Change management and vendor risk management are key overarching compliance concerns, according to senior regulatory officials at ABA’s Regulatory Compliance Conference.
“We live in a world of rapid change,” said Eric Belsky, director of consumer and community affairs at the Federal Reserve. He noted that compliance requirements have shot up in the last few years, in part due to “the sheer number of new regulations,” and that banks “need to have clear policies and procedures” to address not just the regs themselves but also the flow of changes in regulations.
Grovetta Gardineer, deputy comptroller for compliance at the OCC, echoed Belsky’s comments and added that the OCC also monitors how banks handle changes in their markets, products and overall risk profile. Regulators also said they are looking closely at vendor risk management, from due diligence prior to selection to ongoing monitoring of the relationship.
Regulators emphasized that overall, community banks are performing well in examinations. At the outset of the financial crisis, “most community banks were well-rated on consumer compliance,” said Mark Pearce, the FDIC’s director of consumer protection. “It started off at a very high level and has only gotten better, which is remarkable given the number of regulatory changes.”