FEATURES
Volume 30, No. 6
CONTENTS
12 To Modify or Not to Modify: Avoiding the Traps
BY CARL G. PRY, CRCM
Pressure to identify and make changes to distressed borrowers’ loans to provide more-affordable payments comes
from many quarters. But what does that involve? Do you even have to do anything in the first place? And if you do,
what should you do? There are many different ways a loan can be modified or changed to reduce the risk of eventual
foreclosure, and each presents different compliance challenges.
18 Trends in Enforcement Actions:
Are compliance weaknesses still getting regulators’ attention?
BY ADAM SHAPIRO AND JEANINE CATALANO
The authors reviewed the 648 formal enforcement actions issued by bank regulators in 2008 and the first half of
2009. In this article, they describe the themes that emerged from their review: trends in the volume and type of
enforcement actions; the most common provisions included in the enforcement actions; the laws and regulations
toward which the regulators most often directed banks to enhance their compliance; agency
differences; and the geographic distribution of actions.
28 Compliance Audits: A Marriage Made in Heaven—
or Somewhere Worse?
BY PAT PATRICK SHUTTERLY
DEPARTMENTS
Compliance Management 4
BY CARL G. PRY, CRCM
When compliance professionals share their audit experiences, bad and good—with the
former always outnumbering the latter—they sometimes draw an interesting comparison:
marriage. As in a successful marriage, the keys to a having a successful compliance audit
seem to revolve around four critical themes equally important to all parties: communication,
partnership, perspective, and the little things (that mean so much). This article delivers real-world tips for successful compliance audits, collected from compliance professionals across
the country.
Governance 8
BY PAUL R. OSBORNE,
CPA, CPO, AMLP, AND
CATHERINE M. BROWN, AMLP
In Memoriam 41
BY STU LEHR AND MIKE MAHER
Resources
Continuing Education Quiz
42
44
34 Compliance Risk in the Debt Collection World:
One Company’s Risk Management Approach
Recently, ABA Bank Compliance magazine spoke with management at Wilmington Trust
Company, an institution that has adopted a proactive strategy to maximize risk control
by training debt collection staff on a comprehensive array of consumer protection laws.
We asked members of the bank’s management to discuss their perspective on this risk
management approach: Why they do it? What are the benefits? And what’s their view on
compliance risk in the debt collection function, given today’s challenging environment?
