Keywords for Compliance Teams in 2026: ‘Intention’ & ‘Integrity’

January 27, 2026

By Carrie Helmle, Senior Director of Audit Services 

Credit union compliance officers will be operating in something of a quiet period in 2026, at least relatively speaking. The industry is not expecting a large volume of new rules, nor any major surprises in the area of enforcement action.

Against this backdrop, compliance officers will have to mindfully guard against complacency, making intentional moves to contribute to their cooperatives’ ongoing safety and soundness. This can play out in a couple of ways, namely in their own day-to-day operations and in that of cross-functional colleagues. 

Addressing Bad Habits that May Undermine Consistency

There are several ways a compliance team, or even a single compliance leader, can work to root out complacency. By making it their mission to hunt down areas of weakness, leaders can take advantage of the relative calm to make them stronger.

While every credit union will have different strategic priorities for governance, risk and compliance excellence, there are three areas that commonly fall short of best practices: compliance training, internal audit and risk assessments. These are good places to focus in the upcoming year.

Compliance Training

Take a closer look at your policies and procedures. Beyond the simple fact that these documents exist, you want to understand how well they’re being followed and how effective they are at achieving the desired outcomes.

Questions to ask:

• Are employees completing training often, or is participation treated as a one-and-done exercise?
• Are assessment scores reflective of understanding, or are employees passing post-course quizzes only after multiple attempts?
• Is there a disconnect between what employees learn in training and what they practice day to day?

It’s not uncommon for credit unions to start staff out with strong initial training but to then neglect frequent refreshing. Over time, team members can let bad habits creep in or even forget the ins-and-outs of their responsibilities. Reviewing training reports can help compliance leaders identify where concepts aren’t landing and which employees may need additional support.

Cultural signals also matter. Complacency can take hold when employees hear or repeat phrases like, “You don’t have to do that,” or “It’s never been a problem before.” And, when regulatory pressure feels lighter, there may be a temptation to relax standards. That’s when sleeper risks develop and can go unnoticed until there’s a major problem.

Internal Audit

In many cases, credit unions don’t need a complete overhaul of their internal audit practices. Just a few tweaks. Consider bringing in a different external audit partner—even for just a year—to get a fresh perspective. Or, take advantage of emerging technology to implement an automated tracking system that assigns and cures audit findings.

Questions to ask:

• Are required internal and external audits being completed on schedule, or are certain reviews being overlooked?
• Are audit findings clearly owned and resolved, or does accountability fade over time?
• Are higher-risk areas, like ACH, being reviewed against regulatory expectations?

In terms of priority, focus on the higher risk or faster changing areas, such as ACH. Recent changes now require all participants in the ACH network, including receiving institutions, to have fraud monitoring in place. In response, NACHA has begun automating outreach to confirm whether required annual ACH audits have been completed. Lapses in that schedule can trigger lookbacks covering multiple years, with the potential for fines or even restrictions on ACH activity.

Strong audit discipline helps prevent that kind of enforcement. More importantly, it leads to better accountability. When audits are treated as an ongoing governance function, credit unions are better positioned to stay ahead of emerging risks.

Risk Assessment

Speaking of risk, credit unions can use the anticipated calm of the upcoming months to reevaluate their risk assessments. Too often, risk assessments are treated as static documents or templated exercises rather than living tools. Now is an ideal time to revisit them.

Questions to ask:

• Is the risk assessment customized to your credit union, or does it largely mirror a generic template?
• Do identified risks align with your actual products, services, and delivery channels?
• Are mitigating controls clearly documented and reflective of how risk is managed in practice?

This is not to say that the use of risk assessment templates is wrong. They can be a helpful starting point. However, the risks faced by one credit union may be irrelevant or insufficient for another.

Debit card dispute processes are one example where processes, and ultimately risk, may be vastly different depending on the institution. Fraud-related disputes have grown exponentially within the debit product, and the rules governing investigation timelines and provisional credit are strict. Many credit unions outsource this function, only to discover later that vendors are missing required deadlines. Even when a third party is involved, responsibility ultimately rests with the credit union.

Everything today is risk-based, from examination and supervision to enforcement. Risk assessments that are current, personalized, and operationally grounded provide the strongest foundation for safety and soundness.

Intention & Integrity in 2026

As compliance leaders enter a quieter regulatory period, intention matters more than ever. This is the moment to act deliberately, strengthening training, audits, risk assessments, and any other areas of the cooperative that may have weakened over time.

Integrity shows up in the discipline to maintain high standards even when external pressure eases. In 2026, the strongest compliance teams will be defined not by how they respond to chaos, but by the intention and integrity they bring to keeping the compliance engine running smoothly.

Originally published in CUInsight on January 6, 2026.