Containing the Cost of Compliance

March 5, 2015

2

is a Large Term

“Compliance” is a Large Term

• Consumer Compliance

• BSA/AML Compliance

• Fair Lending

• Community Reinvestment Act

• UDAAP

• Enterprise Wide Risk Management

Four Pillars of Compliance

• Compliance Program

• Policies & Procedures

• Regulatory Relations

• Monitoring for Changes in Regulations

Characteristics of a Compliance Officer

• Experienced with compliance regulations & risk management

• Certified CRCM and ACAMs

• Works Well with Others

• Has a good circle of compliance Friends

• IS EXTREMELY EXPENSIVE TO KEEP!

The Costs of Compliance

• Salary

• Training

• Continued monitoring

• Software

• NON-COMPLIANCE

Costs of Non-Compliance

• Enforcement actions

• Look backs

• Civil money penalties

• Additional staff

• Additional resources

• Consultants

Keeping Up with Compliance

• Subscribing to regulatory websites

• Annual compliance assessments

• Focus on training

• Outsourcing portions of compliance

• Creating a compliance culture

Developing a Compliance Culture

• Compliance committee

• Ongoing training

• Positive reinforcement

• Messages from management

• Regulatory relations

Regulatory Relations

Sometimes feel like this …

10

11

Regulators Arrive at the Bank

for an Exam

Regulatory Relations

• Regulators are people too

• Communication is key

• Self detected-self corrected

• Relationships go a long way

Reducing Compliance Costs

• Forms & checklists

• Focus on areas of expertise

• Powerful systems for review

• Ongoing quality controls

Containing the Cost of Compliance

March 5, 2015