The first Latin phrase I ever learned was caveat emptor. I learned this vocabulary from The Brady Bunch episode where Mike Brady (the father, as you know) intended to help his son Greg select a car to buy. Instead of consulting his father, Greg went to his friend Eddie who suckered him into buying an [...]
For financial institutions, awash in a sea of regulations, compliance issues are inevitable. Less certain is the matter of deciding which issues to present to the Board of Directors and how to present them. This can put compliance officers in the position of finding the delicate balance between not wanting to alarm the board while [...]
Proposed Rulemaking Comments Due Dec. 10, 2013 The compliance world has been deluged with 166 new pages of proposed rulemaking to amend flood insurance rules. Issued by the five federal regulators on October 11, the proposal amends regulations varying from escrow of premiums and fees to the seven rules for private flood insurance. In addition, [...]
One question I frequently encounter when I meet compliance officers throughout the country is how can I help my Board understand or at least appreciate our compliance risks or our current compliance situation. Nice doggy. Perhaps, a brief movie reference would be beneficial here (as a long-time movie aficionado, I find a brief [...]
There is something about a massive storm approaching that brings both wonder and a bit of terror to those that lie in its path. Having spent a pair of hurricane seasons in Haiti, and having seen the ravages of massive storms on ill prepared locales, I can appreciate the concern of those in the path [...]
Rather than deal with the obvious, “How do I ensure a satisfactory rating on my next compliance examination?,” let’s deal with the most common type of compliance questions financial institutions ask. After all, you’d be hard pressed to say what is the most common type of Ice Cream (Vanilla, but you get the idea). As [...]
Question: How do I make Enterprise Risk Management fly at my institution? Answer: The other day I was visiting the always amazing Smithsonian’s Air and Space Museum with my son. I entered the Wilbur and Orville Wright section, where a presentation was being made. The subject of the flying challenge emerged and what the Wright [...]
Question: What is the expectation for compliance for credit unions? Answer: The answer to this question requires some basic understanding about the FFIEC (the Federal Financial Institution Examination Council). The FFIEC home page has this to say about itself: "The Federal Financial Institutions Examination Council (FFIEC) was established on March 10, 1979 and is a formal [...]
What are the top three internet resources for analyzing Fair Lending? We could divide this question into a few categories, such as paid internet resources vs. free access resources. However, there is certainly some crossover either way, because the smart, solution-minded individual would either directly pursue these avenues or ensure that the solution being used [...]
I travel to financial institutions throughout the country all year long. I am sometimes asked if I see certain compliance problems over and over. One possible approach to answering this question is to say that BSA, UDAAP and ECOA/Fair Lending issues are what I see happen most frequently. But, the deeper way of answering this [...]
