as compliance officers, we have long joked about all the hats that we must wear. Recently the “regulatory change management” hat has taken on more prominence. We all recognize that our industry is in a time of unprecedented regulatory change. The last two years have been a
challenging ride, with ups and downs. With the enactment of the Dodd-Frank Wall Street
Reform and Consumer Protection Act, the next several years are expected to put more
excitement in our compliance rollercoaster ride with compressed time frames, new and
revised rules, required Congressional studies, and new approaches to examinations. There
may be times when we feel like we are in freefall. But putting the right regulatory change
framework in place will lay the rails to stay on track to ensure successful compliance.
There are many effective approaches to managing regulatory change. Whether your financial institution manages the
process within a centralized enterprise compliance function,
in a decentralized line-of-business (LOB) manner, or by using
some combination of the two, you should include some common components in your program to ensure success. Following
are the four critical elements:
■ ■ Identification—becoming aware of relevant new and changed
rules, regulations, and guidance.
■ ■ Impact analysis—assessing regulatory changes and determining how they will impact each line of business.
■ ■ Implementation—managing projects or tasks to
effectively design controls to ensure compliance with
the regulatory changes.
■ ■ Integration—ensuring immediate compliance testing and incorporating it into ongoing
Staying abreast of regulatory changes is
critical to an effective regulatory change
management program. You will be well
served to think through a strat-
egy of exactly what you want
to capture. Give consideration
to the types of publications,
which agencies, and what areas
(e.g., consumer protection, information technology, safety and
soundness, trust, etc.) should be included.