Does anyone know of or have a sanctions chart for compliance risk assessment. E.g. a list of all the sanctions/fines for noncompliance with specific regulations.
Posted By: rlcarey
Re: Santions Chart - 06/10/14 03:30 AM
Why do you need anything more than 12 USC 1818(i)???
I want to use the specific regulatory sanctions as a risk factor for performing compliance audits, performing compliance training etc. What you cite it a catch-all and doesn't differeniate between regulations, e.g. what ones are more risky than others.
Posted By: osucpa
Re: Santions Chart - 06/10/14 03:35 PM
One could argue, just because the CMP and/or sanctions are more severe does not mean there is more risk involved. The inherent risk could be higher but the residual risk could be lower based on the bank's controls.
Granted, and we have an offsetting value for internal controls that minimize the inherent risk. But we would still like to include the sanctions as a risk factor.
Therefore, if anyone know of a chart, I would appreciate it.
Posted By: James Hill
Re: Santions Chart - 06/25/14 10:30 PM
Hi Rosie,
I'd be interested in working on this with you if you haven't found a list ready-made. I have often thought that this would be a valuable tool to help management see what is at risk from a dollar perspective.
Reply to my PM or email me at jdhill@hzcu.org if you'd like to chat.
-James