Consumer Insurance Protection Rules (CIP)

Does anyone know yet, which type of exam - safety & soundness or compliance CIP will fall under?

Recent compliance seminar I attended said this was a "safety and soundness" issue.

I think the answer here is that "it depends." I was having a friendly conversation with my local regulator yesterday. She indicated that noone at OCC wants to be responsible for enforcing these rules. Currently, NDIPs are covered in safety and soundness exams by the OCC.

But in my last life, the consumer affairs people were doing our NDIP work. That was a Fed member bank.

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Opinions expressed are not necessarily those of my employer.

Paul Brinker CRCM
Director, Corporate Compliance
First National Bank of Omaha
402-964-8313

This could vary by regulatory agency.

When the OCC had their Reg. P tele-conference, I asked this same question about that. Privacy will be integrated into S&S. I commented that I thought compliance was a more natural fit and the answer was, combined exams are in our future anyway. So as to national banks, this may be moot anyway.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.