I'm posting anonymously lest one of my coworkers reads this and labels me as a "bad-attitude-haver!" Is anyone else's bank completely pooh-poohing the impact of the new DNC rules? I sat in on a Financial Services Roundtable teleconference the other day, and it sounded to me as though the big boys are paying pretty close attention to this. I put together a "position paper," if you will, summarizing the rules, the penalties for non-compliance and the several areas in which we're vulnerable, but I'm not feeling any concern emanating from management. I feel like the AFLAC duck, walking around quacking like a maniac ("DO NOT FAX! DO NOT FAX!") , and no one's listening...

I'm reviewing a lot of Risk Management material for Sarbanes-Oxley, FDICIA, Risked based exams, etc. The common thread in all of these is the importance of the "tone from the top."

It makes me want to puke because the tone I see at the top is one that doesn't want to be bothered with "silly rules." The only time these guys get religion is when a regulator slaps 'em with a hefty CMP and makes each board member sign and MOU or C&D.

But who gets caught in the cross-fire? Compliance Officers who are just trying to make sure their shop is doing the right thing.