Oh My! Understanding the Bank Vendor Management Environment and Virtual Currencies
|
|
- Imogene Brooks
- 7 years ago
- Views:
Transcription
1 Oh My! Understanding the Bank Vendor Management Environment and Virtual Currencies Douglas King, Payments Risk Expert Federal Reserve Bank of Atlanta
2 2
3 OH MY! UNDERSTANDING THE BANK VENDOR MANAGEMENT ENVIRONMENT & VIRTUAL CURRENCIES Agenda The Retail Payments Risk Forum The Current Risk Environment for Financial Institutions Bank Vendor Management A Bit on Crypto-currencies Q&A 3
4 THE VIEWS EXPRESSED IN THIS PRESENTATION ARE THOSE OF THE PRESENTER AND DO NOT NECESSARILY REFLECT THE VIEWS OF THE FEDERAL RESERVE BANK OF ATLANTA OR THE FEDERAL RESERVE SYSTEM.
5 THE RETAIL PAYMENTS RISK FORUM
6 A CATALYST FOR COLLABORATION 6
7 THE CURRENT RISK ENVIRONMENT FOR FINANCIAL INSTITUTIONS
8 THE BANKING INDUSTRY S CURRENT RISK ENVIRONMENT 8
9 WHY SUCH AN EMPAHSIS ON VENDOR RISK MANAGEMENT? 9
10 HAS IT LEFT YOU FEELING LIKE THIS? 10
11 BANK VENDOR MANAGEMENT
12 WHAT CONSTITUTES A VENDOR (THIRD-PARTY)? [A]ny person that provides a material service to a covered person and any business arrangement between a bank and another entity. 1 Payment processing Website and software vendors Appraisal management Document and disclosure vendors Loan brokers Attorneys Contract underwriters 1 Dodd-Frank Act and OCC Bulletin
13 WHAT CONSTITUTES A SIGNIFICANT VENDOR (THIRD- PARTY) RELATIONSHIP? TP performs critical functions TP stores, access, transmits, or performs transactions with sensitive customer information Performs a service involving lending or card payment transactions Poses risks that could affect earnings, capital, or reputation Provides product or service that covers large number of consumers Provides product or service that implicates higher risk consumer protection regulations Relationship is new or involves new FI activities Has material effect on FI s revenues or expenses Increases FI s geographic market Involves deposit taking arrangements Markets products directly to FI customers that could pose risk of financial loss to individual 13
14 THE RISKS ASSOCIATED WITH VENDOR RELATIONSHIPS Strategic: Reputational: Operational Transactional: Financial: Compliance: Foreign: Adverse business impact Negative public opinion Failed internal processes, people or systems Problems with service or product delivery Unable to meet contractual arrangements Violations of laws, regulations or internal policies Country, culture, or geopolitical 14
15 THE ELEMENTS OF A VENDOR RISK MANAGEMENT LIFE CYCLE PROGRAM Planning and risk assessment Due diligence and selection Contract negotiation and implementation Oversight and ongoing monitoring Business continuity and contingency plans 15
16 WHAT DOES THIS MEAN FOR VENDORS? Vendors need to implement a written compliance management system that includes the following elements (not an exhaustive list): Hire and maintain a compliance officer and needed staff Identify and comply with all applicable consumer protection laws Understand the products and services outsourced by the bank and review related marketing materials Conduct onsite due diligence visits to all material sub-service providers Maintain records demonstrating compliance with service level standards in any material contracts with banks Procedures to promptly notify the bank of significant regulatory inquiries or consumer complaints 16
17 WHAT CAN THE CONSEQUENCES BE? 17
18 THERE ARE ALSO NON-MONETARY CONSEQUENCES 18
19 A BIT ON VIRTUAL CURRENCIES
20 DIGITAL CURRENCIES CAN BE ELECTRONIC OR VIRTUAL Digital Currencies Electronic Virtual 20
21 DIGITAL CURRENCIES AREN T NEW Fiat currency is government-issued currency declared to be legal tender and has physical attributes Electronic currency is pegged to a fiat currency Digital representation of value that is government-issued legal tender The link between electronic currency and the fiat currency is preserved and has a legal foundation The stored funds are expressed in the same unit of account (e.g. U.S. dollar, euro, etc.) Virtual currency is not pegged to a traditional fiat currency Digital representation of value that is not government-issued legal tender The unit of account (e.g. U.S. dollar) is changed into a virtual one (e.g. bitcoins) Unregulated currency that is issued and usually controlled by its developers 21
22 THE NUMBER OF VIRTUAL CURRENCIES GROWS DAILY 22
23 A FEW MUSINGS ON VIRTUAL CURRENCIES Bitcoin and other virtual currencies are currently just a blip on the payments spectrum More promise as a payments system than a currency Consumer adoption is hampered by a lack of protections and difficulty of obtaining currency The regulatory environment still needs time to mature As the virtual currency regulatory environment evolves, will their benefits remain? The public ledger (blockchain) has potential benefits beyond payments 23
24 THANK YOU Douglas King
Vendor Management Best Practices
Vendor Management Best Practices Presented by: Raji Sathappan, MBA, CRCM, CISA, CAMS FMS East Coast Regional Conference September 2015 Certified Public Accountants Consultants Wealth Management Technology
More informationAny business relationship between a bank and another entity, by contract or otherwise
An Overview for Bank Directors Managing the Third Party Relationship Patrick Neuman Boardman & Clark LLP Madison, Wisconsin Any business relationship between a bank and another entity, by contract or otherwise
More informationVendor Management: Who the CFPB is Watching and Who They Are Expecting You to be Watching
Vendor Management: Who the CFPB is Watching and Who They Are Expecting You to be Watching John Barnes 713.210.7441 jbarnes@bakerdonelson.com Jessica Hinkie 713.210.7405 jhinkie@bakerdonelson.com Kat Statman
More informationServicing Issues Update
September 2014 Servicing Issues Update Regulatory Developments 1. Future Rulemaking. CFPB has indicated that it is reviewing its mortgage servicing regulations and may issue additional amendments and clarifications.
More informationGUIDANCE FOR MANAGING THIRD-PARTY RISK
GUIDANCE FOR MANAGING THIRD-PARTY RISK Introduction An institution s board of directors and senior management are ultimately responsible for managing activities conducted through third-party relationships,
More informationThird-Party Risk Management: Busting Myths and Telling Truths
Third-Party Risk Management: Busting Myths and Telling Truths Richik Sarkar, Esq. McDonald Hopkins LLC 600 Superior Avenue, East, Suite 2100 Cleveland, OH 44114 (216) 430-2009 rsarkar@mcdonaldhopkins.com
More informationChief Executive Officers of All National Banks, Department and Division Heads, and All Examining Personnel.
AL 2000 9 O OCC ADVISORY LETTER Comptroller of the Currency Administrator of National Banks Subject: Third-Party Risk TO: Chief Executive Officers of All National Banks, Department and Division Heads,
More informationRisks and Precautions with Title Lending
AL 2000 11 O OCC ADVISORY LETTER Comptroller of the Currency Administrator of National Banks Subject: Title Loan Programs TO: Chief Executive Officers of All National Banks, Department and Division Heads,
More informationCredit Union Liability with Third-Party Processors
World Council of Credit Unions Annual Conference Credit Union Liability with Third-Party Processors Andrew (Andy) Poprawa CEO, Deposit Insurance Corporation of Ontario Canada 1 Credit Union Liability with
More informationBoard Responsibility. A bank can outsource a task, but it cannot outsource the responsibility.
Third-Party Risk Board Responsibility The Board of Directors and senior management are ultimately responsible for managing activities conducted through third-party relationships as if the activity were
More informationManaging Sub-Servicing Partnerships
Managing Sub-Servicing Partnerships 2 Managing Sub-Servicing Partnerships WHY IT IS IMPORTANT TO GINNIE MAE: Ginnie Mae recognizes that there are entities that specialize in the servicing and are better
More informationVendor Management Compliance Top 10 Things Regulators Expect
Vendor Management Compliance Top 10 Things Regulators Expect Peter Davey, AAP VP & Director, Enterprise Payments, CapitalOne Pamela T. Rodriguez, AAP, CIA, CISA EVP, Risk Management & Education, EastPay
More informationVendor Management: An Enterprise-wide Focus. Susan Orr, CISA CISM CRISC CRP Susan Orr Consulting, Ltd.
Vendor Management: An Enterprise-wide Focus Susan Orr, CISA CISM CRISC CRP Susan Orr Consulting, Ltd. Why Focus on Vendor Management Increased financial regulatory scrutiny GLBA and Identity Theft Red
More informationNCUA LETTER TO CREDIT UNIONS
NCUA LETTER TO CREDIT UNIONS NATIONAL CREDIT UNION ADMINISTRATION 1775 Duke Street, Alexandria, VA 22314 DATE: August 2008 LETTER NO.: 08-CU-19 TO: SUBJ: Federally Insured Credit Unions Third-Party Relationships:
More informationPRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES
PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES TECHNICAL COMMITTEE OF THE INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS FEBRUARY 2005 Preamble The IOSCO Technical Committee
More informationVendor Management Compliance Top 10 Things Regulators Expect
Vendor Management Compliance Top 10 Things Regulators Expect Paul M. Phillips, CFA Attorney, Adams and Reese Pamela T. Rodriguez, AAP, CIA, CISA EVP, Risk Management & Education, EastPay 2014 EastPay.
More informationWhite Paper on Financial Institution Vendor Management
White Paper on Financial Institution Vendor Management Virtually every organization in the modern economy relies to some extent on third-party vendors that facilitate business operations in a wide variety
More informationThe rise of third party relationships means rise in risk and regulation. Non-compliance is risky business for financial institutions
The rise of third party relationships means rise in risk and regulation Non-compliance is risky business for financial institutions Increasing dependency on third parties by banks has resulted in mandatory
More informationUnderstanding the Fundamentals of Credit Union Third-Party Vendor Due Diligence
Understanding the Fundamentals of Credit Union Third-Party Vendor Due Diligence November 20, 2014 2 p.m. E. Andrew Keeney, Esq. Kaufman & Canoles, P.C. Sponsored by Affinion Benefits Group E. Andrew Keeney,
More informationCompany Name Vendor Management Policy and Procedure. Table of Contents
Policy and Procedure Table of Contents Table of Contents... i Introduction... 1 Risks of Using Vendors... 1 Vendor Due Diligence... 2 Monitoring... 2 Section 1 Personnel... 1 Section 2 - Outside Vendors
More informationOutsourcing Technology Services A Management Decision
Outsourcing Technology Services A Management Decision A Telephone Seminar for National Banks Tuesday, July 20, 2004 And again on Wednesday, July 21, 2004 Agenda Outsourcing activities and relationships
More informationVendor Management Best Practices
23 rd Annual and One Day Seminar Vendor Management Best Practices Catherine Bruder CPA, CITP, CISA, CISM, CTGA Michigan Texas Florida Insight. Oversight. Foresight. SM Doeren Mayhew Bruder 1 $100 billion
More informationOCC 98-3 OCC BULLETIN
To: Chief Executive Officers and Chief Information Officers of all National Banks, General Managers of Federal Branches and Agencies, Deputy Comptrollers, Department and Division Heads, and Examining Personnel
More informationOffice of Inspector General
Audit Report OIG-14-034 Not Sufficiently Documented April 21, 2014 Office of Inspector General Department of the Treasury Contents Audit Report Background... 2 Results of Audit... 4 OCC Has Updated Guidance
More informationIdentifying Key Risk Indicator
PUERTO RICO PAYMENTS SYMPOSIUM Identifying Key Risk Indicator EPOCPR Services Agenda for Today Background History Regulators & Risk Management Let s have fun Regulators & Risk Assessment ACH Risks Categories
More informationTo: Our Clients and Friends March 25, 2014
Financial Services Group To: Our Clients and Friends March 25, 2014 A Significant Change Is Occurring Regarding Regulatory Oversight of Banks and Their Third Party Relationships. Both Banks and their Vendors
More informationNavigating Vendor Management Issues in Today s Regulatory Environment
Navigating Vendor Management Issues in Today s Regulatory Environment May 6, 2015 Elizabeth E. McGinn, Partner Moorari K. Shah, Counsel 1 Disclaimer The information contained herein is for informational
More information9/13/2013. 20/20 Vision for Vendor Management & Oversight. Disclaimer. Bank Service Company Act - FIL-49-99
20/20 Vision for Vendor Management & Oversight 2013 WBA Technology Conference September 17, 2013 Ken M. Shaurette, CISSP, CISA, CISM, CRISC, IAM Director IT Services Disclaimer The views set forth are
More informationVENDOR RISK MANAGEMENT UPDATE- ARE YOU AT RISK? Larry L. Llirán, CISA, CISM December 10, 2015 ISACA Puerto Rico Symposium
1 VENDOR RISK MANAGEMENT UPDATE- ARE YOU AT RISK? Larry L. Llirán, CISA, CISM December 10, 2015 ISACA Puerto Rico Symposium 2 Agenda Introduction Vendor Management what is? Available Guidance Vendor Management
More informationGet in the Groove with the Regulatory Jazz: Cyber Security and Vendor Management Examinations from the Regulators and Auditors Perspective
Get in the Groove with the Regulatory Jazz: Cyber Security and Vendor Management Examinations from the Regulators and Auditors Perspective Rory Guenther, CISA Senior Examiner, Operational Risk Specialist,
More informationOutsourced Third Party Relationship Management/ Vendor Management. TTS Webinar July 15, 2015 Susan Orr CISA, CISM, CRISC, CRP
Outsourced Third Party Relationship Management/ Vendor Management TTS Webinar July 15, 2015 Susan Orr CISA, CISM, CRISC, CRP 1 Risk Management Guidance 2 3 Appendix J: 4 - Key Elements Third Party Management
More informationTO: Chief Executive Officers of National Banks, Federal Branches and Data-Processing Centers, Department and Division Heads, and Examining Personnel
AL 2000 12 O OCC ADVISORY LETTER Comptroller of the Currency Administrator of National Banks Subject: Risk Management of Outsourcing Technology Services TO: Chief Executive Officers of National Banks,
More informationCENTRAL BANK OF NIGERIA
CENTRAL BANK OF NIGERIA Guidance Notes on the Calculation of Capital Requirement for Operational Risk Basic Indicator Approach (BIA) and the Standardized Approach (TSA) TABLE OF CONTENTS OPERATIONAL RISK
More informationPRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES
PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES A CONSULTATION REPORT OF THE INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS STANDING COMMITTEE 3 ON MARKET INTERMEDIARIES
More informationFEDERAL HOUSING FINANCE AGENCY ADVISORY BULLETIN AB 2014-07 OVERSIGHT OF SINGLE-FAMILY SELLER/SERVICER RELATIONSHIPS. Purpose
FEDERAL HOUSING FINANCE AGENCY ADVISORY BULLETIN AB 2014-07 OVERSIGHT OF SINGLE-FAMILY SELLER/SERVICER RELATIONSHIPS Purpose This advisory bulletin communicates the Federal Housing Finance Agency s (FHFA)
More informationOffice of the State Bank Commissioner Guidance Document MT 2014-01
Office of the State Bank Commissioner Guidance Document MT 2014-01 Date: June 6, 2014 Regulatory Treatment of Virtual Currencies Under the Kansas Money Transmitter Act Purpose The purpose of this guidance
More informationBank Vendor Management An Aspirin to Prevent a Headache or Just a Headache?
April 2014 Bank Vendor Management An Aspirin to Prevent a Headache or Just a Headache? BY LAWRENCE D. KAPLAN & KEVIN L. PETRASIC A flurry of recent regulatory guidance, pronouncements and enforcement actions
More informationFinancial Services Guidance Note Outsourcing
Financial Services Guidance Note Issued: April 2005 Revised: August 2007 Table of Contents 1. Introduction... 3 1.1 Background... 3 1.2 Definitions... 3 2. Guiding Principles... 5 3. Key Risks of... 14
More informationThird-Party Senders Risks and Best Practices
Third-Party Senders Risks and Best Practices Please turn off all cell phones or mobile devices. Thank you to today s sponsors! This morning s refreshment break sponsored by The Royal Bank of Scotland EventMobile
More informationPreparing for the Outsourcing Challenge: Legal Due Diligence to Ensure a Winning Service Provider Relationship
THE 4 TH NATIONAL CONFERENCE ON OUTSOURCING IN FINANCIAL SERVICES NEGOTIATING, MANAGING & TERMINATING OUTSOURCING RELATIONSHIPS WHILE ENSURING REGULATORY COMPLIANCE Renaissance Mayflower, Washington, DC
More informationReverse Due Diligence A New Trend In Financial M&A
Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Reverse Due Diligence A New Trend In Financial M&A
More informationBlind spot Banks are increasingly outsourcing more activities to third parties. But they can t outsource the risks.
Blind spot Banks are increasingly outsourcing more activities to third parties. But they can t outsource the risks. For anyone familiar with the banking industry, it comes as no surprise that banks are
More informationSample Financial institution Risk Management Policy 2011
Sample Financial institution Risk Management Policy 2011 1 Contents Risk Management Program...2 Internal Control and Risk Management Diagram... 2 General Control Environment... 2 Specific Internal Control
More informationVII 4.1. VII. Unfair and Deceptive Practices Third Party Risk. Third Party Risk. Introduction. Background
Third Party Risk Introduction The board of directors and senior management of an insured depository institution (institution) are ultimately responsible for managing activities conducted through third-party
More informationCOMMENTARY. occ and fdic Guidance on Supervisory Concerns and Expectations Regarding Deposit Advance Products JONES DAY
December 2013 JONES DAY COMMENTARY occ and fdic Guidance on Supervisory Concerns and Expectations Regarding Deposit Advance Products The Office of the Comptroller of the Currency ( OCC ) and the Federal
More informationStandard: Application Service Provider Security Requirements
Standard: Application Service Provider Security Requirements Page 1 Executive Summary SJSU has the option to select and contract with approved 3 rd parties, application service providers, services and
More informationRisk Management of Outsourced Technology Services. November 28, 2000
Risk Management of Outsourced Technology Services November 28, 2000 Purpose and Background This statement focuses on the risk management process of identifying, measuring, monitoring, and controlling the
More informationGuidelines for Financial Institutions Outsourcing of Business Activities, Functions, and Processes Date: July 2004
Guidelines for Financial Institutions Outsourcing of Business Activities, Functions, and Processes Date: July 2004 1. INTRODUCTION Financial institutions outsource business activities, functions and processes
More informationVENDOR MANAGEMENT. General Overview
VENDOR MANAGEMENT General Overview With many organizations outsourcing services to other third-party entities, the issue of vendor management has become a noted topic in today s business world. Vendor
More informationJoint Guidance on Overdraft Protection Programs. February 18,2005
Attachment Office of the Comptroller of the Currency Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation National Credit Union Administration Joint Guidance on Overdraft
More informationWho s Regulating Whom & What are the Requirements: Banks As Payment Services Providers
Who s Regulating Whom & What are the Requirements: Banks As Payment Services Providers Tony DaSilva, AAP, CISA S&R Senior Technical Expert Federal Reserve Bank of Atlanta Disclaimer The opinions expressed
More informationThird Party Relationships
3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 A B D INTRODUCTION AND PURPOSE Background Yes/No Comments 1. Does the credit union maintain a list of the third party
More informationCompliance Risk Management Survey A Point of View
FINANCIAL SERVICES Compliance Risk Management Survey A Point of View July 2014 kpmg.com Compliance Risk Management Survey A Point of View 3 Introduction As the financial crisis unfolded, regulators looked
More informationThe Other Side of CFPB Compliance
The Other Side of CFPB Compliance Strengthening your compliance program via vendor management Legal Disclaimer This information is for the use of attendees only. Any distribution, reproduction, copying
More informationPutting the Management Back in Vendor Management February 20, 2014
Putting the Management Back in Vendor Management February 20, 2014 Moderator: Brian O Reilly The Collingwood Group, LLC Panelists: Calvin Hagins, CFPB Ken Markison, MBA Jonathan McKernan, Wilmer Hale Dan
More informationSUPERVISORY AND REGULATORY GUIDELINES: PU48-0809 GUIDELINES ON MINIMUM STANDARDS FOR THE OUTSOURCING OF MATERIAL FUNCTIONS
SUPERVISORY AND REGULATORY GUIDELINES: PU48-0809 ISSUED: 4 th May 2004 REVISED: 27 th August 2009 GUIDELINES ON MINIMUM STANDARDS FOR THE OUTSOURCING OF MATERIAL FUNCTIONS I. INTRODUCTION The Central Bank
More informationConsumer Affairs Laws Section 1380 and Regulations
Insurance Consumer Protection The Gramm-Leach-Bliley Financial Services Modernization Act (the Act) was enacted on November 12, 1999. Section 305 of the Act required the federal banking agencies (the Agencies)
More informationOCC BULLETIN OCC 2001-47
OCC BULLETIN Comptroller of the Currency Administrator of National Banks Subject: Third-Party Relationships Description: Risk Management Principles TO: Chief Executive Officers of National Banks, Federal
More informationWho s Your Vendor? Secondary Market Compliance and Title Agent Vendor Management
Who s Your Vendor? Secondary Market Compliance and Title Agent Vendor Management 2015 LBA Bank Counsel Conference Marx Sterbcow, Managing Attorney, Sterbcow Law Group The Bureau s Scrutiny of Vendor Management
More informationStatement of the Office of the Comptroller of the Currency. Provided to the Subcommittee on Financial Institutions and Consumer Protection
Statement of the Office of the Comptroller of the Currency Provided to the Subcommittee on Financial Institutions and Consumer Protection Senate Committee on Banking, Housing, and Urban Affairs Shining
More informationVendor Risk Management in the New Regulatory Environment. kpmg.com
Vendor Risk Management in the New Regulatory Environment kpmg.com Vendor Risk Management in the New Regulatory Environment 2 Vendor Risk Management in the New Regulatory Environment Background Regulators
More informationHandout for Rule-making meeting on May 20, 2016
Compare sections of Chapter 208-460 to 12 CFR 723 (2016). Handout for Rule-making meeting on May 20, 2016 Section of Existing State Rule WAC 208-460-040 WAC 208-460-040 How do you implement a member business
More informationA Cautionary Tale Plus Cross-Channel Risk
Dan Tobin A Cautionary Tale Plus Cross-Channel Risk IT Examiner Supervision, Regulation & Credit Dan.tobin@bos.frb.org Agenda A Cautionary Tale Shames-Yeakel v. Citizens Financial Bank Cross-Channel Risk
More informationGUIDELINE ON THE APPLICATION OF THE OUTSOURCING REQUIREMENTS UNDER THE FSA RULES IMPLEMENTING MIFID AND THE CRD IN THE UK
GUIDELINE ON THE APPLICATION OF THE OUTSOURCING REQUIREMENTS UNDER THE FSA RULES IMPLEMENTING MIFID AND THE CRD IN THE UK This Guideline does not purport to be a definitive guide, but is instead a non-exhaustive
More informationCFPB Update: Regulatory and Enforcement Developments
CFPB Update: Regulatory and Enforcement Developments December 16, 2014, 12:30 1:30 pm ET American Law Institute Webinar Jonathan L. Pompan Alexandra Megaris 1 Agenda Supervision and Examinations What is
More informationBITS GUIDE TO CONCENTRATION RISK
BITS GUIDE TO CONCENTRATION RISK IN OUTSOURCING RELATIONSHIPS BITS A DIVISION OF THE FINANCIAL SERVICES ROUNDTABLE 1001 PENNSYLVANIA AVENUE, NW SUITE 500 SOUTH WASHINGTON, DC 20004 202-289-4322 WWW.BITS.ORG
More informationVendor Compliance Management Series: Performing an Effective Risk Assessment
Vendor Compliance Management Series: Performing an Effective Risk Assessment Legal Disclaimer This information is not intended to be legal advice and may not be used as legal advice. Legal advice must
More informationTable of Contents... 1. Chapter 1 Introduction... 5. 1.1 Goals & Objectives... 5 1.2 Required Review... 5 1.3 Applicability...
... 1 Chapter 1 Introduction... 5 1.1 Goals & Objectives... 5 1.2 Required Review... 5 1.3 Applicability... 5 Chapter 2 Company Culture... 6 Chapter 3 Risk Management Governance... 7 3.1 Board of Directors...
More informationConsumer Financial Services. Industry-leading counsel in regulatory compliance, product development, and litigation. Attorney Advertising
Consumer Financial Services Industry-leading counsel in regulatory compliance, product development, and litigation Attorney Advertising Recognized for national excellence by Chambers. Vast regulatory experience.
More informationThe very dangerous intersection of UDAAP and vendor mismanagement. By Martin J. Bishop
The very dangerous intersection of UDAAP and vendor mismanagement By Martin J. Bishop (Martin J. Bishop is vice chair of the Litigation Department and co-chair of the Consumer Financial Services Practice
More informationTHE UH OH MOMENT. Financial Services Enterprises Focus on Governance, Transparency and Supply Chain Risk
THE UH OH MOMENT Financial Services Enterprises Focus on Governance, Transparency and Supply Chain Risk By Lois Coatney, Chuck Walker and Joseph Yacura, ISG Directors www.isg-one.com INTRODUCTION A top
More informationBank Secrecy Act Anti-Money Laundering Examination Manual
Bank Secrecy Act Anti-Money Laundering Examination Manual Core Overview - Customer Identification Program Assess the bank's compliance with the statutory and regulatory requirements for the Customer Identification
More informationGuidelines. ADI Authorisation Guidelines. www.apra.gov.au Australian Prudential Regulation Authority. April 2008
Guidelines ADI Authorisation Guidelines April 2008 www.apra.gov.au Australian Prudential Regulation Authority Disclaimer and copyright These guidelines are not legal advice and users are encouraged to
More informationOvercoming the challenges to growth for broker-dealers
Overcoming the challenges to growth for broker-dealers The months ahead will be a challenging time for the financial services sector, and broker-dealers face significant uncertainty. A broad spectrum of
More informationWhite Paper THE FIVE STEPS TO MANAGING THIRD-PARTY RISK. By James Christiansen, VP, Information Risk Management
White Paper THE FIVE STEPS TO MANAGING THIRD-PARTY RISK By James Christiansen, VP, Information Management Executive Summary The Common Story of a Third-Party Data Breach It begins with a story in the newspaper.
More informationACH Operations Bulletin #1-2014
ACH Operations Bulletin #1-2014 Questionable ACH Debit Origination: Roles and Responsibilities of ODFIs and RDFIs September 30, 2014 Replaces ACH Operations Bulletin #2-2013 (Originally Issued March 14,
More informationVendor Risk Management (VRM), How Much Is Enough?
Vendor Risk Management (VRM), How Much Is Enough? Purpose: This paper discusses which vendor relationships should be included in an institution s vendor oversight program and to what level they should
More informationThe New Third-Party Oversight Framework: Trust but Verify kpmg.com
Financial Services Regulatory Point of View The New Third-Party Oversight Framework: Trust but Verify kpmg.com The New Third-Party Oversight Framework: Trust but Verify 1 Financial services regulatory
More informationGUIDANCE NOTE OUTSOURCING OF FUNCTIONS BY ENTITIES LICENSED UNDER THE PROTECTION OF INVESTORS (BAILIWICK OF GUERNSEY) LAW, 1987
GUIDANCE NOTE OUTSOURCING OF FUNCTIONS BY ENTITIES LICENSED UNDER THE PROTECTION OF INVESTORS (BAILIWICK OF GUERNSEY) LAW, 1987 CONTENTS Page 1. Introduction 3-4 2. The Commission s Policy 5 3. Outsourcing
More informationBank Secrecy Act Regulations Definitions and Other Regulations Relating to Money Services Businesses, 76 FR 43585 (July 21, 2011).
RULING FIN-2015-R001 Issued: August 14, 2015 Subject: Application of FinCEN s Regulations to Persons Issuing Physical or Digital Negotiable Certificates of Ownership of Precious Metals Dear [ ]: This responds
More informationThird-Party Due Diligence Report Rules. Last Updated: December 2014
Third-Party Due Diligence Report Rules Last Updated: December 2014 Introduction In August 2014, the SEC approved final rules implementing Section 932 of the Dodd-Frank Act, which required the SEC to, among
More informationConflicts of Interest
Comptroller s Handbook AM-CI Asset Management (AM) Conflicts of Interest January 2015 Office of the Comptroller of the Currency Washington, DC 20219 Contents Introduction...1 Overview... 1 Types of Conflicts
More informationInformation Technology
Information Technology Information Technology Session Structure Board of director actions Significant and emerging IT risks Practical questions Resources Compensating Controls at the Directorate Level
More informationCONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS
CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS STATEMENT ON SUBPRIME MORTGAGE LENDING I. INTRODUCTION
More information{Regulatory Compliance Update.} December 10, 2014
{Regulatory Compliance Update.} December 10, 2014 Presenter Elizabeth Snyder, CRCM, Regulatory Compliance Manager Elizabeth leads Plante Moran s regulatory compliance team. As a compliance specialist with
More informationVermont Department of Financial Regulation. Together...Working for Vermont
Vermont Department of Financial Regulation Together...Working for Vermont PROTECTS, LICENSES, AND REGULATES T he Department of Financial Regulation (DFR) is a state agency that touches the lives of every
More informationCONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS
CONFERENCE OF STATE BANK SUPERVISORS AMERICAN ASSOCIATION OF RESIDENTIAL MORTGAGE REGULATORS NATIONAL ASSOCIATION OF CONSUMER CREDIT ADMINISTRATORS STATEMENT ON SUBPRIME MORTGAGE LENDING I. INTRODUCTION
More informationFinTech Webinar Series: Vendor Management Principles
FinTech Webinar Series: Vendor Management Principles Evolving Best Practices of Bank Service Providers February 14, 2013 Speakers Russell Bruemmer Partner Eric Mogilnicki Partner Jeffrey Hydrick Special
More informationCFPB Consumer Laws and Regulations
Secure and Fair Enforcement for Mortgage Licensing Act 1 The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 2 () was enacted on July 30, 2008, and mandates a nationwide licensing and registration
More informationMorgan Stanley. Policy for the Management of Third Party Residential Mortgage Servicing Providers
Morgan Stanley Policy for the Management of Third Party Residential Mortgage Servicing Providers Title Policy for the Management of Third Party Residential Mortgage Servicing Providers Effective Date Owner
More informationVII 5.1. VII. Abusive Practices Third Party Procedures. Third Party Risk. Introduction. Background
Third Party Risk Introduction The board of directors and senior management of an insured depository institution (institution) are ultimately responsible for managing activities conducted through third-party
More informationWEBLINKING: IDENTIFYING RISKS AND RISK MANAGEMENT TECHNIQUES
Federal Deposit Insurance Corporation National Credit Union Administration Office of Thrift Supervision Office of the Comptroller of the Currency April 23, 2003 WEBLINKING: IDENTIFYING RISKS AND RISK MANAGEMENT
More informationCompliance and Operational Services for Online Lenders
Compliance and Operational Services for Online Lenders VP Compliance Services, LLC October 2014 Company Overview VP Compliance Services (VPCS) is a leading provider of compliance and operational services
More informationOffice of Financial Regulation. Alisa Goldberg Chief, Bureau of Registration Division of Securities
Office of Financial Regulation Alisa Goldberg Chief, Bureau of Registration Division of Securities 1 History The Office of Financial Regulation (OFR) was created in 203 by section 20.121(3), Florida Statutes,
More informationExecutive Fraud Forum October 30, 2013
Executive Fraud Forum October 30, 2013 Payments Fraud Trends Mary Kepler, Director, Retail Payments Risk Forum, Federal Reserve Bank of Atlanta Judy Long, Executive Vice President, First Citizens National
More informationAutomated valuation models: Changes in the housing market require additional risk management considerations
Automated valuation models: Changes in the housing market require additional risk management considerations Overview From 2003 to 2006, the US residential real estate market experienced an unprecedented
More informationRISK FACTORS AND RISK MANAGEMENT
Bangkok Bank Public Company Limited 044 RISK FACTORS AND RISK MANAGEMENT Bangkok Bank recognizes that effective risk management is fundamental to good banking practice. Accordingly, the Bank has established
More information<please respond here>
Accountability and Scope of Outsourcing IOSCO Introduction 1 What functions (if any), does your firm outsource? Please explain what factors led to the decision to outsource. If no functions are outsourced,
More informationCompliance Management Systems A Blueprint for Success
Compliance Management Systems A Blueprint for Success Date or subtitle May 13, 2015 1 Tim Tedrick, CRCM, CRP Partner 815.626.1277 ttedrick@wipfli.com 2 Page 1 Regulatory FDIC https://www.fdic.gov/regulations/compliance/manual/p
More information