FEATURES
Volume 30, No. 4
CONTENTS
8
A Delicate Balance: Managing CRA in the Current Economic Climate
By Karen TucKer, nBe, and calvin r. Hagins, crcM, crP, aMlP
According to news reports, the economy is in recession, foreclosures are up, and business results are down. And yet, in the midst of the
current economic climate, regulators continue to expect banks to comply with the Community Reinvestment Act (CRA). Why? CRA is a
fundamental aspect of banking. Banks continue to have an obligation to help meet the credit needs of their communities, consistent with
safe and sound banking practices.
16 Risk Management for Community Banks
By Wylli FooTe, crcM
The scope and complexity of enterprise-wide risk management depends today on the size of your bank. If, for example, you work for
a large bank—$2 billion or more in assets—you almost by definition have developed some level of enterprise-wide risk program. You
probably also provide some level of reporting to the board (or a designated board committee) of key areas of risk. Most often, color or
other coding is used to visually represent the level (high, moderate, or low) and direction (increasing, decreasing, or stable) of risk in each
risk area.
20 Compliance Due Diligence for Mergers and Acquisitions
By carl g. Pry, crcM
Recently there has not been a lot of merger and acquisition (M&A) activity in the banking
world. The difficult economy has been an equal opportunity offender, affecting almost all
banks in the country. There have been several large bank acquisitions, and some FDIC-assisted transactions involving distressed institutions, but normal M&A activity has been
mostly quiet. That may change as things begin to pick up. What happens if you’re assigned
to evaluate a potential acquisition for compliance concerns? Would you know where to start?
DEPARTMENTS
Compliance Management 4
By carl g. Pry, CRCM
28 Survey Reveals Expanded, Stressful Role for
Compliance Officers
By JosePH M. Kelly, senior edi Tor
Governance 38
By Paul r. osBorne, cPa,
cPo, aMlP, and
JeFFrey a. Jones, caMs
The American Bankers Association’s Center for Regulatory Compliance conducts a
comprehensive survey every two years. The 2009 survey revealed some interesting highlights
about the expanding role of compliance officers. This article takes a look at the changes and
what they mean to the industry.
Highlights
Resources
Continuing Education Quiz
40
42
44
34 Internet Gambling Regulation Compliance:
Four Focus Points for Banks
By s TePHen Kenneally
The Unlawful Internet Gambling Enforcement Act (UIGEA) aims to limit online wagering
by placing new prohibitions on banks making payments to Internet gambling businesses.
The agencies responsible for writing the regulation and enforcing this broadly worded law,
the Board of Governors of the Federal Reserve System and the Department of the Treasury,
realized that a loose interpretation of the legislation enforced through its regulation would
grind the payments system to a halt if each check, wire, ACH, and card transaction had to
be validated as a lawful payment. Compounding this hurdle, the UIGEA did not define
“unlawful Internet gambling,” leaving it to a patchwork of state and tribal laws.