek clarification from any member of the Credit Union in the rse of investigating any relevant matter.

If any member or volunteer of the Credit Union has any concern that the funds being provided to, or from, the Credit Union are from, or for, illegal activities, those concerns must be detailed in writing to the MLRO at the registered office of the Credit Union. Any information supplied will be dealt with in the

Where the MLRO has any cause for concern, he/she is required to report the matter directly to the Serious Organised Crime Office (SOCO)Directors will be advised without any names being divulged.

Directors will report annually to the Annual General Meeting on work of the

CHAPTER SEVEN – INTERNAL AUDIT

The Board of Directors (Management Committee) will be responsible fseeing that Internal Control systems are in place to ensure:

That the books of account and records (including computer records) fairly reflect the Credit Union’s affairs with respect to its transactions, assets and

That the Credit Union’s assets are properly safeguarded.

Supervision of the Credit Union’s cash holdings, receipts and payments.

There are limited opportunities to defraud the Credit Union.

The three principal elements of Internal Control are a Plan of Organisation functioning Board of Directors, Credit Committee, Supervisory

Committee and Annual Meeting of Members), Operational Control bBoard of Directors, and Internal Audit.

The Committee responsible for Internal Audit is the Supervisory Committee, be appointed at the Annual General Meeting and will report on a

regular basis to the Board of Directors, the members and the external Auditor as and when they consider appropriate.

Members of the Supervisory Committee cannot be involved in any type of rational practice. They will have no executive power, and cannot set

policy, but they will have responsibility for ensuring that agreed policies are implemented. They also have a responsibility to confirm that records and FSA returns are accurate and up to date and to examine documentary evidence from which they were written up and to confirm their validity.

At the AGM the Supervisory Committee will report to members reflecting the work carried out during the financial year.

If the Supervisory Committee requires outside assistance in fulfilling its duties, Board approval will be sought for any necessary expenditure incurred.

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empowered to seek clarification from any member of the Credit Union in the

If any member or volunteer of the Credit Union has any concern that the funds being provided to, or from, the Credit Union are from, or for, illegal activities,

O at the registered office of the Credit Union. Any information supplied will be dealt with in the

Where the MLRO has any cause for concern, he/she is required to report the matter directly to the Serious Organised Crime Office (SOCO). The Board of

Directors will report annually to the Annual General Meeting on work of the

The Board of Directors (Management Committee) will be responsible for

That the books of account and records (including computer records) fairly reflect the Credit Union’s affairs with respect to its transactions, assets and

Supervision of the Credit Union’s cash holdings, receipts and payments.

There are limited opportunities to defraud the Credit Union.

The three principal elements of Internal Control are a Plan of Organisation functioning Board of Directors, Credit Committee, Supervisory

Committee and Annual Meeting of Members), Operational Control by the

The Committee responsible for Internal Audit is the Supervisory Committee, be appointed at the Annual General Meeting and will report on a

regular basis to the Board of Directors, the members and the external Auditor

Members of the Supervisory Committee cannot be involved in any type of rational practice. They will have no executive power, and cannot set

policy, but they will have responsibility for ensuring that agreed policies are implemented. They also have a responsibility to confirm that records and FSA

date and to examine documentary evidence

At the AGM the Supervisory Committee will report to members reflecting the

quires outside assistance in fulfilling its duties, Board approval will be sought for any necessary expenditure incurred.


120. Swan CU will aim to have afrom outside of the branch area covered by MK Community Bank

More details of the SC responsibilities and Systems and Control Manual

CHAPTER EIGHT

Training

121. The Board will ensure that every individual involved in the management or running of the Credit Union will have the necessary skills and training to carry out their functions effectively.

122. To this end the Credit Union will appoint a Training Officer, whoseresponsibilities will include:

a. Reviewing the training needs of all officers and workers involved in the Credit Union on a quarterly basis andcourses to address any learning deficiencies.

b. Developing and delivering training cinvolved in the Credit Union and arranging training for delivery by external agencies as appropriate.

c. Developing and delivering introductory training courses for new volunteers and new members of the Cvolunteers will receive training before they start work at aPoint, and new Board members will be trained within the first six months of joining the Board.

d. Attending training courses with external agencies, including other Credit Unions, to review organisational practice and to ensure the Credit Union is operating to the highest possible standards.

e. Reporting to the Board undertaken by committee members and volunteers and on those individuals who n

f. Recording the details of all courses and training received by individuals and lodging this information on their personal file.

123. The Board will ensure that funds are raised both from internal and external sources and allocated to ass

124. The Board will review its training needs at least annually, based on a report from the Training Officer, and will determine the minimum level of training acceptable for volunteers and committee members tfunctions.

125. The Training Officer will be responsible for ensuring that detailed training records are maintained for all volunteers, committee members and staff and


Swan CU will aim to have at least one member of the Supervisory branch area covered by MK Community Bank

responsibilities and procedures are set out in our separate and Control Manual.

CHAPTER EIGHT – OTHER CU POLICIES

The Board will ensure that every individual involved in the management or running of the Credit Union will have the necessary skills and training to carry out their functions effectively.

To this end the Credit Union will appoint a Training Officer, whoseresponsibilities will include:

Reviewing the training needs of all officers and workers involved in the edit Union on a quarterly basis and arranging appropriate training

courses to address any learning deficiencies.

Developing and delivering training courses to meet the needs of those involved in the Credit Union and arranging training for delivery by external agencies as appropriate.

Developing and delivering introductory training courses for new unteers and new members of the Committee. Information

volunteers will receive training before they start work at a, and new Board members will be trained within the first six months

of joining the Board.

Attending training courses with external agencies, including other Credit , to review organisational practice and to ensure the Credit Union

is operating to the highest possible standards.

Reporting to the Board as necessary on the courses and training undertaken by committee members and volunteers and on those individuals who need additional training.

Recording the details of all courses and training received by individuals and lodging this information on their personal file.

The Board will ensure that funds are raised both from internal and external sources and allocated to assist in the training of new officers and volunteers.

The Board will review its training needs at least annually, based on a report from the Training Officer, and will determine the minimum level of training acceptable for volunteers and committee members to carry out specific

The Training Officer will be responsible for ensuring that detailed training records are maintained for all volunteers, committee members and staff and

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t least one member of the Supervisory Committee branch area covered by MK Community Bank.

are set out in our separate

The Board will ensure that every individual involved in the management or running of the Credit Union will have the necessary skills and training to carry

To this end the Credit Union will appoint a Training Officer, whose

Reviewing the training needs of all officers and workers involved in the arranging appropriate training

ourses to meet the needs of those involved in the Credit Union and arranging training for delivery by

Developing and delivering introductory training courses for new Information Point

volunteers will receive training before they start work at an Information , and new Board members will be trained within the first six months

Attending training courses with external agencies, including other Credit , to review organisational practice and to ensure the Credit Union

on the courses and training undertaken by committee members and volunteers and on those

Recording the details of all courses and training received by individuals

The Board will ensure that funds are raised both from internal and external ist in the training of new officers and volunteers.

The Board will review its training needs at least annually, based on a report from the Training Officer, and will determine the minimum level of training

o carry out specific

The Training Officer will be responsible for ensuring that detailed training records are maintained for all volunteers, committee members and staff and


will notify relevant individuals and the committee, when refresher trainadditional specialist training is needed.

Information Technology

126. Our goal is to provide the Board and the committees of the Swan Credit Union with timely and accurate information at reasonable cost, however to achieve this, we will only utilise ITreliable and secure.

127. Where appropriate we will use internet hosted solutions which improve the accessibility and availability of information for our members but at all times, our overarching priority is all the client data that is being held.

Further details are given in our separate

Disaster Recovery and Business Continuity

See our separate Systems and Control Manual

Complaints Policy

128. The Board will appoint a Complaints O

129. A complaint is any expression of dissatisfaction, whether written or oral, about a service that the Credit Union has provided or failed to provide and has resulted in a financial loss, distressloss or inconvenience to occur.

130. The Credit Union asserts its right to make appropriate decisions about any area of its operations in accordance with the Procedures Manual.

131. Complaints can only be made by:

a. A Credit Union member or Junior Sor Junior Saver.

b. A nominated beneficiary

c. A business with which the Credit Union has dealings.

Procedures: Details of the agreed complaints procedures are set out in

132. If the Complaints Officer feels it is appropriate, the complainant should be offered an amount no greater than £50. If an amount greater than £50 is considered appropriate, the decision

133. If a complainant is still dissatisfied following receipt of the final response, the complaint may appeal to the Financial Ombudsman Service (FOS) within six months of the final response from co-operate with any investigation undertaken by the FOS.

Equal Opportunities

134. Swan Credit Union Ltd is committed to ensuring that all individuals are treated fairly and valued equally and that all laws and regulations relating to discrimination are followed. The Credit Union’s policies will be governed by


will notify relevant individuals and the committee, when refresher trainadditional specialist training is needed.

Our goal is to provide the Board and the committees of the Swan Credit Union with timely and accurate information at reasonable cost, however to achieve this, we will only utilise IT solutions which have been tested and proven to be

Where appropriate we will use internet hosted solutions which improve the accessibility and availability of information for our members but at all times, our overarching priority is to ensure the confidentiality, security and integrity of all the client data that is being held.

Further details are given in our separate Systems and Control Manual

and Business Continuity

tems and Control Manual.

oard will appoint a Complaints Officer.

A complaint is any expression of dissatisfaction, whether written or oral, about a service that the Credit Union has provided or failed to provide and has resulted in a financial loss, distress or inconvenience or the potential for such loss or inconvenience to occur.

The Credit Union asserts its right to make appropriate decisions about any area of its operations in accordance with the Rules and the Policy and

only be made by:

A Credit Union member or Junior Saver, or potential or former member

A nominated beneficiary or personal representative of (a

A business with which the Credit Union has dealings.

: Details of the agreed complaints procedures are set out in

If the Complaints Officer feels it is appropriate, the complainant should be no greater than £50. If an amount greater than £50 is

considered appropriate, the decision will be referred to the Board.

If a complainant is still dissatisfied following receipt of the final response, the complaint may appeal to the Financial Ombudsman Service (FOS) within six months of the final response from Swan Credit Union. The Credit Unio

operate with any investigation undertaken by the FOS.

Credit Union Ltd is committed to ensuring that all individuals are treated fairly and valued equally and that all laws and regulations relating to

ollowed. The Credit Union’s policies will be governed by

of 29

will notify relevant individuals and the committee, when refresher training and

Our goal is to provide the Board and the committees of the Swan Credit Union with timely and accurate information at reasonable cost, however to achieve

solutions which have been tested and proven to be

Where appropriate we will use internet hosted solutions which improve the accessibility and availability of information for our members but at all times,

to ensure the confidentiality, security and integrity of

and Control Manual

A complaint is any expression of dissatisfaction, whether written or oral, about a service that the Credit Union has provided or failed to provide and has

or inconvenience or the potential for such

The Credit Union asserts its right to make appropriate decisions about any s and the Policy and

potential or former member

or personal representative of (a) above.

: Details of the agreed complaints procedures are set out in Annex 4.

If the Complaints Officer feels it is appropriate, the complainant should be no greater than £50. If an amount greater than £50 is

will be referred to the Board.

If a complainant is still dissatisfied following receipt of the final response, the complaint may appeal to the Financial Ombudsman Service (FOS) within six

. The Credit Union will

Credit Union Ltd is committed to ensuring that all individuals are treated fairly and valued equally and that all laws and regulations relating to

ollowed. The Credit Union’s policies will be governed by


this commitment in dealing with its own work force, volunteers, officers, members, and with all those with whom the Credit Union has contact or dealings.

135. This Equal Opportunities policy and principleCredit Union Ltd will do its best to provide an example of good practice to the community at large.

136. The Credit Union will oppose discrimination against any individual or group specifically on grounds of race, ethnic origin, reimpairment, gender, sexual orientation or marital status, social class, HIV status, age, appearance or size, or on any other unjustified grounds. Nowhether member, volunteer, officreceive less favourable treatment, or will be disadvantaged by unjustifiable requirements or conditions.

137. Where discrimination occurs on the basis of race, colour, disability or impairment, sex/marital status or trade union membership, individuals hathe right to appeal through the Board and retain the right for further appealthe Financial Ombudsman

Death of a Member

138. On the death of a member, the Credit Union will be guided by the recommended procedures from ABCUL, when deciding on the allocatiany savings or associated insurance funds.


this commitment in dealing with its own work force, volunteers, officers, members, and with all those with whom the Credit Union has contact or

This Equal Opportunities policy and principles will apply to all,Credit Union Ltd will do its best to provide an example of good practice to the

The Credit Union will oppose discrimination against any individual or group specifically on grounds of race, ethnic origin, religion or creed, disability or impairment, gender, sexual orientation or marital status, social class, HIV status, age, appearance or size, or on any other unjustified grounds. Nowhether member, volunteer, official or employee of Swan Credit Union Ltreceive less favourable treatment, or will be disadvantaged by unjustifiable requirements or conditions.

Where discrimination occurs on the basis of race, colour, disability or impairment, sex/marital status or trade union membership, individuals hathe right to appeal through the Board and retain the right for further appealthe Financial Ombudsman.

On the death of a member, the Credit Union will be guided by the recommended procedures from ABCUL, when deciding on the allocatiany savings or associated insurance funds.

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this commitment in dealing with its own work force, volunteers, officers, members, and with all those with whom the Credit Union has contact or

s will apply to all, and Swan Credit Union Ltd will do its best to provide an example of good practice to the

The Credit Union will oppose discrimination against any individual or group ligion or creed, disability or

impairment, gender, sexual orientation or marital status, social class, HIV status, age, appearance or size, or on any other unjustified grounds. No-one,

Credit Union Ltd will receive less favourable treatment, or will be disadvantaged by unjustifiable

Where discrimination occurs on the basis of race, colour, disability or impairment, sex/marital status or trade union membership, individuals have the right to appeal through the Board and retain the right for further appeal to

On the death of a member, the Credit Union will be guided by the recommended procedures from ABCUL, when deciding on the allocation of


Annex 1: Procedures for

Recruitment

1. Vacancies for volunteer positwebsite, and through third parties throughout the Common Bond A

2. Applicants for Controlleapproved person’s form for submission to the Financial Conduct Authority.

3. All vacant positions will have a job description and person specification.

4. All potential volunteers will be required to compleform, and will be subsequently respond within 5 working days to enquiries

5. All potential volunteers will be interviewed by a Band selected on the basis orequirements.

6. Where volunteers want to help out with for the respective branch

7. References will be taken up prior to a personresponsibility of the recruiting officer to check references

Management & Support for Volunteers

8. A single database of voresponsible for recruitment should updating details on volunteers maintained on Dropbox.

9. A training session will be held at least every

10. It is the responsibility of the recruiting Bvolunteer has the right induction support for them to effectively.

11. Volunteers will receive regular email updates on Credit U

12. Reasonable volunteer expenses will be payable.


1. The best and simplest way for prospective members to join is to use ourautomated on-line website joining form. Automatic ID checks are carried out on such applications based on name, address, National Insurance number etc.

2. If successful then these automated checks meet our legal obligations under the Money Laundering Act andata are unable to be fully validated then CUS will contact the member to provide the necessary ID information.


nnex 1: Procedures for Volunteers

Vacancies for volunteer positions will be advertised on the Credit Uh third parties throughout the Common Bond A

ontrolled Function posts will be asked to complete an approved person’s form for submission to the Financial Conduct Authority.

All vacant positions will have a job description and person specification.

All potential volunteers will be required to complete the online volunteering form, and will be subsequently directed to the relevant Board memberrespond within 5 working days to enquiries.

teers will be interviewed by a Board member and selected on the basis of their skills, experience and time to fulfil the post

Where volunteers want to help out with a specific branch then the lead contact for the respective branch will be responsible for recruitment.

References will be taken up prior to a person being appointed.responsibility of the recruiting officer to check references.

Management & Support for Volunteers

A single database of volunteers will be maintained on Dropbox. responsible for recruitment should updating details on the database of volunteers maintained on Dropbox.

training session will be held at least every 12 months for all volunteers.

sponsibility of the recruiting Board member to ensure that the volunteer has the right induction support for them to carry out their role

ceive regular email updates on Credit Union news.

Reasonable volunteer expenses will be payable.


The best and simplest way for prospective members to join is to use ourline website joining form. Automatic ID checks are carried out on

such applications based on name, address, National Insurance number etc.

If successful then these automated checks meet our legal obligations under the Money Laundering Act and the member can be contacted to start saving. If the data are unable to be fully validated then CUS will contact the member to provide the necessary ID information.

of 29

ions will be advertised on the Credit Union h third parties throughout the Common Bond Area.

unction posts will be asked to complete an approved person’s form for submission to the Financial Conduct Authority.

All vacant positions will have a job description and person specification.

te the online volunteering oard member who will

oard member or other officer f their skills, experience and time to fulfil the post

specific branch then the lead contact

being appointed. It is the

ropbox. The officer the database of

months for all volunteers.

oard member to ensure that the carry out their role

nion news.

The best and simplest way for prospective members to join is to use our line website joining form. Automatic ID checks are carried out on

such applications based on name, address, National Insurance number etc.

If successful then these automated checks meet our legal obligations under the d the member can be contacted to start saving. If the

data are unable to be fully validated then CUS will contact the member to provide


3. Prior to commencing to save, records of prospective members will be coded CUS as status waiting (W). They will only become members and coded as Active (A) once they start to save

4. Non-qualifying, but active

New members at Information Points

5. Volunteers signing up new memautomated system. Should the prospective member prefer a paper and mail system then volunteers are necessary to ensure that applicants are eligible to join the Cthat our money laundering policy is being followed.

a) Accept and check that the Application Fdated.

b) Check that applicant's details comply with eligibility for membership.

c) Explain the reason for a nominee, if

d) Check documentation for ID

• One document to prove documents.

• One document to prove acceptable documents.

Note: If a document for the address and vice versa.

e) Copy the ID documents and annotate each copy to indicate you have seen the original documents.

f) Collect a completed Standing Order form

g) Post the documents

h) Explain that a usually within 10 working days

6. If the original ID documents hasign and date the copies to say that the originals have been seen. If the original documents have not been seen, then an additional computer check on ID will be carried out by CUS Ltd on receipt of the copies.

7. If an applicant is unable to can normally find an alternative way to establish the identity and/or address e.g. we could accept a letter from a third party who is in a responsible position and who knows the applicant.

8. New members can also form (available on our website or from our information pointsID directly to CUS. In these cases an additional computer based ID check will be carried out to ensure that regulations.

Foreign nationals

9. Passports from European Union (EU) or European Economic Area (EEA) countries do not need to be accompanied by a visa:


Prior to commencing to save, records of prospective members will be coded waiting (W). They will only become members and coded as Active

(A) once they start to save.

but active members will be coded by CUS as G on the database.

Information Points

signing up new members should recommend use of the above onautomated system. Should the prospective member prefer a paper and mail system then volunteers should follow the procedures below. These procedures are necessary to ensure that applicants are eligible to join the CU and to ensure that our money laundering policy is being followed.

Accept and check that the Application Form is fully completed, signed and

Check that applicant's details comply with eligibility for membership.

Explain the reason for a nominee, if appropriate.

Check documentation for ID - A minimum of two documents is

One document to prove identity – see below for list of acceptable documents.

One document to prove address – see below for list of acceptable documents.

Note: If a document is being used for identity it cannot also be used for the address and vice versa.

Copy the ID documents and annotate each copy to indicate you have seen the original documents.

a completed Standing Order form or request a Pay Point card

ocuments to CUS Ltd.

Explain that a Welcome Pack and membership number will be sent 10 working days.

If the original ID documents have been seen, then the volunteer should endorse, sign and date the copies to say that the originals have been seen. If the original documents have not been seen, then an additional computer check on ID will be carried out by CUS Ltd on receipt of the copies.

If an applicant is unable to obtain and present the documents required, the CU can normally find an alternative way to establish the identity and/or address e.g. we could accept a letter from a third party who is in a responsible position and who knows the applicant.

also directly join by post, by sending the completed website or from our information points) and photocopies of

ID directly to CUS. In these cases an additional computer based ID check will be carried out to ensure that Swan Credit Union is compliant with money laundering

Passports from European Union (EU) or European Economic Area (EEA) countries do not need to be accompanied by a visa:

of 29

Prior to commencing to save, records of prospective members will be coded by waiting (W). They will only become members and coded as Active

G on the database.

should recommend use of the above on-line automated system. Should the prospective member prefer a paper and mail

. These procedures U and to ensure

orm is fully completed, signed and

Check that applicant's details comply with eligibility for membership.

of two documents is required.

see below for list of acceptable

see below for list of

is being used for identity it cannot also be used

Copy the ID documents and annotate each copy to indicate you have

or request a Pay Point card.

and membership number will be sent

should endorse, sign and date the copies to say that the originals have been seen. If the original documents have not been seen, then an additional computer check on ID will be

obtain and present the documents required, the CU can normally find an alternative way to establish the identity and/or address e.g. we could accept a letter from a third party who is in a responsible position and

sending the completed application and photocopies of

ID directly to CUS. In these cases an additional computer based ID check will be compliant with money laundering

Passports from European Union (EU) or European Economic Area (EEA)


EU Countries: Austria, Belgium, Bulgaria, Denmark, Estonia, Finland, France, Germany, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom.

EEA Countries: Norway, Iceland, Lichtenstein. Switzerland an EEA country.

10. Passports from countries other than EU or EEA countries should be accompanied by a valid and unexpired visa. Collectors should photocopy the visa, sign copy of visa to certify they have seen the original, and send to other documents.

Other procedures for new members

11. There is a separate application form for special arrangements for establishingoriginal birth certificate is acceptable. We will also need a letter from a parent or from their head teacher.

12. Some applicants may have different names on their passport from that in other ID documentation. In such cases a marriage documentation will be required to link the current name with the name by which applicant was previously known.

13. The Board has delegated approval of membership to a Membership Oreserves the right to refuse an aapplication; any shares deposited will be refunded.

ID requirements

14. The Credit Union exists so that area can support each other, saving their money together and lenother at affordable rates ofnot all know each other personally, so it is important we can verify that people are who they say they are. We also have to comply with money laundering regulations.

15. We therefore need to see at least two documents, one to prove identity and one to prove address. Examples of acceptable documents are as follows:

16. Identification documents should contain a current photo ID issued by an appropriate authority. For example:

• Current signed Passport (with valid unexpired visa for non EEA countries)

• Current driving license with photo

• Current EU National Identity Card

• HM Forces ID Card

17. If you do not have ID as above, please provide two other forms of ID from the lisbelow:

• National Insurance card

• Current driving license (paper)

• Benefit book


: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Gibraltar, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom.

ay, Iceland, Lichtenstein. Switzerland is treated as if it were

Passports from countries other than EU or EEA countries should be accompanied by a valid and unexpired visa. Collectors should photocopy the visa, sign copy of

they have seen the original, and send to CUS Ltd with copies of

Other procedures for new members

There is a separate application form for junior accounts (under 16) and there are special arrangements for establishing ID and address – for applicantoriginal birth certificate is acceptable. We will also need a letter from a parent or

head teacher.

Some applicants may have different names on their passport from that in other ID documentation. In such cases a marriage certificate or other change of name documentation will be required to link the current name with the name by which applicant was previously known.

ed approval of membership to a Membership Othe right to refuse an application. Should the Board decide to reject an

any shares deposited will be refunded.

The Credit Union exists so that people who live or work in the Common Barea can support each other, saving their money together and lenother at affordable rates of interest. Obviously, in an area as large as oursnot all know each other personally, so it is important we can verify that people are who they say they are. We also have to comply with money laundering

We therefore need to see at least two documents, one to prove identity and one to prove address. Examples of acceptable documents are as follows:

Identification documents should contain a current photo ID issued by an For example:

Current signed Passport (with valid unexpired visa for non EEA

Current driving license with photo

Current EU National Identity Card

HM Forces ID Card

If you do not have ID as above, please provide two other forms of ID from the lis

National Insurance card

Current driving license (paper)

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us, Czech Republic, , Greece, Hungary,

Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom.

treated as if it were

Passports from countries other than EU or EEA countries should be accompanied by a valid and unexpired visa. Collectors should photocopy the visa, sign copy of

with copies of

accounts (under 16) and there are applicants under 16,

original birth certificate is acceptable. We will also need a letter from a parent or

Some applicants may have different names on their passport from that in other ID certificate or other change of name

documentation will be required to link the current name with the name by which

ed approval of membership to a Membership Officer, but ecide to reject an

people who live or work in the Common Bond area can support each other, saving their money together and lending it to each

interest. Obviously, in an area as large as ours, we do not all know each other personally, so it is important we can verify that people are who they say they are. We also have to comply with money laundering

We therefore need to see at least two documents, one to prove identity and one to prove address. Examples of acceptable documents are as follows:-

Identification documents should contain a current photo ID issued by an

Current signed Passport (with valid unexpired visa for non EEA

If you do not have ID as above, please provide two other forms of ID from the list


• Recent letter from the Benefits Agency confirming rights to benefits

• HMRC tax notification

• Employee ID card

• Blue disabled parking badge

• Any one document from the list at 18 beladdress, together with any document from the list above.

18. Documents accepted as proof of address include:

• Current driving licence (if not being used to prove identity).

Or any of the following documents (if less than three

• Utility bill (not mobile telephone)

• Bank or Building S

• Pension statement

• Local authority rent card or tenancy agreement

• Mortgage statement

• Current TV Licence

• Pay-slip addressed to home address

• Solicitor's confirmat

• Landlord's confirmation of tenancy agreement

• Tenancy agreement

19. Additional documents may be required e.g. a marriage certificate to verify any change in name.

20. Documents that are not acceptable include:

• Bus Pass

• Rail Card

• Library card

• Credit or Debit Cards

• Birth Certificate (unless applicant is under 16 years of age)

21. We understand that not everyone has the forms of identification we need. If prospective members are unable to provide this documentation or are unsure which documents will be acceptable, they should contact head office for advice.

Annex 3: Procedures f

1. An Information Point will offer the following minimum services to members:

— Access to a computer with online access to the

— Provision of information

— Access to information on policies and procedures

2. An Information Point will be open should be present; however


Recent letter from the Benefits Agency confirming rights to benefits

HMRC tax notification

Employee ID card

Blue disabled parking badge

one document from the list at 18 below, if not being used to prove together with any document from the list above.

Documents accepted as proof of address include:

Current driving licence (if not being used to prove identity).

Or any of the following documents (if less than three months old):

Utility bill (not mobile telephone)

Bank or Building Society account statement

Pension statement

Local authority rent card or tenancy agreement

Mortgage statement

Current TV Licence

slip addressed to home address

Solicitor's confirmation of house move

Landlord's confirmation of tenancy agreement

Tenancy agreement

Additional documents may be required e.g. a marriage certificate to verify any

Documents that are not acceptable include:

edit or Debit Cards

Birth Certificate (unless applicant is under 16 years of age)

We understand that not everyone has the forms of identification we need. If prospective members are unable to provide this documentation or are unsure

e acceptable, they should contact head office for advice.

Annex 3: Procedures for Information Points

Point will offer the following minimum services to members:

Access to a computer with online access to the Swan Credit Union website

information and assistance to join, save and borrow

Access to information on policies and procedures

Point will be open at all times advertised. Ideally twohowever they can operate with one volunteer.

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Recent letter from the Benefits Agency confirming rights to benefits

if not being used to prove together with any document from the list above.

Current driving licence (if not being used to prove identity).

Additional documents may be required e.g. a marriage certificate to verify any

Birth Certificate (unless applicant is under 16 years of age)

We understand that not everyone has the forms of identification we need. If prospective members are unable to provide this documentation or are unsure

e acceptable, they should contact head office for advice.

Point will offer the following minimum services to members:

Credit Union website

and assistance to join, save and borrow

all times advertised. Ideally two volunteers eer.


3. There will be a designated BThey will be responsible for organisInformation Points are open at all advertised times.

4. If a volunteer fails to showdesignated Board member for Information Points

5. The role of volunteers at Credit Union to encourageinclude:

a) Dealing with enquiries about membership and helping people to join. includes processing membership applications (see procedure for new members), informing people how to join by post, and communicating the benefits of membership.

b) Helping members to sadifferent saving methods available to them and communicating the benefits.

c) Helping members to borrow. complete a loan application form online or in hardcopy, and advof interest rates and benefits.

d) Helping members to access other services such as the online member’s area, special offers or getting more involved.

6. All volunteers will be provided with access to a computer and online access to the Swan Credit Union website at amembers with accurate up to date information.

7. Volunteers are asked to encourage members to use the online member’s area in the first instance, and only use hardcopy forms wherehelps members to manage their money independently and is quicker and more efficient to process.

8. Volunteers who agree to cover the times they have agreed and providing adequate notice where theyto do so. Where possible, if they are unable to attend.

9. List of hardcopy items to be held at

• A copy of this Policies and Procedures M

• Leaflets

• Loan Application

• Loan Application guidance

• Membership Application form

• Standing Order form

• Share Withdrawal form

• Change of Address form

• Compulsory notices for display (Money laundering and deposit protection)


There will be a designated Board member responsible for Information Pointswill be responsible for organising a rota of volunteers to ensure that

are open at all advertised times.

fails to show, the other volunteer who is present should member for Information Points.

The role of volunteers at Information Points is to provide advice on the encourage people to join, save and borrow. The specific tasks will

Dealing with enquiries about membership and helping people to join. includes processing membership applications (see procedure for new members), informing people how to join by post, and communicating the benefits of membership.

Helping members to save. This could be through advising members on the different saving methods available to them and communicating the

Helping members to borrow. This could be through helping members to complete a loan application form online or in hardcopy, and advof interest rates and benefits.

Helping members to access other services such as the online member’s area, special offers or getting more involved.

will be provided with access to a computer and online access to the ion website at an Information Point in order to be able to provide

members with accurate up to date information.

Volunteers are asked to encourage members to use the online member’s area in the first instance, and only use hardcopy forms where needed. Onlhelps members to manage their money independently and is quicker and more

Volunteers who agree to cover Information Points are responsible for attending at the times they have agreed and providing adequate notice where theyto do so. Where possible, Information Point volunteers should try to arrange cover

attend.

s to be held at Information Points:

this Policies and Procedures Manual

pplication form

pplication guidance

Membership Application form

Standing Order form

Share Withdrawal form

Change of Address form

Compulsory notices for display (Money laundering and deposit

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Information Points. s to ensure that

who is present should notify the

is to provide advice on the Swan people to join, save and borrow. The specific tasks will

Dealing with enquiries about membership and helping people to join. This includes processing membership applications (see procedure for new members), informing people how to join by post, and communicating the

ve. This could be through advising members on the different saving methods available to them and communicating the

This could be through helping members to complete a loan application form online or in hardcopy, and advising them

Helping members to access other services such as the online member’s

will be provided with access to a computer and online access to the in order to be able to provide

Volunteers are asked to encourage members to use the online member’s area in needed. Online access

helps members to manage their money independently and is quicker and more

are responsible for attending at the times they have agreed and providing adequate notice where they are unable

volunteers should try to arrange cover

Compulsory notices for display (Money laundering and deposit


Partnership Information Points

10. To encourage new members to community groups will be encouraged to provideSwan Credit Union (for example CAB, Parish CInformation Points may be supported through the use of volunnecessarily need to be manned at set ‘opening hours’.

Annex

1. A complaint can be received at any place wherebusiness and can be received by any officer, employeeComplaints can be made in writing or orally and can be made in person, by letter, by telephone or by e-mail.

2. The Complaints Officer will log the information in the complaints register and inform the Chair of the Board.

3. Oral complainants will be offered assurancthe matter, but if still dissatisfied, they will be asked to put their complaint in writing by e-mail or letter to be referred to the Complaints Officer for further action.

4. The Complaints Officer wwritten complaints unless they are the subject of the complaint, when the Chair may delegate a suitable individual, not involved in the complaint, to action and investigate the complaint.

5. Appropriate actions will problems as well as any specific problem identified by a complaint.

6. Records of all complaints taking longer than one working day to resolve will be kept for a period of three years. An annual reporton the amount and type of complaints dealt with by the Credit Union.

Responding to Complaints

7. Within a Day: the aim is to resolve complaints to the complainant’s satisfaction by the end of the next working day after the compresolved in this time period will not be included in the annual report to the FSA and need not be kept for three years.

8. Within 7 Days: If the complaint cannot be resolved quickly, an acknowledgement will be sent to the complainclude the name of the person handling the complaint and a copy of the Credit Union’s internal complaint handling procedure.

9. Within 8 weeks: If still unresolved within 8 weeks of receiving a complaiCredit Union will send the complainant:

• A final response or

• A response which explains the delay, and advises the complainant when a final response can be expected.


Information Points

ourage new members to join the Credit Union other organisations and community groups will be encouraged to provide & display information about

Credit Union (for example CAB, Parish Councils). These ‘partnership’ may be supported through the use of volunteers

necessarily need to be manned at set ‘opening hours’.

Annex 4: Complaints Procedures

an be received at any place where the Credit Union conducts business and can be received by any officer, employee, CUS or volunteer.

ints can be made in writing or orally and can be made in person, by letter, mail.

The Complaints Officer will log the information in the complaints register and inform the Chair of the Board.

Oral complainants will be offered assurances by the officer initially dealing with the matter, but if still dissatisfied, they will be asked to put their complaint in

mail or letter to be referred to the Complaints Officer for further action.

The Complaints Officer will be responsible for action on, and investigationcomplaints unless they are the subject of the complaint, when the Chair

may delegate a suitable individual, not involved in the complaint, to action and investigate the complaint.

Appropriate actions will be taken to identify and remedy any recurring or systemic problems as well as any specific problem identified by a complaint.

Records of all complaints taking longer than one working day to resolve will be kept for a period of three years. An annual report will be made to the on the amount and type of complaints dealt with by the Credit Union.

Responding to Complaints

Within a Day: the aim is to resolve complaints to the complainant’s satisfaction by the end of the next working day after the complaint was received. Complaints resolved in this time period will not be included in the annual report to the FSA and need not be kept for three years.

Within 7 Days: If the complaint cannot be resolved quickly, an acknowledgement will be sent to the complainant within 7 days of receipt of the complaint and will include the name of the person handling the complaint and a copy of the Credit Union’s internal complaint handling procedure.

Within 8 weeks: If still unresolved within 8 weeks of receiving a complaiCredit Union will send the complainant:

A final response or

A response which explains the delay, and advises the complainant when a final response can be expected.

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nion other organisations and & display information about

‘partnership’ teers, but do not

the Credit Union conducts or volunteer.

ints can be made in writing or orally and can be made in person, by letter,

The Complaints Officer will log the information in the complaints register and

es by the officer initially dealing with the matter, but if still dissatisfied, they will be asked to put their complaint in

mail or letter to be referred to the Complaints Officer for further action.

for action on, and investigation of, all complaints unless they are the subject of the complaint, when the Chair

may delegate a suitable individual, not involved in the complaint, to action and

be taken to identify and remedy any recurring or systemic problems as well as any specific problem identified by a complaint.

Records of all complaints taking longer than one working day to resolve will be will be made to the Regulators

on the amount and type of complaints dealt with by the Credit Union.

Within a Day: the aim is to resolve complaints to the complainant’s satisfaction by laint was received. Complaints

resolved in this time period will not be included in the annual report to the FSA

Within 7 Days: If the complaint cannot be resolved quickly, an acknowledgement inant within 7 days of receipt of the complaint and will

include the name of the person handling the complaint and a copy of the Credit

Within 8 weeks: If still unresolved within 8 weeks of receiving a complaint, the

A response which explains the delay, and advises the complainant


10. The complainant will be asked whether they are willing to extend the time for the investigation to be completed. The complainant will be advised that if they are dissatisfied with the delay they can refer the complaint to the Financial Ombudsman Services (a copy of the FOS leaflet will be included in the response).

11. A final response will include a summary of the complaint and the investigation, the Credit Union’s views on the issues raised in the complaint, an acknowledgement by the Credit Union if it has been at fault and details of redress or offer made to settle the complaint. Reference the complainant’s right to refer to the FOS if they remain unsatisfied.

12. The Credit Union will:

a. Ensure all complainants receive an apology where appropriate.

b. Seek to improve its service to all members as a result of complaints received.

Annex 5: A guide to the use of

Introduction

1. The confidentiality of all financial antheir account is guaranteed by the Credit Union Board and by its policies and procedures. All staff and volunteers with access to such information have signed a confidentiality statement. We are signedProtection Act via our annual subscription to the information commissioner.

2. All new officers will sign a declaration of confidentiality form.

3. The following paragraphs explain in what circumstances and to which organisations we might pass on your personal and financial informationas permitted or required by law.

New members

4. When you apply to us to open an account ormay check the following records about you

• Our own records.

• Those at credit reference agencies (CRA’S), t

Loan applications

5. When you make a loan application to us we may check the following records about you and others (see 5 below):

• Our own records.

• Those at credit reference agencies they will place a search


The complainant will be asked whether they are willing to extend the time for vestigation to be completed. The complainant will be advised that if they are

dissatisfied with the delay they can refer the complaint to the Financial Ombudsman Services (a copy of the FOS leaflet will be included in the

nclude a summary of the complaint and the investigation, the Credit Union’s views on the issues raised in the complaint, an acknowledgement by the Credit Union if it has been at fault and details of redress or offer made to settle the complaint. Reference will also be made to the complainant’s right to refer to the FOS if they remain unsatisfied.

The Credit Union will:

Ensure all complainants receive an apology where appropriate.

Seek to improve its service to all members as a result of complaints

A guide to the use of personal information by Swan

The confidentiality of all financial and personal information about members and account is guaranteed by the Credit Union Board and by its policies and

procedures. All staff and volunteers with access to such information have signed a confidentiality statement. We are signed up to the requirements of the Data

nnual subscription to the information commissioner.

All new officers will sign a declaration of confidentiality form.

The following paragraphs explain in what circumstances and to which organisations we might pass on your personal and financial informationas permitted or required by law.

When you apply to us to open an account or apply for credit, Swanmay check the following records about you

edit reference agencies (CRA’S), to verify an address.

When you make a loan application to us we may check the following records about you and others (see 5 below):

redit reference agencies . When CRA’s receive a search from us they will place a search footprint on your credit file that may be seen by other

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The complainant will be asked whether they are willing to extend the time for vestigation to be completed. The complainant will be advised that if they are

dissatisfied with the delay they can refer the complaint to the Financial Ombudsman Services (a copy of the FOS leaflet will be included in the

nclude a summary of the complaint and the investigation, the Credit Union’s views on the issues raised in the complaint, an acknowledgement by the Credit Union if it has been at fault and details of

will also be made to the complainant’s right to refer to the FOS if they remain unsatisfied.

Ensure all complainants receive an apology where appropriate.

Seek to improve its service to all members as a result of complaints

Swan Credit Union

d personal information about members and account is guaranteed by the Credit Union Board and by its policies and

procedures. All staff and volunteers with access to such information have signed up to the requirements of the Data

nnual subscription to the information commissioner.

The following paragraphs explain in what circumstances and to which organisations we might pass on your personal and financial information to others,

apply for credit, Swan Credit Union

address.

When you make a loan application to us we may check the following records

. When CRA’s receive a search from us footprint on your credit file that may be seen by other


lenders. They supply to us both public (including the electoral register) and shared credit and fraud prevention information.

• Those at fraud prevention agencies assessing an application for credit and verifying identities to prevent and detect crime and money laundering.

6. If you tell us that you have a partner, spouse or financial associate, who is also a member, we will link your records together so you must betheir agreement to disclose information about them. CRA’s also link your records together and these links will remain on your files and theirs until such time as you or your partner successfully files for a disassociation with CRA’s to

7. Information on applications will be sent to CRA’s and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it/them to CRA’s. If you borrow and do not repay in full and on time, CRA’s will record the outstanding debt. This information may be supplied to other organisations by CRA’s and FPA’s to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years, after that they are closed, whether settled by you or not.

8. If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information on to FPA’s and other organisations involved in crime and fraud prevention.

9. If you have borrowed from us and do not make payments that you owe us, we will trace your whereabouts and recover debts.

10. We and other organisations may access and use from other countries the information recorded by FPA’s.

11. Your data may also be used for other specific permission or in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.

12. We will from time to time send you by email or post information on new products and services. You can choose not to receive such material by contacting us on 03030 300147.

13. You have the right to access certain records held about you. Please contact us for more information.

14. Further information on how the CRA’s & FPA’s use your personacan be obtained by contacting them directly, they may charge a small fee for this information: Equifax Plc, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583.

Money Laundering Act

15. All credit unions are required t(MLRO),. Financial transactions such as very large cash deposits or unusual activity on your accounts, must, by law, be reported in confidence by our staff and volunteers to our MLRO.

16. In turn the MLRO mustreporting to the Serious Organised Crime Office (SOCO). Any such reports are confidential to the MLRO and are


lenders. They supply to us both public (including the electoral register) and shared credit and fraud prevention information.

Those at fraud prevention agencies (FPA’s). We will make checks such aapplication for credit and verifying identities to prevent and

detect crime and money laundering.

If you tell us that you have a partner, spouse or financial associate, who is also a member, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRA’s also link your records together and these links will remain on your files and theirs until such time as you or your partner successfully files for a disassociation with CRA’s to

Information on applications will be sent to CRA’s and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it/them to CRA’s. If you borrow and do not repay in full and on time,

’s will record the outstanding debt. This information may be supplied to other organisations by CRA’s and FPA’s to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years,

e closed, whether settled by you or not.

If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information on to FPA’s and other organisations involved in crime and fraud prevention.

ou have borrowed from us and do not make payments that you owe us, we will trace your whereabouts and recover debts.

We and other organisations may access and use from other countries the information recorded by FPA’s.

Your data may also be used for other purposes for which you give your specific permission or in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.

We will from time to time send you by email or post information on new and services. You can choose not to receive such material by

contacting us on 03030 300147.

You have the right to access certain records held about you. Please contact us for more information.

Further information on how the CRA’s & FPA’s use your personacan be obtained by contacting them directly, they may charge a small fee for this information: Equifax Plc, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583.

unions are required to have a Money Laundering Reporting O(MLRO),. Financial transactions such as very large cash deposits or unusual activity on your accounts, must, by law, be reported in confidence by our staff and volunteers to our MLRO.

In turn the MLRO must decide if these are serious enough to warrant onward reporting to the Serious Organised Crime Office (SOCO). Any such reports are confidential to the MLRO and are not known or reported to other B

of 29

lenders. They supply to us both public (including the electoral register) and

e checks such as; application for credit and verifying identities to prevent and

If you tell us that you have a partner, spouse or financial associate, who is also a sure that you have

their agreement to disclose information about them. CRA’s also link your records together and these links will remain on your files and theirs until such time as you or your partner successfully files for a disassociation with CRA’s to break that link.

Information on applications will be sent to CRA’s and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it/them to CRA’s. If you borrow and do not repay in full and on time,

’s will record the outstanding debt. This information may be supplied to other organisations by CRA’s and FPA’s to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years,

If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information on to FPA’s and other

ou have borrowed from us and do not make payments that you owe us, we will

We and other organisations may access and use from other countries the

purposes for which you give your specific permission or in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.

We will from time to time send you by email or post information on new and services. You can choose not to receive such material by

You have the right to access certain records held about you. Please contact

Further information on how the CRA’s & FPA’s use your personal information can be obtained by contacting them directly, they may charge a small fee for this information: Equifax Plc, Credit File Advice Centre, PO Box 3001, Bradford, BD1

o have a Money Laundering Reporting Officer (MLRO),. Financial transactions such as very large cash deposits or unusual activity on your accounts, must, by law, be reported in confidence by our staff and

e if these are serious enough to warrant onward reporting to the Serious Organised Crime Office (SOCO). Any such reports are

not known or reported to other Board members


or to any of our staff and volunteers. In most cases by the Credit Union and the member concerned will not be informed of any such referrals.

Annex 6: Interest rates from

1. New loans issued from 1 December 2014 will be charged at the following rates:

• Loans up to £500: 3% per month (42.6% APR).

• Loans of £501 or more, up to the maximum permitted by PRA rules: 2% per month (26.8% APR).

• Loans over £3,000 or morePRA rules, and judged by the Credit C(12.7% APR).

• Discount interest rates of 1.75% or 1.5% per month may be available for repeat loans to previous borrowers with a good record (loyalty loans) but only if judged by CUS to be low risk.

2. Introductory loans, which do not require the membership, approved after 1 February 2012, and up to £2,000 home owners) will be charged at 2% per month (26.8% APR). Introductory loans may be used for example where payroll deduction facilities are in place and where it is deemed that the risk of default is small. These loans will be subject to credit checks and examination of bank statements.

3. Immediate loans at 3% interest will be offered to those who child benefit income into their account.


or to any of our staff and volunteers. In most cases no further action will nion and the member concerned will not be informed of any such

Annex 6: Interest rates from December 2014

New loans issued from 1 December 2014 will be charged at the following rates:

£500: 3% per month (42.6% APR).

Loans of £501 or more, up to the maximum permitted by PRA rules: 2% per month (26.8% APR).

,000 or more to home owners, up to the maximum permitted by and judged by the Credit Committee as low risk: 1

Discount interest rates of 1.75% or 1.5% per month may be available for repeat loans to previous borrowers with a good record (loyalty loans) but only if judged by CUS to be low risk.

Introductory loans, which do not require the usual 3 months minimum membership, approved after 1 February 2012, and up to £2,000 (up to 3,000 for

will be charged at 2% per month (26.8% APR). Introductory loans may be used for example where payroll deduction facilities are in place and

ere it is deemed that the risk of default is small. These loans will be subject to credit checks and examination of bank statements.

Immediate loans at 3% interest will be offered to those who agree to pay their child benefit income into their account.

of 29

no further action will be taken nion and the member concerned will not be informed of any such

New loans issued from 1 December 2014 will be charged at the following rates:

Loans of £501 or more, up to the maximum permitted by PRA rules: 2% per

, up to the maximum permitted by ommittee as low risk: 1.0% per month

Discount interest rates of 1.75% or 1.5% per month may be available for repeat loans to previous borrowers with a good record (loyalty loans) but only

usual 3 months minimum (up to 3,000 for

will be charged at 2% per month (26.8% APR). Introductory loans may be used for example where payroll deduction facilities are in place and

ere it is deemed that the risk of default is small. These loans will be subject to

agree to pay their

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