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Balance Between Audit/Compliance and Risk Management Best Practices FIRMA 21 st National Training Conference. Michael Coyne Risk & Regulatory Oversight PNC Wealth Management & Institutional Investments The PNC Financial Services Group, Inc. Pittsburgh, Pennsylvania. Background.
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Balance Between Audit/Compliance and Risk ManagementBest PracticesFIRMA 21st National Training Conference Michael Coyne Risk & Regulatory Oversight PNC Wealth Management & Institutional Investments The PNC Financial Services Group, Inc. Pittsburgh, Pennsylvania
Background • The PNC Financial Services Group, Inc. • PNC is one of the largest diversified financial services companies in the United States based on assets, operating businesses engaged in retail banking, corporate and institutional banking, asset management, and global fund processing services. We provide many of our products and services nationally and others in our primary geographic markets located in Pennsylvania; New Jersey; the greater Washington, DC area, including Maryland and Virginia; Ohio; Kentucky and Delaware. We also provide certain global fund processing services internationally.
Structure and Relationship Overview • PNC Wealth Management & Institutional Investments • Risk Management Structure • Business Risk & Regulatory Oversight • Fiduciary Legal team with Investments, ERISA expertise • Corporate Fiduciary Compliance team with segment responsibilities • Corporate Risk Management • Fiduciary & Investment Risk Management • Operating Risk Management • Other Functional Risk Management support (Credit, Market, Technology) • Internal Audit • Fiduciary and Investments audit team
Communication and Teamwork - Forums • Business Risk Management, Investments and Fiduciary Committee • Key business issues and segment reporting • Exception reporting, Compliance reporting, Legal issues, Audit issues and schedule • Rotating segment reporting • Product Development & Oversight Committee • Review and approve new products or significant changes to existing products • Participation by Corporate Risk Management, Compliance, product managers
Communication and Teamwork - Forums • Risk Roundtable Forum • Key risk issues and emerging risks in informal setting • Participation from Corporate Risk, Business Management, Audit, Legal, Compliance, AML Risk Management • Policies and Procedures Committee • Review and approve new or amended policies and procedures • Participation by Corporate Risk Management, Compliance, Legal, Business Management, product managers
Challenges and Areas of Focus • Potential overlap in issues review/resolution; “too many cooks…” • Potential for conflicting charters between groups; “monitoring v. testing” • Potential for differing interpretations of regulatory expectations • Differing viewpoints on issue “scaling” or rating criteria • Importance of connection between business management and Corporate Risk Initiatives • Ensuring appropriate Compliance/Risk/Audit participation in key business initiatives (e.g., acquisitions, system enhancements, etc.)