Partnering with
professionals in functional
areas bolsters the bank’s
capacity to assess practical
implications of regulatory
changes.
TaBle 1:
Proven success strategies
1control the destiny of the organization
intensified testing
2
maximize resources, talent,
and the perspective of others
3
developments
influencing 2013
“international Year of statistics”.
examiner testing expectations
interagency coordination
memorandums of
understanding (mous)
2013 tactical risk Management opportunities
“keep your friends close and your enemies
(data) closer.”
re-evaluate the testing program to ensure
scoping and review protocols enable the bank to
sufficiently identify exposures related to existing
and emerging risks.
leverage internal and external relationships to
maximize your institiution’s capacity for strong
compliance in an environment where federal and
state agencies are increasingly coordinating to
enhance enforcement of consumer protection laws.
financial service organizations (e.g., CFPB’s
analysis of differences between consumer-and creditor-purchased credit scores at www.
consumerfinance.gov/reports/analysis-of-differences-between-consumer-and-creditor-purchased-credit-scores/ and its review of
how the nation’s largest credit bureaus manage consumer data at www.consumerfinance.
gov/reports/key-dimensions-and-processes-in-the-u-s-credit-reporting-system/).
■ ■ The introduction of new routine reports and
analyses to heighten congressional oversight
and public awareness of industry risks and
developments (e.g., the CFPB annual fair
lending report to Congress at http://files.
consumerfinance.gov/f/201212_cfpb_fair-
lending-report.pdf; the fall 2012 edition of
CFPB’s supervisory highlight at www.co
n-sumerfinance.gov/reports/supervisory-high-
lights-fall-2012/; and the CFPB’s snapshot
of complaints received at www.co
nsumer-finance.gov/reports/consumer-response-a-snapshot-of-complaints-received/).
The compliance industry’s feedback ac-
knowledged the increasing reliance on data in
bank supervision, regulation, and enforcement.
The industry expects the wave to continue
through 2013. But there are certain practices
that help manage the “enemy,” including:
Driving 2013 Expectations:
The continuation of intense data
verification examination.
The reviews in 2012 were reportedly more intense than in prior years.
■ ■ Implement a process to ensure that your
institution is capturing all complaints.
Provide the compliance function with the
ability to assess complaint processing and
resolution and the identification of issue
concentrations or trends that may warrant a
systemic response. Consider conclusions in
risk assessments and board and management
reporting.
