It would depend on what had triggered such an unnatural desire:), and what is the size of the bank. Basically, what the regulators want to see is that 4 components are fully addresed: policies & procedures; testing & monitoring; training; and consumer complaints. You need to start with compliance risk assessment, and base your system on that. Also, regular updates to the Board or its committee is a good idea.
Policies and procedures are self-explanatory, you need to approve and revise them periodically.
For testing & monitoring, they will be happy if you have a formal monitoring schedule (risk-based), and document each monitoring with a memorandum.
On training, you need to establish criteria for assigning training for job types, and means to monitor the performance (test scores, number of attempts, remedial training, etc); also, the formal training plan presented to the Board is a good practice.
Finally, on consumer complaints you need a policy or procedure, a log, review of the trends, and also Board updates.
I joined a bank that had compliance MOU for the absence of CMS, and after putting all of the above in place, the MOU was lifted.
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