“You can build, buy or rent for this important position. One, you can take someone from within your organization and give them the training and tools to be good at it, or you can go out and buy someone with a proven track record of compliance expertise, but that can be expensive,” he said, adding another alternative is to outsource some of the work, like the credit union's documents business.

Klewin said it isn't clear yet what approach the CFPB will take but it appears the agency is data driven. He encouraged credit unions to make use of the comment period process to speak out on any proposed rules.

“They may take a disclosure or change in a rule and take it to the people affected to determine a course,” Klewin said. “It's a remarkably different approach and the old way of doing disclosures may go right out the window. It may make sense but it would be very foreign to how credit unions and regulators are accustomed to operating.”