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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…
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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
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Technology Service Providers and the new SOC reports
What do all of the 2012 changes to the IT Examination Handbooks have in common? They are all, directly or indirectly, related to vendor management. I had previously identified vendor management as a leading candidate for increased regulatory scrutiny in 2012, and boy was it. (Not all of my 2012 predictions fared as well, I’ll…
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CFPB Examinations Are Coming – UPDATE 2
Coming soon to your financial institution: Dear Board of Directors: Pursuant to the authority of the Dodd-Frank Wall Street Reform… Read the rest of the article