If you missed the September Monthly Connection, you missed a good one! David Dickinson started it off by discussing “how” to disagree with examiners. To sum it up…don’t take it personal; be professional; ask for citations and learn from them; and don’t be afraid to ask what other financial institutions do differently to comply. There’s a valuable lesson here in that your examiners can be a great resource and do provide learning opportunities. An exam can be a two-way street in that you learn from each other. Examiners are not always right just as compliance officers are not always right. Discuss, don’t cuss.
Here's a clip from the discussion:
The Hot Topics included Kevin Edwards talking about beneficial ownership and the changes that are being phased in. Links were provided so that members can review the current issues, evaluate their positions and determine where they should be for change management purposes. Kevin reminded members examiners are looking at beneficial ownership and referenced an enforcement action against a large bank which centered around that bank’s BSA program including beneficial ownership.
Andy Zavoina talked about complaint management in reference to a recent Consumer Compliance Outlook, which had three articles addressing this facet of compliance. This is an integral part of your compliance rating and Board and Senior Management involvement is vital to its success. Meaningful reporting to them raises awareness and helps ensure a good complaint management program. Andy also touched on the fact that one of the hardest parts of this process is defining what a complaint is and isn’t. Determining when to draw the line is important.
Kevin also discussed your responsibilities when you use a third party and referenced a recent Joint Statement on Banks’ Arrangements with Third Parties to Deliver Bank Deposit Products and Services. The document may be useful as a checklist of sorts to help ensure that institutions which may use one or more third parties remain aware of their responsibilities.
The Team then turned its attention to the members’ compliance questions on HMDA, TRID, Flood and Adverse Action. The beauty of this interactive program is that, when the Team needed clarification on a question, the member was able to provide the information live, in order to get the best answer.
Published
2024/09/23