What's Up with the Regulators?
In an attempt to kick up some interesting activity in this Financial Services User Group sub space, I thought I would start a discussion of interest to all bankers: What's Up with the Regulators? It so happens that at least one of the regulators, the OCC, publishes a bank supervision strategic plan each year. In the Fiscal Year 2019 Bank Supervision Operating Plan, the OCC says "the development of supervisory strategies will focus on the following risk areas:
- Cybersecurity and operational resiliency, with emphasis on maintaining information technology systems and remediating identified concerns.
- Commercial and retail credit loan underwriting, concentration risk management, credit risk management, and the allowance for loan and lease losses, including preparations for the current expected credit losses accounting rule.
- Bank Secrecy Act/anti-money laundering (BSA/AML) compliance, with emphasis on determining whether AML compliance programs keep pace with changing risk environments and regulatory developments.
- Consumer-compliance related change management process, with emphasis on implementation of regulatory requirements, including the Home Mortgage Disclosure Act, the integrated mortgage disclosure requirements under the Truth in Lending Act and Real Estate Settlement Procedures Act, and the Military Lending Act.
- Internal controls and end-to-end processes necessary for product and service delivery. This may include emphasis on implementation of new or revised products or strategic partnerships."
What do you think FSUG members? Is this what you are seeing in your institutions? Any advice or concerns related to your preparations? Many members use Archer around the first and last bullet in this list, which are core operational risk management concerns. I find the last bullet most interesting as it seems to be focused on a desire by the regulator to make certain bankers understand all of the infrastructure supporting product and service delivery and the associated control procedures. A classic use of Archer: Products -> Supporting Business Processes -> Risks -> Control Procedures -> Management Control Attestations -> Audit Testing -> Issues Management.
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