TOPIC: OCC

CDD: One Year Later | Survey Request

It's officially been one year since the CDD rule went into affect. Have you had an exam since then? What aspects of CDD and beneficial ownership, if any, did the examiner focus on? 

We're doing a short survey on the impact CDD is having on recent exams and would appreciate if you could take a few minutes to fill it out. We're happy to share the results if you participate. 

Thank you! 

Survey: https://www.surveymonkey.com/r/QCJ33BN

    Basic Knowledge/Risks of Private Banking for BSA

    VP at a bank ($7.6BUSA)
    I am interested in learning more about private banking. I have read the exam manual and I know what I know from my CAMS course, but still would like some real world pitfalls. I have heard from others to avoid calling your program "the private bank" because often you are not really doing a true private banking relationship but the name itself draws scrutiny. 

    We are not talking about banking foreign individuals, but more or less just personalized service. I intended on having an increased level of CDD/KYC but other than that, can anyone share any stories or regulator criticisms you have had?

    Thank you, 

      OCC Reveals 4 Top Risks Facing the Banking Industry

      Twice per year, the Office of the Comptroller of the Currency (OCC) releases a wide-ranging report on the health of the US banking industry and potential risks. This spring's edition is another powerful installment in that series, with predictions on emerging risks, a potential recession, and overall bank profitability. Learn 4 important risks from the OCC’s Semiannual Risk Perspectives Report, plus a few more key takeaways: https://www.trupointpartners.com/blog/4-key-risks-facing-the-banking-industry-according-to-the-occ

        How the Government Shutdown is Affecting Regulatory Agencies

        Good afternoon, Bankers! Today's topic is the current government shutdown. This post originally appeared on the Ncontracts blog.

        How the Government Shutdown is Affecting Regulatory Agencies

        The partial government shutdown has furloughed workers at the national parks, the Smithsonian museums, the IRS, courts, and other federal institutions, but enforcement actions from federal banking agencies continue...

        READ THE FULL PDF: Download the attached PDF

          Blog: OCC Release Priority Objectives for Fiscal Year 2019

          October 1 kicked off a new fiscal year for the Office of the Comptroller of the Currency’s (OCC). With that, they released their annual supervisory strategy plans for the 2019 fiscal year. Our latest blog discusses what their main areas of focus will be and the role your AML compliance program will play.

          Read more.

            Guide to the OCC's Advanced Notice of Proposed Rulemaking for CRA Modernization

            Yesterday, the OCC released an Advanced Notice of Proposed Rulemaking that outlines their efforts to modernize the Community Reinvestment Act. Since the OCC regulates slightly more than a fifth of all active banks in the US, this change has big implications for the industry. In this article, you'll learn all about what the ANPR says, and what it might mean for your bank - even if the OCC isn't your regulator: https://www.trupointpartners.com/blog/occ-advanced-notice-of-proposed-rulemaking-cra-reform

              Reminder! Free May Webinar - Managing the Risk of Cyber Threats: Assessing Third Parties and Measuring What Matters

              Don't forget! You are invited to our May webinar discussing the risks and opportunities associated with cyber threats. Register for free today! If you are not able to make it to the live event, we will send you the recording afterwards.

              A recent Harvard Business Review survey stated that 85% of those surveyed expect financial impact to rise from cyber breaches while only 23% of respondents said their strategic plan addresses business risk. Join study co-author & leading cyber expert Reid Sawyer and third-party risk expert Michael Berman for a presentation that’s sure to help both C suite and frontline managers better understand the risks and opportunities associated with this timely issue of cyber risk.

              Session takeaways:

              • Exploration of how FFIEC, OCC, FDIC and Fed mandates overlap regarding vendor management
              • Best practices in vendor due diligence reviews and contract management to decrease cyber risk
              • Re-conceptualize threats from a strategic not tactical mindset
              • Mandates for stress testing
              • What the future holds with cyber risk

              Register Today

                Free May Webinar - Managing the Risk of Cyber Threats: Assessing Third Parties and Measuring What Matters

                Hello, Bankers! You are invited to our May webinar discussing the risks and opportunities associated with cyber threats. Register for free today! If you are not able to make it to the live event, we will send you the recording afterwards.

                A recent Harvard Business Review survey stated that 85% of those surveyed expect financial impact to rise from cyber breaches while only 23% of respondents said their strategic plan addresses business risk. Join study co-author & leading cyber expert Reid Sawyer and third-party risk expert Michael Berman for a presentation that’s sure to help both C suite and frontline managers better understand the risks and opportunities associated with this timely issue of cyber risk.

                Session takeaways:

                • Exploration of how FFIEC, OCC, FDIC and Fed mandates overlap regarding vendor management
                • Best practices in vendor due diligence reviews and contract management to decrease cyber risk
                • Re-conceptualize threats from a strategic not tactical mindset
                • Mandates for stress testing
                • What the future holds with cyber risk

                Register Today

                  New Regulatory Guidance About Cybersecurity Insurance

                  Hello, Bankers! Today we are discussing cybersecurity insurance. This post originally appeared on the Ncontracts blog.

                  New Regulatory Guidance About Cybersecurity Insurance

                  Does your institution need cybersecurity insurance? Is it required? If utilized, are there rules? Cybersecurity insurance can protect against financial loss in the event of a cyber incident, but there are many intricate details...

                  READ THE FULL ARTICLE: Download the attached PDF

                    Blog: Top 10 Risks - Concentration Risk

                    This blog post is part of a series of posts on risks that impact financial institution. See the original article here or download the attached PDF.

                    What is Concentration Risk – And What Does My Regulator Have to Say About It?

                    When most bankers and credit union executives think of concentration risk, they think of lending—but concentration risk has a different meaning when talking about third-party vendor management.

                    Regulators are looking at two main concerns:

                    • Over-reliance on a single vendor. This is a classic case of putting all your eggs in one basket. If an institution relies heavily on a single provider...

                    READ THE FULL ARTICLE: Download the attached PDF

                      Free Webinar - How to Determine Your Critical Vendors

                      Person at a Company (USA)

                      Good morning, bankers! You're invited to join us for a free webinar on November, 16 where you can learn how to determine your critical vendors and how to make sure they don't negatively affect your FI's risk exposure. Can't watch live? Just register and you'll get the recorded version of the webinar. Register Here.

                      Determining Critical Vendors

                      What makes a critical vendor different from other vendors? The importance of properly determining your critical vendors is a key factor in your vendor management program. It maps out how you proceed in the vendor management process, with due diligence, monitoring and annual reviews. Knowing what questions to ask is at the forefront. Likewise, identifying who is a critical vendor, how many different types of vendors you should have and the criteria to determine the criticality of vendors is paramount to a successful vendor management program. This webinar will discuss:

                      • How to determine inherent risk and vendor classifications
                      • Considerations when risk rating your vendors, from NPPI, GLBA
                      • Differences in the guidance by federal regulators including OCC, FRB, FDIC, and NCUA
                      • What ‘critical vendor’ looks like in a post-Equifax breach realm

                      Join us as we address critical vendors and the role increased vendor risk plays in the financial institution.

                        Blog: Does Vendor Size Matter?

                        Person at a Company (USA)

                        Good afternoon, bankers. Today, we're discussing the costs and benefits of working with big vendors. This post was orginally published on the Ncontracts blog.

                        Does Vendor Size Matter?

                        Sometimes, but it doesn’t replace the need for vendor risk management

                        Some institutions try to simplify vendor management by picking the biggest vendor in each category. Going big lets them play it safe—or so they think.

                        But choosing the largest vendor is no replacement for solid vendor management.

                        Big vendors can offer a lot of benefits. They are traditionally...

                        READ THE FULL ARTICLE: Download the attached PDF.

                          Blog: Vendor Management - What the OCC Wants you to Know

                          Person at a Company (USA)

                          Welcome to part 2 of a 5-part series where we discuss what the agencies want from banks and credit unions regarding vendor management.

                          This post was originally published on April 10, 2017 at the Ncontracts blog

                          Third-party risk is a hot button issue for regulators. When a financial institution (FI) outsources an activity to an outside vendor, it can introduce all kinds of risk. Vendor management, or third-party relationship management, is all about identifying, measuring, monitoring and controlling those risks.

                          Different regulators use different terms to talk about vendor management. While they all ultimately have the same goal, they go about it in different ways. Today we’re looking at the OCC’s approach to vendor management to better understand what the agency really wants from FIs.

                          The OCC views the failure to “engage in a robust analytics process” for vendor management as potentially “an unsafe and unsound banking practice,” according to OCC Bulletin 2013-29 – Third Party Relationships. Naturally risk-averse, the agency...

                          READ THE FULL ARTICLE: Download the attached PDF.

                            Blog: After Six Years, Agencies Fine Mortgage Processor $65 Million

                            Person at a Company (USA)

                            This article was originally posted February 8th, 2017 at https://ncontracts.com/articles/after-six-years-agencies-fine-mortgage-processor-65-million/

                            It’s bad enough to be hit with a regulatory consent order. Now imagine the expense and public relations nightmare when those proceedings drag on for years.

                            Just ask Fidelity National’s subsidiary ServiceLink. This week the Fed, FDIC and OCC fined the company $65 million for improper actions taken by its predecessor company, Lender Processing Services, resulting in “significant deficiencies in the foreclosure-related services that LPS provided to mortgage servicers.”

                            You might remember LPS from the heyday of the mortgage foreclosure robo-signing scandal....

                            To read the full article:
                            Download the attached document.

                              Blog: After Six Years, Agencies Fine Mortgage Processor $65 Million

                              Person at a Company (USA)

                              This article was originally posted February 8th, 2017 at https://ncontracts.com/blog/

                              It’s bad enough to be hit with a regulatory consent order. Now imagine the expense and public relations nightmare when those proceedings drag on for years.

                              Just ask Fidelity National’s subsidiary ServiceLink. This week the Fed, FDIC and OCC fined the company $65 million for improper actions taken by its predecessor company, Lender Processing Services, resulting in “significant deficiencies in the foreclosure-related services that LPS provided to mortgage servicers.”

                              You might remember LPS from the heyday of the mortgage foreclosure robo-signing scandal....

                              To read the full article:
                              Download the attached document.

                              Blob