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Corporate Compliance: Compliance Framework and Hot Topics

Corporate Compliance: Compliance Framework and Hot Topics. Tammy Eisenberg Executive Director, Corporate Compliance CLS Group March 6, 2014. Disclaimer. The views represented herein are solely those of the author and do not necessarily represent the views of the CLS Group.

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Corporate Compliance: Compliance Framework and Hot Topics

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  1. Corporate Compliance: Compliance Framework and Hot Topics Tammy Eisenberg Executive Director, Corporate Compliance CLS Group March 6, 2014

  2. Disclaimer The views represented herein are solely those of the author and do not necessarily represent the views of the CLS Group.

  3. What is Corporate Compliance? At it’s most fundamental, a bank Corporate Compliance program is about ethics and managing conflicts of interest. Put simply, it’s about doing the right thing.

  4. Elements of a Corporate Compliance Program

  5. What is Compliance Risk • How does your organization define “Compliance Risk?” • Basel Committee on Banking Supervision – “Compliance and the Compliance Function in Banks.” • Compliance Risk is the risk of legal or regulatory sanctions, material financial loss, or loss of reputation a bank may suffer as a result of its failure to comply with laws, regulations, rules, related self-regulatory standards, and codes of conduct applicable to its banking activities.

  6. What is a Compliance Risk Framework • A Compliance Risk Framework is a tool that identifies, measures, documents and assesses compliance risk associated with a bank’s activities, including: • Development of new products/services • New business practices • New types of business/customer relationships • Material changes to any of the above

  7. Expectations of Regulators Federal Reserve SR 08-8 “Compliance Risk Management Programs at Large Banking Organizations with Complex Compliance Profiles.” SEC Release Nos. IA-2204; IC-26299 “Compliance Programs of Investment Companies and Investment Advisers.” FINRA Rule 3012 “Supervisory Control System.”

  8. Roles and Responsibilities

  9. Process

  10. Governance

  11. Risk Assessment

  12. Monitoring and Testing

  13. Training • Ensure understanding of: • Purpose of Compliance Risk Framework • Roles and Responsibilities • Methodologies • Information to be Reported

  14. Reporting and Communication

  15. What is a Compliance Policy Framework?

  16. Types of Policy Documents

  17. Relationship between Frameworks

  18. Types of Compliance Policies

  19. Hot Topics There are hot topics for almost every kind of compliance policy!

  20. Lessons Learned

  21. Questions

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