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Editor: Lucy H. Griffin

Board of Advisors:
John S. Byrne, Esq.
David Battle
Robert P. Chamness
David Dickinson
Phillips G. Gay, Jr.
Barbara Hurst
Michael D. Maher
Robert G. Rowe, III
Andy Zavoina
Volume 8, Number 10
This issue went to press on October 15, 2003.
Table of Contents

Corporate Governance: Governing the Governors (6 Action Steps, 6 Risk Controls, 5 Control Assessments)
The Board of Governors of the Federal Reserve means business. Governor Susan Schmidt Bies continues to speak clearly, strongly, and often on the need for strong corporate governance and the responsibility of all management to maintain high ethical standards. In her words, "we've seen some astonishing corporate governance and internal control breakdowns in companies that exhibited no outward indication of serious problems."

Predatory Lending: Pre-empting Predators (3 Action Steps)
Federal regulators have some fancy tools and the Comptroller of the Currency plans to use his. The tool in question is federal preemption. The OCC is proposing a rule that would automatically preempt certain state laws. At the same time, the regulatory revisions would clearly prohibit predatory lending, as defined by the OCC.

Action Audit: Growing A Compliance Program (8 Compliance Program Elements)
One of the most common questions asked by small banks is what type of compliance program should we have? The art of compliance is developing a system that functions properly in the context of its institution.

Compliance Notes In the Editor's Opinion: RESPA: What Did They Know and When Did They Know It?
Most of the banking world was shocked and appalled by HUD's 2002 proposal to revise what HUD still calls the "good faith estimate." Where did this proposal come from and what is fueling it?

Compliance Q&A Disaster Recovery: After the Hurricane
There is nothing better to test disaster recovery than a good disaster. Hurricane Isabel provided the test for financial institutions up and down the East Coast.

Ethics: OCC Sings Fed's Song
OCC's Chief of Staff, Mark Nishan, spoke to the Midwest National Bank Conference in St. Louis and delivered a strong message on corporate ethics in banking.

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