What Does the OCC Look for in a CMS?
What Does the OCC Look for in a CMS?

The Office of the Comptroller of the Currency (OCC) defines a compliance management system (CMS) as “the method by which a bank manages consumer compliance risk, supports compliance with consumer protection-related laws and regulations, and prevents consumer harm.” The Comptroller’s Handbook CC-CMS, published in June 2018, specifically addresses CMSs designed to manage consumer compliance risk.

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What Does the Federal Reserve Look for in a CMS?
What Does the Federal Reserve Look for in a CMS?

The Federal Reserve defines a compliance management system (CMS) as a credit union’s overall approach to managing compliance risk. Compliance risk is the potential for violating any of the laws and regulations that govern bank operations, including those related to federal consumer financial protection. From the Bank Secrecy Act to the SAFE Act, it seeks

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Risk Management Aids Prep for Risk-Focused Exams
Risk Management Aids Prep for Risk-Focused Exams

Risk management helps financial institutions anticipate and guard against all kinds of risks—everything from cyber threats to compliance mistakes to careless third-party vendors. But did you know it can also help prepare for exams? According to a recent American Bankers Association compliance survey, “Examiner review of a bank’s risk management system appears to reduce examination

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Agile Approach to Compliance
Can You Adopt an Agile Approach to Compliance?

One of the buzzwords in business these days is “agile.” If you’re looking to learn more about what an agile approach is, and how it can be used in compliance, this post is for you. You’ve probably heard the word “agile” to describe a way of working. The “agile” approach is a common term in

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A Risk Assessor Origin Story Courtesy of Stephen King’s IT

*** Warning: This blog contains spoilers for the horror movie IT (2017) and IT Chapter Two (2019). ***   Movies are chockfull of superhero origin stories, but what about us regular risk management folks? Well, we finally have one thanks to horror movies IT and IT Chapter Two, released in 2017 and 2019 respectively. Based

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Michael Berman at FDIC
What Does the FDIC Look for in a CMS?

The FDIC expects a bank’s board of directors and management to have a compliance management system (CMS) adapted to its business strategy to effectively manage compliance risk. It should be consistent with the size and complexity of its products, services, and markets. Compliance risk is the potential for violating any of the laws and regulations

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How to Buy CMS Software: 7 Key Features Every CMS Needs

Compliance management is no joke. From the day-to-day work of making sure everyone is following policies and procedures to training staff to tracking, understanding, and implementing new regulations and predicting the impact of proposed rules, it’s a Herculean exercise in organization and education. That’s why federal regulators require financial institutions to have a compliance management

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Everyone Excited About the Executive Order Declaring Guidance Non-Binding Stand Up! Not So Fast Bankers.

Last week President Trump issued an executive order stating that guidance from federal regulatory agencies is non-binding. The order formalizes the administration’s previously stated view that legally binding requirements need to go through the rule making process. But before you start going through your policies and procedures looking for requirements to trash and begin re-assessing

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What Does the NCUA Look for in a CMS?

The NCUA defines a compliance management system as a credit union’s overall approach to managing compliance risk. Compliance risk is the potential of violating any of the laws and regulations that govern credit union operations, including those related to federal consumer financial protection enforced by the NCUA. From the Bank Secrecy Act to the SAFE

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Have You Prepared for Climate Change Risk?

Is your bank considering climate change risk when addressing enterprise risk management (ERM)? If not, it might be time to start. Global warming may seem like an abstract concept, but bank regulators across the world are looking at this emerging risk and suggesting that financial institutions recognize its potential impact on economic and operating conditions.

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Quiz Time! How Did You Get Your Start in Banking?

Risk management starts at the top, but bankers typically start at the bottom. From janitors and tellers to junior loan officers and credit analysts, many CEOs and other C-level executives got their start in the humblest banking positions. But these entry-level bank jobs are more than the first wrung on a ladder to a satisfying

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5 Fair Lending Lessons Learned in 2019

As Q4 2019 approaches, now is perfect time to reflect on some of the lessons learned this year. In particular, we’ve seen lots of changes in Fair Lending compliance. What are the takeaways? Here are the 5 Fair Lending lessons learned in 2019. 1. HMDA Data is Different, and Arguably More Important, Than Before. With

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