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#2247702 - 01/14/21 09:52 PM Conduct Risk Program
SLODWatch1 Offline
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Joined: Jan 2021
Posts: 3
Hi all,

Does the OCC have any documentation specifically targeting Conduct Risk Programs?

Additionally, does anyone know of a place where I could view a sample program?

Thanks!

SLODWatch1

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Risk Management
#2247721 - 01/15/21 01:06 PM Re: Conduct Risk Program SLODWatch1
osucpa Offline
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Joined: May 2011
Posts: 1,400
Please give a little more detail related to Conduct Risk Programs.

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#2247723 - 01/15/21 01:15 PM Re: Conduct Risk Program SLODWatch1
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,958
Galveston, TX
I do not recall any of the regulators specifically mentioning conduct risk. Conduct risk involves conduct of the bank or individuals within the bank that may impact customers or the bank's reputation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2247724 - 01/15/21 01:28 PM Re: Conduct Risk Program SLODWatch1
SLODWatch1 Offline
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Joined: Jan 2021
Posts: 3
Good morning,

I haven't seen anything specific from the OCC either, but in the wake of several banks falling short on identifying misconduct by their employees, I'm trying to locate reference guidance from regulators (already have Financial Conduct Authority and Federal Reserve guidance) to build a program. Most banks leverage their Code of Conduct, Conflict of Interest and/or Ethics policies to govern conduct (i.e. sales practices, fraud, etc.) while I'm trying to make an umbrella policy which incorporates all of those into a Conduct Risk Program.

Thanks,
SLODWatch1

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#2247733 - 01/15/21 03:34 PM Re: Conduct Risk Program SLODWatch1
osucpa Offline
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Joined: May 2011
Posts: 1,400
I would have you think about how are you going to test some of the information you mentioned prior to creating a program. Here Internal Audit and HR rely heavily on our employees acknowledging the Employee Handbook on an annual basis and we review some of the items you mentions but we do not perform a complete Conduct audit.

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#2247742 - 01/15/21 05:47 PM Re: Conduct Risk Program SLODWatch1
SLODWatch1 Offline
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Joined: Jan 2021
Posts: 3
Good point OSUCPA. I'll advise leadership of that perspective. Thanks all!

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