On November 7th, the FFIEC finalized the issuance of its updated Interagency Consumer Compliance Rating System (“CCRS”). While the press release stated that the document was intended to “more fully align the rating system with the FFIEC agencies current risk-focused, tailored examination approaches” and “the rating system’s adoption will represent no additional regulatory burden for financial institutions”, a closer reading of the 31-page document provides a helpful glimpse into future regulatory expectations regarding a bank’s Compliance Management System (CMS). This program will address not only the purpose of the update but the public comments, and FFIEC responses, to the initial proposed guidance.
The guidance further stated that the updated CCRS “was not developed with the intention of new or higher supervisory expectations for financial institutions”. It does, however, provide pearls of wisdom and provides all banks with an opportunity to review their present Compliance Management policy and process to ensure it is updated and stays abreast of regulatory expectations.
This two-hour program will address all three main categories - “Board and Management Oversight”, “Compliance Program” and “Violations of Law and Consumer Harm” along with each of those categories four subcomponents or assessment factors.
A bank’s numerical consumer compliance rating is extremely important in numerous aspects of a bank’s operations ranging from the frequency and scope of future compliance examinations, MRAs, potential civil monetary penalties and regulatory approval for mergers or acquisitions. The update provides greater clarification of what are considered the 12 assessment factors that will impact a bank’s numerical compliance rating and whether these might be risk weighted or not and if so, which party risks weights them.
We will also cover the seemingly contradictory regulatory guidance regarding technical violations of law which are typically only discovered during transaction testing. We will address the degree of proactivity expected of a bank in self-identifying violations of consumer affairs laws and regulations during monitoring along with how to identify and treat the root cause, severity, duration, and pervasiveness of any violations discovered.
Participants receive a detailed manual that serves as a valuable resource long after the conclusion of the program which will aid in the improvement of your bank’s Compliance Management System. These materials are intended to place your compliance program in alignment with regulatory expectations.
Upon completion of the program, participants better understand the following:
- Detailed explanation of all 12 assessment factors including the three primary categories and the four subcomponents of each category;
- Periodic risk assessment of bank's compliance management system to identify current or emerging risks necessitating reporting to Board and Senior Management;
- Initial and ongoing comprehensive oversight of any third parties that perform functions for the bank which might impact consumer compliance responsibilities to include a review of third party policies, procedures, training materials and internal controls;
- Change management process for new laws and regulations;
- Comprehensive consumer complaint program including periodic monitoring and Compliance Officer oversight;
- Promptness and comprehensiveness in responding to identified compliance deficiencies; and
- Tailored, periodic, comprehensive compliance training for all bank personnel including those responsible for product development, marketing and customer service
The program is designed for first, second and third lines of defense personnel which will include: Compliance Officers, Branch Administration, Deposit Operations, Senior Management, Auditors, and those responsible for any components of the CMS ranging from training, development of policies and procedures, complaint management, and the monitoring/audit function. This program is also recommended for Board Members and Management who will benefit from greater knowledge regarding regulatory expectations of a bank’s CMS.