AN IN-DEPTH LOOK AT COMPLIANCE MONITORING

[Pages:33]AN IN-DEPTH LOOK AT COMPLIANCE MONITORING

Karen A. Geno ? Geno Management Advisory Services Jeff Blake ? Citizens Business Bank

Welcome

Session 2 Overview

1

? Elements of an Effective Compliance Monitoring Program

2

? Approach, Scope, Frequency ? Templates, Examples

3 ? Case Studies

Learning Objectives

? Definitions ? Approach ? Scope ? Frequency ? Tools ? Results ? Benefits ? Follow Up

COMPONENTS OF AN EFFECTIVE COMPLIANCE MANAGEMENT PROGRAM

A. POLICIES AND PROCEDURES

B. TRAINING

C. MONITORING

D. CONSUMER COMPLAINT RESPONSE

FDIC COMPLIANCE MANUAL

"Monitoring" in the FDIC Compliance Examination Manual --

? -- proactive approach by the institution to identify procedural or training weaknesses in an effort to preclude regulatory violations

? -- includes reviews at the transaction level during the normal, daily activities of employees in every operating unit of the institution.

HOW MONITORING DIFFERS FROM AUDITS

Periodic monitoring is conducted more frequently than formal compliance audits; can be less thorough in nature and can be conducted by employees not trained in compliance or auditing methods.

Performed By: Done by the Business Unit

Done by the Compliance Manager or Compliance Staff

SCOPE/FREQUENCY OF MONITORING ALTERNATIVES

SCOPE Lending Compliance Examples

? Flood ? Reg. B Operations Compliance Examples ? Reg. CC ? Reg. D ? Reg. E

FREQUENCY ? Daily ? Monthly ? Quarterly ? Continuous

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