Bank Directors Seminar, Coeur d'Alene, ID, September 15-17, 2019

New Areas of Complex Compliance Risk

Concern for banks of all sizes:  Regulatory Change Management: even reg relief causes

changes that need operationalization; when regs change rapidly, risk increases

 Vendor Compliance: this is how banks innovate for customer experience and new products, but are the vendors vetted and banks are responsible for compliance errors

 Cyber Compliance: FFIEC IT Exam Handbook

 Data and Privacy

Wells Fargo – Not Just About Big Banks and Fraud

 The Fed’s Order, dated February 2, 2017 stands out not only because for the first time it publicly imposed asset cap

 The Fed also called out the entire Board of Directors in a very public way

 The Fed said that “the Firm pursued a business strategy that emphasized sales and growth without ensuring that senior management had established and adequate risk management framework commensurate with size and complexity of the firm, which resulted in weak compliance practices”