-
Implementing the CFPB-required Compliance Management System (Part 2)
CFPB compliance examinations have only just started and the agency has already identified deficiencies in some institutions: “The CFPB has found one or more situations in which an effective CMS was lacking across the financial institution’s entire consumer financial portfolio, or in which the financial institution failed to adopt and follow comprehensive internal policies and […]
-
CFPB Examinations To Require “Compliance Management Systems” (Part 1)
We have known for some time that CFPB examinations are coming, and late last year the CFPB released their Supervision and late last year…
Read the rest of the article -
FDIC Institutions still getting UIGEA (Reg GG) findings – UPDATE
Update 1 – 12/5/2011 to add examination procedures*. Update 2 – 2/13/2012 to emphasize policy requirements. Update 3 – 10/8/2012 to add specific courses of action Read the rest of the article
-
“Operational Risk Increasing”
In a recent speech to the Exchequer Club1, Thomas J. Curry, the new head of the OCC, stated that although asset quality has improved, charge-off rates have fallen, and capital now stands at its highest level in a decade, another type of risk is gaining increasing prominence; Operational Risk. “Some of our most seasoned supervisors, […]
