by Elva M. Coffey-Sears, CRCM, CRP
A quick review of recent issuances by the Federal Financial Regulators confirms a significant reduction in new regulations and regulatory amendments thus far this year. Further, the agencies’ Spring Rulemaking Agendas for 2018 indicate this reduced level of regulatory change can be expected to continue for the remainder of the year. While this is definitely good news for bank compliance officers, it doesn’t mean we have less to do! This lull in regulatory actions provides compliance officers with much needed time to reexamine their institution’s current policies, procedures and practices to verify they are achieving the desired result.
Just last week, the OCC released a revised Compliance Management Systems (CMS) booklet. The introduction to the revised manual clearly states “The principles in this booklet do not set new or higher expectations for banks.” Great, you think, that’s one less thing to add to my compliance review schedule! But wait, the highlights contained in the release notification (OCC Bulletin 2018-18) indicate that the updates “clarify the roles of the bank’s board of directors and management” and “include revised concepts and references regarding third party risk management, new, modified, or expanded bank products or services; and corporate and risk governance.”
Thus, while regulatory expectations may not have changed, what impact do the new clarifications or the “revised concepts and references” have on your current CMS? The best way to find out is to evaluate your CMS using your primary regulator’s current CMS exam procedures. Completing this step-by-step analysis of your CMS also provides insights into regulatory hot buttons, such as third-party risk management. At the conclusion of the procedures, determine your institution’s performance in each of the assessment factors and your overall consumer compliance rating. This process allows you to confirm whether your program meets regulatory expectations and is achieving the desired result. The added bonus comes in knowing the status of your CMS before being told by an examiner!