Introduction to Becoming an MMC EIC

Board Oversight and Management

Board Oversight and Management Scope of Review The Examination Team assessed the institution’s board of directors and management, as appropriate for their respective roles and responsibilities, based upon the following assessment factors:  oversight of and commitment to the institution’s Compliance Management System;  effectiveness of the institution’s change management processes, including responding timely and satisfactorily to any variety of change, internal or external, to the institution;  comprehension, identification, and management of risks arising from the institution’s products, services, or activities; and  self-identification of consumer compliance issues and corrective action undertaken as such issues are identified. The Examination Team used the following examination procedures as outlined in the MMC Examination Manual:  Board and Management Oversight  Company Business Model  IT and Data Security  Service Provider Oversight Board Oversight and Management Component Rating Provident is assigned a rating of 2 for board oversight and management. This rating indicates that the institution’s oversight and management is satisfactory, and staff is generally able to ensure the financial institution is in compliance with consumer laws and regulations. Provident is a limited partnership without a board of directors. Senior management is responsible for Provident’s business risk. Areas of responsibility include: policies and procedures, compliance, risk management, internal audit, technology, finance/accounting, and operations. Provident maintains a flat organizational structure, which it believes helps promote staff involvement in the decision-making process and allows greater staff access to management. Provident credits the flat structure for enabling staff to raise matters requiring management attention quickly and effectively to decision makers for action.

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