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Business as Unusual
Creating an IT compliance program that works
by Bill Koch, Editor, The Compliance Advisor
During
our grade school years, we all hit a sticking point. It might have been
fractions, science projects or even certain words on a spelling test. Hopefully,
it’s now a memory that makes you laugh, but at the time, there was probably nothing
comedic about it.
Many
compliance officers find themselves in a similar position as federal
regulations mount. While still managing your other responsibilities, creating a
solid compliance program may be your sticking point. How can you create an IT
compliance program that protects your bank and is manageable? [
Read More ... ]
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Building IT compliance programs that work
Trey Sullivan |
After 9/11 and the deluge of new federal regulations that
followed, many compliance officers had to re-think their compliance programs
from the ground up. The most challenging part can be building the IT infrastructure
and processes necessary to keep your financial institution safe. This month’s
feature article tells the story of one compliance officer and the impressive IT
compliance program she built using a variety of excellent resources.
Last month, we asked
if you provide your customers with copies of their credit reports.
Your
responses showed excellent insights into the risks associated with providing
this information — as well as not providing it. This month, we ask how you deal
with suspicions of internal fraud.
What do you do when your suspicions hit
close to home?
To keep this
material relevant to you, I invite you to become actively involved with this
newsletter. Please send ideas for articles you’d like to see and let me know if
the topics being covered are relevant to the issues your institution
faces. Take our brief survey and you’ll be registered for an Apple iPod™.
If you would like to unsubscribe from this newsletter, please click on link at
the bottom of the page.
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New SAR Activity Review Available
The ninth edition of the Financial Crimes Enforcement Network's SAR Activity
Review has just been published. The issue provides guidance on
disseminating Suspicious Activity Reports to law enforcement and tips on
completing SARs.
Download
FDIC Board Approves
Audit, Reporting Changes
More
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Complete our 1-minute reader survey and you could win
an Apple iPod. |
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GLBA,
FDIC & FFIEC:
Preparing for Your
Security Review & Risk Assessment
Learn the guidelines that establish administrative,
technical and physical safeguards to protect the privacy of customers’
nonpublic personal information. This Webinar focuses on FFIEC’s final
guidelines and will help your organization:
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Understand
the specific compliance requirements
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Access
your current state of readiness
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Gain
insights on comprehensive security risk assessments
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Build
a compliance blueprint
Wednesday, December 7, 2:00 p.m. EST
Wednesday, December 14, 2:00 p.m. EST
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for this complimentary Webinar today. |
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Last Issue's Dilemma:
Rating your credit policies
Historically, our bank has not given copies of
credit bureau reports to customers. With the increase in identity theft all
over the country, more and more customers are demanding to see their credit
reports for their own protection.
Aware of this pressure — and wanting to be
customer-focused — some of our loan officers have become vocal about this
policy. We are now re-evaluating the liabilities of providing credit bureau
reports to customers.
I wonder what risks we will run into
if we change this policy.
Should we please our customers and give them copies of their
credit reports or should we stick with our current policy?
— Daniel Stockman, Compliance Officer
Read the best advice from readers
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This Issue's Dilemma:
When
fraud hits close to home
Our small community bank is family owned and has
been for over 30 years. We employ a close-knit group of employees, many
of whom have ties to the founding family.
Lately, we've had a rash of operational issues that
appear to me to be the work of an internal fraudster. I have brought
this up several times to our president, along with some suggestions of
procedures we could implement in the affected areas. He insists that
these were just operational errors, not fraud.
He feels our basic processes are sound and will
not let me institute changes to who has access to information or interviews
with employees to discuss some of these errors. Don't I owe it to our
customers and internal auditor to point out and correct these problems? What
are others doing in similar circumstances?
— Mike Gibson, Compliance Officer
Can You Help?
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Fraud and AML
Monitoring: Stay ahead of the bad guys |
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Change Management:
Survive and thrive |
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Government
Regulations: Keep up with your changing environment |
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