Casting the Net for Third Party Risk

July 26, 2016 | Agreed Upon Procedures (AUP), Program Tools, Regulatory Compliance, Risk Management, Shared Assessments, Third Party Risk, Third Party Risk Management

The summer of 2016 has been one of media challenges, and breaking records for heat waves across many states. Slow moving boats, relaxing fishing in normal idyllic mid-summer breaks have been swept aside by a flurry of activity within the sea of third party risk. This past week in Boston, the Share ....

Heightened Expectations Raise the Bar for All

December 12, 2014 | Compliance, Cybersecurity, Guidance, Office of the Comptroller of the Currency (OCC), Regulatory Compliance, Risk, Risk Management

The Office of the Comptroller of the Currency (OCC) published final guidelines that establish minimum standards for risk governance frameworks for OCC regulated institutions with over $50 billion in assets. While that asset threshold would seem to specifically exclude most community banks, the OCC h ....

How to Respond to the Regulation Avalanche

September 8, 2014 | Compliance, Regulations, Regulatory Compliance, Risk

As follow up to my previous blog on how the avalanche of regulation can stifle innovation in banks and credit unions, I wanted to share some ideas to start the discussion on organizational steps that you can take to enhance the risk and compliance culture. Maturing the processes internally, requires ....

A New Ice Bucket Challenge for FIs

August 26, 2014 | Compliance, Dodd-Frank, Regulations, Regulatory Compliance

While last week my news feeds on social media showed an avalanche of humorous ice bucket challenges, it sparked a comparison to me of the recent Avalanche of Regulation Infographic published by the American Bankers Association (ABA). The burden of regulatory compliance is dousing the fires of creati ....

OCC Releases Guidance on Third Party Relationships (OCC 2013-29)

October 31, 2013 | Regulations, Regulatory Compliance, Third Party Risk, Vendor Oversight, Vendor Security

Yesterday the OCC released its long awaited Guidance on Third-Party Relationships (OCC 2013-29). Notably, this Guidance, posted below, rescinds OCC Bulletin 2001-47, “Third-Party Relationships: Risk Management Principles,” and OCC Advisory Letter 2000-9, “Third-Party Risk.” The Guidance int ....

It’s Game Time – Be Your Own Compliance Umpire

October 7, 2013 | Regulatory Compliance

Managing your suite of regulatory compliance programs today requires a game day strategy to keep all the moving parts working together to achieve the end goal of meeting the external regulators expectations. While financial institutions can prepare for examination reviews by assessing published gui ....

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