Compliance Committee

Up until the last year our bank had a senior management compliance committee. The committee fell apart this past year due to lack of interest. It's taken some work and lots of follow up, but we are restructuring the committee for this coming year. The committee will now consist of line management with a representative from each of the business units, but what I am interested in finding out is if any of you have a working committee. What is the committee responsible for? How often do you meet? I really want this committee to feel it's serving a purpose and any suggestions or ideas are greatly appreciated!

We have two committees - a working committee in the form of a Management Committee and a formal Committee that meets quarterly.

Management meets weekly and Compliance fortunately gets to discuss and present issues. Besides discussing projects and reviews, we incorporate changes in systems, procedures, ongoing projects, etc. It is effective because everyone is aware of compliance and more importantly, compliance is involved ahead of time in design and implementation.

The Audit (Compliance) Committee of the Board meets quarterly, and most discussions are brief (sanatized) considering their time availability.

Our compliance committee / council meets quarterly. We discuss new laws and regulations, corrective action from compliance audits and exams, compliance monitoring / schedule, etc. The committee is comprised of representatives from each functional area and each member is responsible for compliance and compliance monitoring (not audit) in their respective areas. The compliance officer is responsible for a portion of the regulations, and provides support (training, research, etc.) for the others.

I had established a Compliance Council. It had members from functional areas, Lending, Operations, IT, Training, Audit who were SVPs and below. We had EVPs and above as ex officio members. The Compliance Officer chaired the meetings and made the reports. As I presented quarterly to the Director's Audit Cmte, the Council also received the report. Originally the Council was to meet quarterly, but that was sometimes meeting to meet. That is, there wasn't enough "meat" to justify getting everyone together. So I started doing detailed reports and had questions referred to me. During implementation of new products or laws (CIP as an example) we were meeting more often and we brought in additional staff.

The Council is designed to oversee compliance and assist the Compliance Officer.

Ari: If you're a banker, send me a PM and I can share our committee structure with you and its responsibilities.

I'd like that information also. Let me know. Thanks.

When you say the Committee is responsible for Compliance Monitoring (not audit), what do you mean. Do they actually prepare monitoring reports that are submitted to the Committee or the Compliance Officer. Are there other functions that the committee is responsible for?

We have Responsible Officers for each regulation (or Act that does not have an implementing regulation). We have an Audit Committee of the Board of Directors to whom I report.

The Responsible Officers are responsible for day to day compliance. They delegate monitoring responsibilities to other employees. Example, an employee in loan processing has been delegated the responsibility of monitoring loan files for regulatory violations or policy exceptions. For nondiscrimination, employees have been assigned to take a 2nd look at denied files to ensure that the cr decision made was reasonable, not based on any prohibited basis, and that the applicant could not have been offered any other loan product and qualified.

Annually, I audit and report any findings to the Audit Committee of the Board.