AML Model Validation Beyond the Guidance
|
|
- Ross Tucker
- 7 years ago
- Views:
Transcription
1 AML Mdel Validatin Beynd the Guidance By: Salvatre Cangialsi February, 2014 Intrductin The Office f the Cmptrller f the Currency and the Federal Reserve have bth issued guidance n Mdel Risk Management. The supervisry guidance applies bradly t all quantitative mdels used thrughut a banking rganizatin in the peratin f their business. Such mdels are widely used within AML cmpliance grups. They are primarily implemented thrugh the AML sftware slutins; but are als implemented via spreadsheets and ther tls used by the cmpliance rganizatin. A key aspect f Mdel Risk Management is a rbust validatin prcess. The validatin prcess emplyed by AML cmpliance grups has received increasing attentin frm regulatrs. Sme banks have been unprepared fr the level f regulatry review and rigr expected ver Mdel Validatins. This article will prvide real wrld insights and guidance n the current issues related t the validatin f mdels used fr AML cmpliance. Overview f the Guidance as Applied t AML SR Letter 11-7 f April 4, 2011 ( prvides revised and cmprehensive guidance n Mdel Risk Management. The guidance addresses amng ther tpics Mdel Validatin. As applied t AML, the guidance is meant t assure that: The prper mdels are chsen, The mdels perate crrectly, and The implementatin and use f the mdels are apprpriate fr the risk f the bank. The primary mdels used by mst banks include: Custmer nbarding and retentin, Custmer and AML risk rating, Suspicius activity detectin scenaris, Scring, and OFAC/Sanctins vilatin detectin. These mdels must be independently validated by all banks. The validatin must be independent f the develpers and users f the mdels. The independent validatin may be perfrmed by an internal grup such as audit. It may als be perfrmed by third party cnsultants having adequate expertise. Hwever, the bank remains respnsible fr verseeing the results f the wrk perfrmed by third parties.
2 A key element f the guidance is hw the risk, business activity, and the cmplexity f the mdels shuld be cnsidered in the manner in which a validatin is perfrmed. Recent Trends In general, AML cmpliance examinatins are increasing in scpe and cmplexity. Findings are becming mre difficult t address while the risk f a regulatry enfrcement actin has increased. It has als been rumred that there will be a higher prbability f criminal prsecutins related t egregius AML deficiencies. Given this backdrp, which is nt new t the Chief Cmpliance Officer (CCO), it is prudent t track examinatin trends and adapt peratins as apprpriate t the bank. The fcus f this sectin is n the recent trends applicable t Mdel Validatins which are as fllws: Increased Examinatin Fcus. Nearly all f the banks we have spken with have fund that a review f the Mdel Validatin prcess was part f their verall AML examinatins. This has been nging and appears t als nw apply t a wider range f small financial institutins. Additinally, the depth f review f the Mdel Validatin prcess has increased. Evlving Requirements. The manner in which the Mdel Validatin prcess is reviewed seems t vary substantially acrss individual regulatrs. T sme extent, this is related t the risk and activities f the bank. Hwever, much f the variance des nt appear t be explained by risk alne. One can assume that, given the newness f this increased fcus, best practices acrss regulatrs have nt fully matured. Cnsequently, it may be difficult fr a bank t anticipate the level f review and their expected perfrmance in this area. Expected Rigr and Quantitative Prcess. What has been a cnsistent trend in recent examinatins is the expected rigr and demand fr quantitative supprt fr judgments reached in a Mdel Validatin. This is nt surprising given that a quantitative apprach is an essential aspect f verall Mdel Risk Management. Nevertheless, the mathematic, statistical, ecnmic, and analytic skills needed fr the expected level f rigr are nt always available r anticipated by a bank prir t an examinatin. The CRAD. The Cmpliance Risk Analysis Divisin f the OCC is cmprised f highly skilled prfessinals in the area f statistical analysis and ecnmetric mdels. The grup is primarily staffed with Ph. D.s in ecnmics and statistics. They prvide brad supprt fr the OCC's supervisry and regulatry initiatives. A number f the banks we have spken with have had the CRAD play a rle in their AML examinatins. The grup has reviewed and prvided substantive challenges t the suspicius activity mdels used by thse banks. With respect t thse challenges, the bank is expected t justify, in a quantitative manner, detectins rules chsen and the threshlds applied t rules. A Questin f Cst vs Scpe. The OCC has prvided guidance n the use f cnsultants as part f an enfrcement actin. See html. Althugh this des nt directly apply t Mdel Validatins, it clearly highlights the OCC's interest ver a bank's due diligence ver third party cnsultants and the cntracts entered int with them. We call attentin t this as a bank pinted ut the OCC's cncern with the cst f
3 an assessment prject. In essence the OCC felt that the cst prvided was t lw t cver the full scpe f wrk that wuld be needed t perfrm a prper Mdel Validatin. Althugh there was misunderstanding by the OCC as t what the actual prject's gals were, it suggests that banks shuld take care in the definitin f the scpe f wrk and the due diligence applied twards third party cnsulting cntracts. Cnfusin with System Assessments. Many banks have perfrmed AML system assessments. Again, this wrk is ften carried ut by independent cnsultants. It is cmmn that the definitin f a system assessment varies frm ne cnsultant t anther. Generally, the assessment will cver a review f rules that partially r fully meets the criteria fr a Mdel Validatin. With increased regulatry fcus n Mdel Validatins, the clarity f the definitin applied t a system assessment must be assured. Challenges Encuntered by Banks With an increasing fcus n a larger range f banks, Mdel Validatins need t be cnsidered a pririty by all CCOs. In develping a prcess fr sund validatins, ne must understand the challenges t that utcme. These challenges can be bradly categrized as: Validatin Apprach. Althugh the OCC guidelines apply t all Mdel Validatins, its implementatin can vary greatly frm bank t bank. The variability is based n several factrs including AML specific requirements, risk prfile, and the views f the regulatr. Withut the benefit f several refinements t the prcess, a bank may face strng criticism that can lead t regulatry actins. System Limitatins. Mdel Validatins are inherently system fcused. Mst AML systems are acquired frm a sftware vendr. The vendr has a prprietary interest in maintaining their intellectual prperty rights and will ften prvide mdels as a "black bx". Withut adequate disclsure frm the sftware vendr, the crrectness f mdel design and implementatin cannt be directly assessed. Validatin is limited t a testing and analysis methdlgy which is less cmprehensive. Required Skill Set. This is the mst difficult challenge fr many banks. A prper Mdel Validatin requires a range f skill sets that may nt be available r are nt easily accessible t the bank. Essentially a team apprach is needed fr the validatin. The team shuld be cmpsed f members with the fllwing skills: AML cmpliance dmain expertise AML system expertise Ecnmetric, statistical, and mathematical Data analytics Audit Needed Tls. Accessing and analyzing data, perfrming tests, and interpreting results are greatly enhanced with the availability f autmated tls. These tls include: AML typlgy mdels
4 Data analytics platfrms Data analytics platfrms such as Tableau, Sptfire, and many thers can be acquired frm cmmercial vendrs. Hwever, they require a learning curve r existing in-huse expertise. AML typlgy tls are mre prblematic. They are highly cmplex, are nt cmmercially available, and very few practitiners in the AML Mdel Validatin space have the expertise t develp these systems. Reliance n Cnsultants. With the range f skills required fr a validatin, banks may emply an independent cnsulting firm t perfrm part r mst f the required wrk. Where the bank is lacking familiarity f the verall requirements fr an AML Mdel Validatin, the selectin prcess can be difficult. Further adding t the difficulty is the large number f small cnsulting firms that will engage cntractrs fr the wrk perfrmed. The use f cntractrs by the cnsulting firm can lead t incnsistent prcesses and a lack f cntinuity ver subsequent engagements. Cmmunicating with Regulatrs. There is much latitude in the implementatin f a Mdel Validatin prcess. When the bank takes an apprach that is nt fully understd by the regulatr r where the regulatr suggest an alternate apprach, it is required that the bank adequately explain all aspects f the validatin apprach. The explanatin may need t be made t the primary regulatr as well as t specialized teams such as the CRAD. Each f these grups may require a different level f detail and explanatin. Having the apprpriate staff t prvide these explanatins is ften a challenge. Budgeting. Senir management must fully understand the imprtance, scpe f wrk, and time cmmitment needed fr a successful Mdel Validatin. Whether the wrk is dne with in-huse staff r by third party cnsultants, adequate resurces must be made available. Given this need, the CCO alng with audit must develp a justificatin apprach that will be successful. Recmmendatins Perfrming a Mdel Validatin fr a financial institutin is clearly nt a simple undertaking. The range f skill sets needed and the challenges inherent in the prcess call fr a well-rganized apprach. In this sectin, we prvide a number f categrized recmmendatins that shuld be cnsidered. Gvernance 1. It is highly recmmended that the CCO assure the invlvement f senir management. 2. Final reprts shuld be delivered t the bard f directrs r similar versight structure. 3. The firm r internal grup perfrming the Mdel Validatin must be clearly independent f the creatin and use f the mdels. Regulatry Cnsideratins 1. The bank's regulatrs shuld be cnsulted peridically cncerning plans fr the Mdel Validatin.
5 2. The CCO shuld develp a netwrk f peers and cnsultants that he can reach ut t peridically t discuss current regulatry expectatins and findings. 3. Cmprehensive dcumentatin shuld be develped t supprt the Mdel Validatin. This dcumentatin at a minimum shuld include: a. The statement f wrk r ther dcument describing the scpe f the engagement and any specific limitatins. It is essential that the scpe f wrk be clearly detailed. It is als imprtant that the scpe f wrk indicate that it will be perfrmed in accrdance with OCC guidelines fr Mdel Validatins. b. Bis f the peple participating in the validatin. c. Detailed and cmprehensive prject plan. d. Written reprt with separate versin cntrl dcumenting the reasn that changes were made. e. Wrk papers. Qualificatins 1. The qualificatins f the firm and the specific team assigned t a Mdel Validatin must be reviewed. It is recmmended that the engagement shuld be perfrmed by a team. The team shuld be made up f individuals with the fllwing skills: Planning a. Subject matter expertise in AML and Sanctins Cmpliance with strng experience guiding Mdel Validatins. b. Quantitative analysis. This individual shuld have demnstrable skills evidenced by an apprpriate mathematics r statistics degree and a prven recrd f experience. c. Technical business analyst. A persn able t access and evaluate data frm multiple system surces and with a gd understanding f the business needs f the AML Cmpliance Grup. d. Strng prject management experience. It is nt necessary that these skills be represented by separate peple. Fr example, in a smaller engagement the subject matter expert may als prvide verall prject management. Further, it is cmmn that the quantitative analyst will have the database and ther technical skills t wrk with the varius systems. 1. Prir t starting an engagement, it is essential that the cntract, statement f wrk, r internal prject descriptin clearly describe that a Mdel Validatin is t be perfrmed in accrdance with
6 OCC and Federal Reserve guidelines. Fr a number f reasns, a bank may decide that the prject will nt fully cnfrm t thse guidelines. Perhaps sme f the wrk will be dne by bank staff and ther wrk by a third party cnsulting firm. It is essential that all wrk that will be perfrmed, as well as wrk that is excluded, be clearly described at the pint f apprving the prject and dcumented in the final reprt t the CCO. 2. Dcumentatin shuld als identify verall respnsibility fr the prject and specific respnsibilities fr key phases, particularly when wrk is dne by third party firms. 3. When parts f an verall Mdel Validatin are dne by separate grups, the verall prject plan shuld dcument hw the separate reprts will be reviewed and relied upn t issue an pinin. 4. The prject plan itself shuld be prepared prir t the cmmencement f wrk. It shuld detail all majr tasks, respnsibilities, and timelines fr cmpletin. Peridic review f prgress against the plan shuld be undertaken and dcumented. 5. The validatin shuld be guided by a cmprehensive framewrk. The framewrk is ne that shuld be applicable in general t any independent assessment and als cntain the detailed requirements fr a Mdel Validatin. In particular the framewrk shuld address: Review a. Key stakehlders and their invlvement b. Prject planning and reprting c. Data cnfidentiality and security prtcls d. Required tls and ther supprts e. Infrmatin gathering prcess f. Methds f analysis g. List f all dcumentatin and artifacts needed h. Test perid, plans, cases, and results i. Reprt preparatin, review, and apprval j. Wrk paper management k. Methdlgy fr fllwing up n findings 1. Develp r update the catalg f all mdels used by the AML cmpliance grup. The catalg shuld cntain: a. Name f the mdel b. Purpse c. Descriptin f its peratin d. Data requirements e. Cntrl parameters f. Expected results g. Scheduling h. Date validated prir t use
7 i. Date implemented j. Date f last validatin k. Other pertinent ntes 2. Gather and evaluate the change cntrl prcess used fr mdel develpment and implementatin. 3. Obtain the AML Risk Assessment, business requirements dcument and ther infrmatin that describes the ratinale fr the mdels used by the AML grup. 4. Dcument and perfrm an assessment f verall gvernance related t Mdel Risk Management, plicies, and cntrls. 5. Befre analyzing mdels, it is essential that the mdel develpment prcess be reviewed t assure that it meets the OCC guidelines. Fr mdels prvided by third parties, the bank must receive sufficient infrmatin t judge cnfrmance. Sme f the infrmatin that shuld be reviewed includes: a. BIOs f key individuals invlved with mdel develpment b. Dcumentatin f all mdels describing their purpse, expected results, and cntrl parameters r ther mechanisms that influence prcessing results. 6. Obtain and review all prir Mdel Validatin and User Acceptance Test reprts. 7. Fr each mdel in the catalg, review and assess the sundness f its implementatin. Testing 1. All tests perfrmed f mdels shuld be cnducted with a data repsitry develped specifically fr the purpse f Mdel Validatin. The data repsitry shuld be cnstructed t supprt all tests and the range f utcmes expected. 2. A statistically valid methdlgy fr data sampling must be determined and dcumented. Nte that data sampling may be needed fr varius test gals and therefre the sampling methdlgy shuld be cnsistent with the data, vlumes, and test gals. 3. Perfrm a cmprehensive data quality review. The data quality review shuld address: a. Accuracy f data elements used by the mdels. Fr example, des the database cntain the latest values fr each transactin? Or, might data be added t the database prir t a mdificatin in the riginating system. b. Cmpleteness f the data. Are all relevant fields representing a transactin present? Often the details frm the riginating message are separate frm the recrding f the banking transactin. In this case are the tw surces cmbined apprpriately? Als cnsider that data elements may be ptinal in the riginating system. If s, is this addressed in the AML
8 system? Cnsider further, data that may nt exist in the riginating message. Fr example, jurisdictinal data such as cuntries which are essential t mnitring may be mitted. c. Cnsistency. Are the same data values represented in a cnsistent manner? An example f this issue is in the use f incnsistent abbreviatins. Anther frm f incnsistency wuld be the rder in which names are recrded. 4. Tests shuld be cnducted that verify that all mdels perfrm in accrdance with their intended functinality. This can be accmplished in several ways and are generally termed back testing. One methd is t use a tl that simulates hw each mdel shuld perfrm. The simulatin is then applied t histrical data t assure that the same results that were riginally btained against histrical data are again received. Any variatin shuld be explained as acceptable r nt. 5. In additin t back testing, a series f "Abve the Line" (ATL) and "Belw the Line " (BTL) tests shuld be perfrmed. These tests are designed t evaluate each mdel's behavir against changes in their threshlds r ther cntrl mechanisms. A key utcme f the tests is an assessment f the threshld changes n false psitives and false negatives. One way f visualizing the impact f the changes is with a Dispsitin Curve. This graph will shw the increasing r decreasing rate f prductive alerts fr the changes made t threshlds. Analysis The analysis prcess shuld be dcumented and cmprehensive. The specific analytical methds will vary based n the factrs discussed abve. But ften they shuld include: 1. Review and explanatin f differential alerts frm Abve and Belw the Line Testing 2. Assessment f the change in the number if prductive alerts as threshlds are mdified. 3. Assessment f prductivity levels against AML risk assessment and acceptable risk 4. Dispsitin curves that graphically present the relatinship between parameter changes and prductive alerts 5. Assessment f false psitives and false negatives 6. Analysis f time spent n varius alert types 7. Review f quality cntrls
SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM
Audit Manual Sectin J SECTION J QUALITY ASSURANCE AND IMPROVEMENT PROGRAM Ref. Plicy and Practice Requirements IIA Standards and Other references J 1 Plicy: The Head f Internal Audit shall develp and maintain
More informationInternal Audit Charter and operating standards
Internal Audit Charter and perating standards 2 1 verview This dcument sets ut the basis fr internal audit: (i) the Internal Audit charter, which establishes the framewrk fr Internal Audit; and (ii) hw
More informationFINANCIAL SERVICES FLASH REPORT
FINANCIAL SERVICES FLASH REPORT Draft Regulatry Cmpliance Management Guideline Released by the Office f the Superintendent f Financial Institutins May 5, 2014 On April 30, 2014, the Office f the Superintendent
More informationAudit Committee Charter
Audit Cmmittee Charter Membership The Audit Cmmittee (the "Cmmittee") f the Bard f Directrs (the "Bard") f Philip Mrris Internatinal Inc. (the "Cmpany") shall cnsist f at least three directrs all f whm
More informationMSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER
MSB FINANCIAL CORP. MILLINGTON BANK AUDIT COMMITTEE CHARTER This Audit Cmmittee Charter has been amended as f July 17, 2015. The Audit Cmmittee shall review and reassess this Charter annually and recmmend
More informationCDC UNIFIED PROCESS PRACTICES GUIDE
Dcument Purpse The purpse f this dcument is t prvide guidance n the practice f Business Case and t describe the practice verview, requirements, best practices, activities, and key terms related t these
More informationCMS Eligibility Requirements Checklist for MSSP ACO Participation
ATTACHMENT 1 CMS Eligibility Requirements Checklist fr MSSP ACO Participatin 1. General Eligibility Requirements ACO participants wrk tgether t manage and crdinate care fr Medicare fee-fr-service beneficiaries.
More informationCASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT
CASSOWARY COAST REGIONAL COUNCIL POLICY ENTERPRISE RISK MANAGEMENT Plicy Number: 2.20 1. Authrity Lcal Gvernment Act 2009 Lcal Gvernment Regulatin 2012 AS/NZS ISO 31000-2009 Risk Management Principles
More informationUNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES
UNIVERSITY OF CALIFORNIA MERCED PERFORMANCE MANAGEMENT GUIDELINES REFERENCES AND RELATED POLICIES A. UC PPSM 2 -Definitin f Terms B. UC PPSM 12 -Nndiscriminatin in Emplyment C. UC PPSM 14 -Affirmative
More informationProfessional Leaders/Specialists
Psitin Prfile Psitin Lcatin Reprting t Jb family Band BI/Infrmatin Manager Wellingtn Prfessinal Leaders/Specialists Band I Date February 2013 1. POSITION PURPOSE The purpse f this psitin is t: Lead and
More informationITIL Release Control & Validation (RCV) Certification Program - 5 Days
ITIL Release Cntrl & Validatin (RCV) Certificatin Prgram - 5 Days Prgram Overview ITIL is a set f best practices guidance that has becme a wrldwide-adpted framewrk fr Infrmatin Technlgy Services Management
More informationJob Profile Data & Reporting Analyst (Grant Fund)
Jb Prfile Data & Reprting Analyst (Grant Fund) Directrate Lcatin Reprts t Hurs Finance Slihull Finance Directr Nminally 37 hurs but peratinally available at all times t meet Cmpany requirements Cntract
More informationProcess Improvement Center of Excellence Service Proposal Recommendation. Operational Oversight Committee Report Submission
Prcess Imprvement Center f Excellence Service Prpsal Recmmendatin Operatinal Oversight Cmmittee Reprt Submissin INTRODUCTION This Prpsal prvides initial infrmatin regarding a pssible additin t a service.
More informationAudit Committee Charter. St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd
Audit Cmmittee Charter St Andrew s Insurance (Australia) Pty Ltd St Andrew s Life Insurance Pty Ltd St Andrew s Australia Services Pty Ltd Versin 2.0, 22 February 2016 Apprver Bard f Directrs St Andrew
More informationInformation Technology Services. University of Maine System. Version 0.07. December 20, 2012
IT PROJECT MANAGEMENT OFFICE (PMO) CHARTER Infrmatin Technlgy Services University f Maine System Versin 0.07 December 20, 2012 Prepared by: Rbin Sherman Authrized by: [1] Table f Cntents EXECUTIVE SUMMARY...
More informationRequest for Resume (RFR) CATS II Master Contract. All Master Contract Provisions Apply
Sectin 1 General Infrmatin RFR Number: (Reference BPO Number) Functinal Area (Enter One Only) F50B3400026 7 Infrmatin System Security Labr Categry A single supprt resurce may be engaged fr a perid nt t
More informationSystems Load Testing Appendix
Systems Lad Testing Appendix 1 Overview As usage f the Blackbard Academic Suite grws and its availability requirements increase, many custmers lk t understand the capability f its infrastructure. As part
More informationCorporate Standards for data quality and the collation of data for external presentation
The University f Kent Crprate Standards fr data quality and the cllatin f data fr external presentatin This paper intrduces a set f standards with the aim f safeguarding the University s psitin in published
More informationChange Management Process
Change Management Prcess B1.10 Change Management Prcess 1. Intrductin This plicy utlines [Yur Cmpany] s apprach t managing change within the rganisatin. All changes in strategy, activities and prcesses
More informationNEW YORK STATE DEPARTMENT OF HEALTH BUREAU OF DENTAL HEALTH SCHOOL-BASED HEALTH CENTER DENTAL PROGRAM PERFORMANCE EFFECTIVENESS REVIEW TOOL (PERT)
NEW YORK STATE DEPARTMENT OF HEALTH BUREAU OF DENTAL HEALTH SCHOOL-BASED HEALTH CENTER DENTAL PROGRAM PERFORMANCE EFFECTIVENESS REVIEW TOOL (PERT) March 1, 2007 TABLE OF CONTENTS SECTION I: INTRODUCTION
More informationCDC UNIFIED PROCESS PRACTICES GUIDE
Dcument Purpse The purpse f this dcument is t prvide guidance n the practice f Risk Management and t describe the practice verview, requirements, best practices, activities, and key terms related t these
More informationPOLICY 1390 Information Technology Continuity of Business Planning Issued: June 4, 2009 Revised: June 12, 2014
State f Michigan POLICY 1390 Infrmatin Technlgy Cntinuity f Business Planning Issued: June 4, 2009 Revised: June 12, 2014 SUBJECT: APPLICATION: PURPOSE: CONTACT AGENCY: Plicy fr Infrmatin Technlgy (IT)
More informationENTERPRISE RISK MANAGEMENT ENTERPRISE RISK MANAGEMENT POLICY
ENTERPRISE RISK MANAGEMENT POLICY Plicy N. 10014 Review Date Octber 1, 2014 Effective Date March 1, 2014 Crss- Respnsibility Vice President, Reference Administratin Apprver Executive Cuncil 1. 1. Plicy
More informationResearch Report. Abstract: The Emerging Intersection Between Big Data and Security Analytics. November 2012
Research Reprt Abstract: The Emerging Intersectin Between Big Data and Security Analytics By Jn Oltsik, Senir Principal Analyst With Jennifer Gahm Nvember 2012 2012 by The Enterprise Strategy Grup, Inc.
More informationChapter 7 Business Continuity and Risk Management
Chapter 7 Business Cntinuity and Risk Management Sectin 01 Business Cntinuity Management 070101 Initiating the Business Cntinuity Plan (BCP) Purpse: T establish the apprpriate level f business cntinuity
More informationThis report provides Members with an update on of the financial performance of the Corporation s managed IS service contract with Agilisys Ltd.
Cmmittee: Date(s): Infrmatin Systems Sub Cmmittee 11 th March 2015 Subject: Agilisys Managed Service Financial Reprt Reprt f: Chamberlain Summary Public Fr Infrmatin This reprt prvides Members with an
More informationPresentation: The Demise of SAS 70 - What s Next?
Presentatin: The Demise f SAS 70 - What s Next? September 15, 2011 1 Presenters: Jeffrey Ziplw - Partner BlumShapir Jennifer Gerasimv Senir Manager Delitte. SAS 70 Backgrund and Overview Purpse f a SAS
More informationThe Importance Advanced Data Collection System Maintenance. Berry Drijsen Global Service Business Manager. knowledge to shape your future
The Imprtance Advanced Data Cllectin System Maintenance Berry Drijsen Glbal Service Business Manager WHITE PAPER knwledge t shape yur future The Imprtance Advanced Data Cllectin System Maintenance Cntents
More informationITIL Service Offerings & Agreement (SOA) Certification Program - 5 Days
ITIL Service Offerings & Agreement (SOA) Certificatin Prgram - 5 Days Prgram Overview ITIL is a set f best practices guidance that has becme a wrldwide-adpted framewrk fr Infrmatin Technlgy Services Management
More informationMANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016
MANITOBA SECURITIES COMMISSION STRATEGIC PLAN 2013-2016 The Manitba Securities Cmmissin (the Cmmissin) is a divisin f the Manitba Financial Services Agency (MFSA). The ther divisin is the Financial Institutins
More informationAppendix H. Annual Risk Assessment and Audit Plan 2013/14
Annual Risk Assessment and Audit Plan 2013/14 Internal Audit Department September 25, 2013 Table f Cntents Intrductin.. 3 Risk Assessment Prcess... 4 Page 2 Intrductin Each year, the Internal Audit Department
More informationCommunicating Deficiencies in Internal Control to Those Charged with Governance and Management
Internatinal Auditing and Assurance Standards Bard ISA 265 April 2009 Internatinal Standard n Auditing Cmmunicating Deficiencies in Internal Cntrl t Thse Charged with Gvernance and Management Internatinal
More informationGUIDELINE INFORMATION MANAGEMENT (IM) PROGRAM PLAN
Gvernment f Newfundland and Labradr Office f the Chief Infrmatin Officer Infrmatin Management Branch GUIDELINE INFORMATION MANAGEMENT (IM) PROGRAM PLAN Guideline (Definitin): OCIO Guidelines derive frm
More informationCommunal Property Institution Capacity Assessment Tool
Cmmunal Prperty Institutin Capacity Assessment Tl Intrductin t cmmunal prperty institutins Cmmunal prperty institutins (CPIs) Participants in the land refrm prgramme can hld prperty thrugh different frms
More informationArmy DCIPS Employee Self-Report of Accomplishments Overview Revised July 2012
Army DCIPS Emplyee Self-Reprt f Accmplishments Overview Revised July 2012 Table f Cntents Self-Reprt f Accmplishments Overview... 3 Understanding the Emplyee Self-Reprt f Accmplishments... 3 Thinking Abut
More informationQuality Assurance/Control Procedures
2015 Prgrammatic Categrical Exclusin {PCE} Agreement Oregn Department f Transprtatin Federal Highway Administratin, Oregn Divisin Quality Assurance/Cntrl Prcedures Intrductin The Prgrammatic Agreement
More informationSeattle Police Department
Seattle Plice Department Prpsed develpment f a Business Intelligence System December 2013 Versin: FINAL Executive Summary Executive Summary 1. Intrductin The United States and the City f Seattle have entered
More informationTraining Efficiency: Optimizing Learning Technology
Ideas & Insights frm 2008 Training Efficiency Masters Series Survey Results Training Efficiency: Optimizing Learning Technlgy trainingefficiency.cm Survey Results: Training Efficiency: Optimizing Learning
More informationStandards and Procedures for Approved Master's Seminar Paper or Educational Project University of Wisconsin-Platteville Requirements
Standards and Prcedures fr Apprved Master's Seminar Paper r Educatinal Prject University f Wiscnsin-Platteville Requirements Guidelines Apprved by the Graduate Cuncil University f Wiscnsin-Platteville
More informationAUDIT AND RISK COMMITTEE TERMS OF REFERENCE
AUDIT AND RISK COMMITTEE TERMS OF REFERENCE 1. TITLE OF COMMITTEE Audit and Risk Cmmittee 2. ESTABLISHMENT The Audit and Risk Cmmittee is established under Part 3 Sectin 19(1) f the Charles Darwin University
More informationRisk Management Policy AGL Energy Limited
Risk Management Plicy AGL Energy Limited AUGUST 2014 Table f Cntents 1. Abut this Dcument... 2 2. Plicy Statement... 2 3. Purpse... 2 4. AGL Risk Cntext... 3 5. Scpe... 3 6. Objectives... 3 7. Accuntabilities...
More informationTHE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM
THE CITY UNIVERSITY OF NEW YORK IDENTITY THEFT PREVENTION PROGRAM 1. Prgram Adptin The City University f New Yrk (the "University") develped this Identity Theft Preventin Prgram (the "Prgram") pursuant
More informationDALBAR Due Diligence: Trust, but Verify
BEST INTEREST INVESTMENT RECOMMENDATIONS Advisr Rle under Best Interest Regulatins January 27, 2016 In the era when the cntractual bligatin is t act in the client s best interest, investment decisins can
More informationGENERAL MOTORS COMPANY AUDIT COMMITTEE CHARTER. Most Recently Amended: December 8, 2015
GENERAL MOTORS COMPANY AUDIT COMMITTEE CHARTER Mst Recently Amended: December 8, 2015 Purpse The purpse f the Audit Cmmittee is t assist the Bard f Directrs f General Mtrs Cmpany in its versight f the
More informationWhat is Software Risk Management? (And why should I care?)
What is Sftware Risk Management? (And why shuld I care?) Peter Kulik, KLCI, Inc. 1 st Editin, Octber 1996 Risks are schedule delays and cst verruns waiting t happen. As industry practices have imprved,
More informationBusiness Continuity Management Systems Foundation Training Course
Certificatin criteria fr Business Cntinuity Management Systems Fundatin Training Curse CONTENTS 1. INTRODUCTION 2. LEARNING OBJECTIVES 3. ENABLING OBJECTIVES KNOWLEDGE & SKILLS 4. TRAINING METHODS 5. COURSE
More information9 ITS Standards Specification Catalog and Testing Framework
New Yrk State ITS Standards Specificatin Develpment Guide 9 ITS Standards Specificatin Catalg and Testing Framewrk This chapter cvers cncepts related t develpment f an ITS Standards Specificatin Catalg
More informationLoss Share Data Specifications Change Management Plan
Lss Share Data Specificatins Change Management Plan Last Updated: 2/27/2013 Table f Cntents I. Purpse... 3 II. Change Management Apprach... 3 III. Categries f Revisins... 4 IV. Help and Supprt... 6 Lss
More informationSuccession Planning & Leadership Development: Your Utility s Bridge to the Future
Successin Planning & Leadership Develpment: Yur Utility s Bridge t the Future Richard L. Gerstberger, P.E. TAP Resurce Develpment Grup, Inc. 4625 West 32 nd Ave Denver, CO 80212 ABSTRACT A few years ag,
More informationTO: Chief Executive Officers of all National Banks, Department and Division Heads, and all Examining Personnel
AL 96-7 Subject: Credit Card Preapprved Slicitatins TO: Chief Executive Officers f all Natinal Banks, Department and Divisin Heads, and all Examining Persnnel PURPOSE The purpse f this advisry letter is
More informationEqual Pay Audit 2014 Summary
Equal Pay Audit 2014 Summary Abut the dcument The fllwing summary is an abridged versin f Ofcm s equal pay audit 2014. In the full versin f the reprt we set ut ur key findings, cmment n any issues arising
More informationOakland Unified School District Impact Assessment Performance Management in Action
Oakland Unified Schl District Impact Assessment Perfrmance Management in Actin The perfrmance management system that has been built in this district prvides the systems that supprt ur cmmitment t scial
More informationSecurity Services. Service Description Version 1.00. Effective Date: 07/01/2012. Purpose. Overview
Security Services Service Descriptin Versin 1.00 Effective Date: 07/01/2012 Purpse This Enterprise Service Descriptin is applicable t Security Services ffered by the MN.IT Services and described in the
More informationVulnerability Management:
Vulnerability Management: Creating a Prcess fr Results Kyle Snavely Veris Grup, LLC Summary Organizatins increasingly rely n vulnerability scanning t identify risks and fllw up with remediatin f thse risks.
More informationSelect Auditing Considerations for the 2014 Audit Cycle
Select Auditing Cnsideratins fr the 2014 Audit Cycle This Alert is intended t remind member firms f certain auditing cnsideratins that may be relevant fr the 2014 audit cycle. The Alert identifies and
More informationPRODUCTION BASED CONSTRUCTION COST ESTIMATE
PRODUCTION BASED CONSTRUCTION COST ESTIMATE (BOTTOM-UP ESTIMATING METHOD) DEVELOPED FOR CONSTRUCTION PLANNING DURING THE DESIGN PHASE REV2 10-JAN-14 1 P a g e CONTENT 1 BOTTOM UP ESTIMATING SUMMARY FOR
More informationLINCOLNSHIRE POLICE Policy Document
LINCOLNSHIRE POLICE Plicy Dcument 1. POLICY IDENTIFICATION PAGE POLICY TITLE: ICT CHANGE & RELEASE MANAGEMENT POLICY POLICY REFERENCE NO: PD 186 POLICY OWNERSHIP: ACPO Cmmissining Officer: Prtfli / Business-area
More informationData Warehouse Scope Recommendations
Rensselaer Data Warehuse Prject http://www.rpi.edu/datawarehuse Financial Analysis Scpe and Data Audits This dcument describes the scpe f the Financial Analysis data mart scheduled fr delivery in July
More informationBusiness Continuity Management Policy
Business Cntinuity Management Plicy Versin: 1.0 Last Amendment: Apprved by: Library Cuncil f New Suth Wales Plicy wner/spnsr: Directr, Operatins and Chief Financial Officer Plicy Cntact Officer: Senir
More informationRequest for Proposal (RFP) RFP HQ2015-01 Training Session and Leadership Program Development Consulting Services
technserve.rg Date: January 5, 2014 Request fr Prpsal (RFP) RFP HQ2015-01 Training Sessin and Leadership Prgram Develpment Cnsulting Services Subject: Request fr Prpsal TechnServe Inc. (TNS) invites yu
More informationIT CHANGE MANAGEMENT POLICY
IT CHANGE MANAGEMENT POLICY Effective Date May 19, 2016 Crss-Reference 1. IT Operatins and Maintenance Plicy 2. IT Security Incident Management Plicy Respnsibility Apprver Review Schedule 1. Plicy Statement
More informationVersion: Modified By: Date: Approved By: Date: 1.0 Michael Hawkins October 29, 2013 Dan Bowden November 2013
Versin: Mdified By: Date: Apprved By: Date: 1.0 Michael Hawkins Octber 29, 2013 Dan Bwden Nvember 2013 Rule 4-004J Payment Card Industry (PCI) Patch Management (prpsed) 01.1 Purpse The purpse f the Patch
More informationUCISA-Infrastructure Group Case Study
UCISA-Infrastructure Grup Case Study King s Cllege Lndn Infrastructure Analysis and Resilience Review 1. Intrductin Infrmatin Services and s (ISS) at King s Cllege Lndn has recently restructured a significant
More informationTHIRD PARTY PROCUREMENT PROCEDURES
ADDENDUM #1 THIRD PARTY PROCUREMENT PROCEDURES NORTH CENTRAL TEXAS COUNCIL OF GOVERNMENTS TRANSPORTATION DEPARTMENT JUNE 2011 OVERVIEW These prcedures establish standards and guidelines fr the Nrth Central
More informationHEALTH INFORMATION EXCHANGE GRANTS CRITERIA
1 HEALTH INFORMATION EXCHANGE GRANTS CRITERIA INTRODUCTION On August, 20 th, the federal Office f the Natinal Crdinatr fr Health Infrmatin Technlgy (ONC) released an pprtunity fr states t apply fr between
More informationHow To Understand The Risks Of A Financial Institutin
Guidance n Managing Outsurcing Risk Divisin f Banking Supervisin and Regulatin Divisin f Cnsumer and Cmmunity Affairs Bard f Gvernrs f the Federal Reserve System December 5, 2013 Table f Cntents I. Purpse
More informationITIL V3 Planning, Protection and Optimization (PPO) Certification Program - 5 Days
ITIL V3 Planning, Prtectin and Optimizatin (PPO) Certificatin Prgram - 5 Days Prgram Overview The ITIL Intermediate Qualificatin: Planning, Prtectin and Optimizatin (PPO) Certificate is a free-standing
More informationDesign for securability Applying engineering principles to the design of security architectures
Design fr securability Applying engineering principles t the design f security architectures Amund Hunstad Phne number: + 46 13 37 81 18 Fax: + 46 13 37 85 50 Email: amund@fi.se Jnas Hallberg Phne number:
More informationMonitoring and Audit of Clinical Research Studies
Mnitring and Audit f Clinical Research Studies Categry: Summary: Equality Analysis undertaken: Plicy Implementatin f this plicy will ensure that the Trust fulfils its statutry bligatins which in turn will
More informationOFFICIAL JOB SPECIFICATION. Network Services Analyst. Network Services Team Manager
JOB SPECIFICATION FUNCTION JOB TITLE REPORTING TO GRADE WORK PATTERN LOCATION IT & Digital Netwrk Services Analyst Netwrk Services Team Manager Band D Full-time Birmingham TRAVEL REQUIRED Occasinally ROLE
More informationVersion Date Comments / Changes 1.0 January 2015 Initial Policy Released
Page 1 f 6 Vice President, Infrmatics and Transfrmatin Supprt APPROVED (S) REVISED / REVIEWED SUMMARY Versin Date Cmments / Changes 1.0 Initial Plicy Released INTENT / PURPOSE The Infrmatin and Data Gvernance
More informationSystems Support - Extended
1 General Overview This is a Service Level Agreement ( SLA ) between and the Enterprise Windws Services t dcument: The technlgy services the Enterprise Windws Services prvides t the custmer. The targets
More informationThe actions discussed below in this Appendix assume that the firm has already taken three foundation steps:
MAKING YOUR MARK 6.1 Gd Practice This sectin presents an example f gd practice fr firms executing plans t enter the resurces sectr supply chain fr the first time, r fr thse firms already in the supply
More informationCDE Data Governance Program - CDE-Specific and SLDS (P20+) Programs
CDE Data Gvernance Prgram - CDE-Specific and SLDS (P20+) Prgrams On September 27 th and 28 th, State Supprt Team (SST) Members Crey Chatis and Jeff Sellers visited Clrad t help CDE begin a Data Gvernance
More informationHow To Measure Call Quality On Your Service Desk
Hw T Measure Call Quality On Yur Service Desk - 1 - Declaratin We believe the infrmatin in this dcument t be accurate, relevant and truthful based n ur experience and the infrmatin prvided t us t date.
More informationEJttilb Health. The University of Texas Medical Branch Audit Services. Audit Report. Epic In-Basket Management Audit. Engagement Number 2015-008
',. -... : t'f" ' EJttilb Health The University f Texas Medical Branch Audit Reprt Audit Engagement Number 2015-008 July 2015 nie University f Texas Medical Branch 301 University Bulevard, Suite 4.100
More informationOrganization Design Specialist
Organizatin Design Specialist Suthern Africa Regin BACKGROUND One f the key challenges t implementing the new strategic directin and especially the cmmitment t face the custmer (the child and the cmmunity)
More information1.2 Supporting References For information relating to the Company Hardware Request project, see the SharePoint web site.
Hardware Request System Visin 1 Intrductin 1.1 Dcument Purpse and Scpe This dcument utlines the visin fr the Hardware Request system. The purpses f this dcument are t: Identify and agree n the prblems
More informationProject Management Fact Sheet:
Prject Fact Sheet: Managing Small Prjects Versin: 1.2, Nvember 2008 DISCLAIMER This material has been prepared fr use by Tasmanian Gvernment agencies and Instrumentalities. It fllws that this material
More informationOE PROJECT MANAGEMENT GLOSSARY
OE PROJECT MANAGEMENT GLOSSARY ACCEPTANCE CRITERIA : thse criteria, including perfrmance requirements and essential cnditins that must be met befre the prject deliverables are accepted. ACTIVITY: an actin
More information10 th May 2010. Dear Peter, Re: Audit Quality in Australia: A Strategic Review
10 th May 2010 Mr. Peter Levy Audit Quality Strategic Review Crpratins and Financial Services Divisin The Treasury Langtn Crescent PARKES ACT 2600 Dear Peter, Re: Audit Quality in Australia: A Strategic
More informationSources of Federal Government and Employee Information
Inf Surce Surces f Federal Gvernment and Emplyee Infrmatin Ridley Terminals Inc. TABLE OF CONTENTS General Infrmatin Intrductin t Inf Surce Backgrund Respnsibilities Institutinal Functins, Prgram and Activities
More information2 DAY TRAINING THE BASICS OF PROJECT MANAGEMENT
2 DAY TRAINING THE BASICS OF PROJECT MANAGEMENT BASICS f Prject management 1.1. Objectives All participants will learn abut prject-based wrking by getting hands-n experience f a number f techniques. The
More informationOffice of the Superintendent of Financial Institutions. Internal Audit Report. Human Resources Performance Management.
Office f the Superintendent f Financial Institutins Internal Audit Reprt n Human Resurces Perfrmance Nvember 2010 Table f Cntents 1. Backgrund...3 2. Audit Objectives, Scpe, Apprach, and Criteria...3 3.
More informationBetter Practice Guide Financial Considerations for Government use of Cloud Computing
Better Practice Guide Financial Cnsideratins fr Gvernment use f Clud Cmputing Nvember 2011 Intrductin Many Australian Gvernment agencies are in the prcess f cnsidering the adptin f clud-based slutins.
More informationBLUE RIDGE COMMUNITY AND TECHNICAL COLLEGE BOARD OF GOVERNORS
BLUE RIDGE COMMUNITY AND TECHNICAL COLLEGE BOARD OF GOVERNORS SERIES: 1 General Rules RULE: 17.1 Recrd Retentin Scpe: The purpse f this rule is t establish the systematic review, retentin and destructin
More informationGravesham Borough Council
Classificatin: Part 1 Public Key Decisin: Please specify - N Gravesham Brugh Cuncil Reprt t: Perfrmance and Administratin Cmmittee Date: 12 Nvember 2015 Reprting fficer: Subject: Crprate Perfrmance Manager
More information17 Construction environmental management plan (CEMP)
17 Cnstructin envirnmental management plan (CEMP) Bur Happld Cntents 17 Cnstructin Envirnmental Management Plan (CEMP) 17-1 17.1 Intrductin 17-1 17.2 Intrductin t EMS 17-1 17.2.1 Plicy 17-2 17.2.2 Planning
More information.100 POLICY STATEMENT
Treasury Management Operatins Sectin: Treasury Management Number: 105.100 Title: Treasury Management Operatins POLICY Index.100 POLICY STATEMENT.110 POLICY RATIONALE.120 AUTHORITY.130 APPROVAL AND EFFECTIVE
More informationPrinciples of Engagement with Universities providing accredited Actuarial Science programmes
The Actuarial Prfessin Principles f Engagement with Universities prviding accredited Actuarial Science prgrammes 1. What is an accredited actuarial science prgramme? Accreditatin f university prgrammes
More information7/25/14 FAIRFAX COUNTY PUBLIC SCHOOLS SUPPORT EMPLOYEE PERFORMANCE ASSESSMENT HANDBOOK
7/25/14 FAIRFAX COUNTY PUBLIC SCHOOLS SUPPORT EMPLOYEE PERFORMANCE ASSESSMENT HANDBOOK A Resurce Fr Supprt Emplyees Cpyright 2014, Fairfax Cunty Public Schls http://www.fcps.edu/hr/epd/evaluatins/supprt.shtml
More informationData Protection Act Data security breach management
Data Prtectin Act Data security breach management The seventh data prtectin principle requires that rganisatins prcessing persnal data take apprpriate measures against unauthrised r unlawful prcessing
More informationRATIONALE TERMS OF REFERENCE FOR THE QUALITY COMMITTEE UNDER THE EXCELLENT CARE FOR ALL ACT. Authority
RATIONALE With the intrductin f the Excellent Care fr All Act, hspital bards must nw have a quality cmmittee that reprts t the bard. The template prvides sample terms f references fr rganizatins t adapt
More informationMajor Review of Progress for Masters by Research Programs
Return the cmpleted frm t the Adelaide Graduate Centre Level 6, 115 Grenfell Street SA 5005 Majr Review f Prgress fr Masters by Research Prgrams Divisin f the Deputy Vice-Chancellr and VicePresident (Research)
More informationFHWA Compliance Assessment Program (CAP) Guidance
See 2015 updates at http://www.fhwa.dt.gv/federalaid/stewardship/feb2015update.cfm FHWA Cmpliance Assessment Prgram (CAP) Guidance Backgrund ed ed The gal f risk-based prject stewardship and versight is
More informationService Level Agreement in IBM T Clud - ITAP
G-Clud Lt 4: Specialist Clud Services Service Definitin 100 Lngwater Avenue Green Park Reading Berkshire RG2 6GP Tel: 0118 9213 510 Email: gclud@dssec.c.uk Website: www.dssec.c.uk Intrductin Thank yu fr
More informationTrends and Considerations in Currency Recycle Devices. What is a Currency Recycle Device? November 2003
Trends and Cnsideratins in Currency Recycle Devices Nvember 2003 This white paper prvides basic backgrund n currency recycle devices as cmpared t the cmbined features f a currency acceptr device and a
More informationA project manager may choose to use a combination or hybrid of agile and waterfall processes on a project. Here, we describe only the agile process.
Intrductin Agile Prcess Jbaid The IT Prject Management Office designed the Agile prcesses t prvide the prject team the flexibility t tailr / adjust the prcess t supprt the needs and cmplexity f the prject.
More informationVCU Payment Card Policy
VCU Payment Card Plicy Plicy Type: Administrative Respnsible Office: Treasury Services Initial Plicy Apprved: 12/05/2013 Current Revisin Apprved: 12/05/2013 Plicy Statement and Purpse The purpse f this
More information