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#1627202 - 11/10/11 04:26 PM Regulatory Hot Buttons in 2012+
AuditorK Offline
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PA
I've been asked to put together a list of regulatory compliance concerns that will most likely impact banks in 2012 and beyond.

I'm thinking UDAAP has to be one that needs to be on the radar screen. Maybe Dodd-Frank. I'd like to hear some other thoughts and opinions.

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General Discussion
#1627223 - 11/10/11 04:35 PM Re: Regulatory Hot Buttons in 2012+ AuditorK
manimal Offline
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Fair Lending Regulations (ADA, CRA/HMDA, ECOA, FHA, UDAAP)
Truth in Lending
Flood Disaster Protection Act
BSA/AML
HMDA
RESPA and Mortgage Law Reform
Electronic Fund Transfers - Esp. Overdraft Programs
Fraud
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#1627305 - 11/10/11 05:45 PM Re: Regulatory Hot Buttons in 2012+ manimal
MyScamper Offline
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Between here and there
I agree totally with manimal's list.

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#1628524 - 11/15/11 04:29 PM Re: Regulatory Hot Buttons in 2012+ MyScamper
TINKerBell Offline
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I agree also, though I would move ODP programs to maybe third on the list as far as priority. Lots of talk at the CRA/Fair Lending Colloquium from the examiners on this issue. UDAAP is where it belongs...at the top!
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#1629462 - 11/16/11 11:02 PM Re: Regulatory Hot Buttons in 2012+ TINKerBell
BurntSienna Offline
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I am hearing from colleagues at other banks that the regulators seem very focused on Vendor Management (oversight for compliance with GLBA, ID Theft, reviewing SAS70's, reviewing financial statements). We just had an external audit this month, and our auditor warned us that Vendor Management was definitely a hot button issue with the regulators recently.

Earlier in the year, I heard from everyone about being sure to have a 3-year risk-based audit plan in place for each business unit (i.e. IT, Compliance, etc.).
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#1629498 - 11/17/11 01:25 PM Re: Regulatory Hot Buttons in 2012+ BurntSienna
waldensouth Offline
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FINALLY ABOVE the gnat line
What kind of regulators....FDIC, FRB, state?
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#1629499 - 11/17/11 01:25 PM Re: Regulatory Hot Buttons in 2012+ BurntSienna
Dolly Nugent Offline
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Ditto the suggestion on having a risk-based audit plan. Some banks are looking for ways to reduce audit expenses, but arbitrarily cutting back on audits without conducting a risk assessment to back-up your reasoning will likely get you into trouble with your regulators.
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#1629587 - 11/17/11 03:29 PM Re: Regulatory Hot Buttons in 2012+ Dolly Nugent
renniks Offline
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New England
I agree with Dolly. The FDIC requires a 3 year "rolling" risk based audit plan. You have to update the plan annually. They are also very focused on Vendor Management and Vendor Risk.

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#1629616 - 11/17/11 03:44 PM Re: Regulatory Hot Buttons in 2012+ renniks
Richard Insley Offline
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Toano, VA
Add "old business" to your list. Nothing fires up a regulator like repeat violations.
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#1629637 - 11/17/11 03:59 PM Re: Regulatory Hot Buttons in 2012+ Richard Insley
#Just Jay Offline
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FDIC was just hear a month ago (S&S/BSA/IT)... blew by IT/Vendor Management... they were here for almost four weeks, and honestly, barely spent 2-3 hours with the IT folks. Didn't even bother with an IT person, just the EIC and another bumbling their way through the IT questionaire.
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#1629733 - 11/17/11 05:24 PM Re: Regulatory Hot Buttons in 2012+ #Just Jay
manimal Offline
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Our most recent exam was similar to JJ... the IT folks were in and out in under a week and didn't press too hard with Vendor Management.
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#1629768 - 11/17/11 06:03 PM Re: Regulatory Hot Buttons in 2012+ manimal
Bullseye Offline
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Just came back from a conference. According to most of the speakers, hot buttons are UDAP and ODP if you are FDIC.

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#1630378 - 11/18/11 06:16 PM Re: Regulatory Hot Buttons in 2012+ Bullseye
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#1630798 - 11/21/11 03:02 PM Re: Regulatory Hot Buttons in 2012+ E.E.G.B
JobSecurity Offline
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Thanks for the webinar info smile

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#1630980 - 11/21/11 06:40 PM Re: Regulatory Hot Buttons in 2012+ JobSecurity
Andy_Z Offline
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I would think you'd put UDAP/UDAAP in its own category as it applies to lending and ops.
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