Compliance: Have 'whistleblower' policy in place

WASHINGTON (9/2/10)--Does your credit union have a whistleblower policy? This is the opening question in Credit Union Magazine's September compliance article, "Consider Whistleblower Policy Protections."

The article explains how a whistleblower policy can protect a credit union, its employees, and volunteers when there are concerns about possible wrongdoings in the credit union. Christopher Pippett, a Pennsylvania attorney who advises credit unions, explains the growing interest in these policies.

"Tax-exempt organizations began seriously focusing on the desirability of having a whistleblower policy a couple of years ago when the Internal Revenue Service (IRS) revised its Form 990...The IRS explains in its instructions that it believes having a whistleblower policy is one indicator of good governance practices." Form 990, "Return of Organization Exempt from Income Tax," requires state-chartered credit unions to report annually whether they have a whistleblower policy.

Pippett also notes provisions in the new financial reform law that, while not applicable to credit unions, address whistleblower policies to protect employees against employer retaliation for reporting suspicious securities activities of publicly traded companies. This shows the government's continued interest in businesses providing employees a way to report concerns, he writes.

In his article, Pippett discusses what a good whistleblower policy should address, and suggests an outline of a possible policy for credit unions, which should state:

  • The purpose of the whistleblower policy;
  • The expectation that employees and volunteers will report concerns;
  • The reporting process;
  • The fact that no retaliation for reporting will occur, as long as the person is acting in good faith;
  • The fact that reports will be handled confidentially;
  • What the credit union will do in general terms to investigate any reported concern; and,
  • How the credit union will inform employees and volunteers of the whistleblower policy.

Pippett notes that numerous examples of whistleblower policies from a variety of non-profit organizations are readily available on the Internet.

All of Credit Union Magazine's compliance articles can be found on CUNA's compliance webpage.

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