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"Your knowledge of and insight into the industry and its vendors enabled us to build a very realistic business case, identify the best solution to meet our long term needs, and countless hours of investigation."
-William Fitting, Senior Vice President
AllFirst Bank |
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Compliance Services
Program Administration
"There are many reasons to consider outsourcing the administration of all or a portion of your compliance program, including:
- Ineffective compliance staff
- Sudden turnover in compliance staff
- Ongoing audit or review issues pointing to failures in your existing program
- Offering new products or services
- Engaging in new business activities or acquiring a new business venture
- Expanding geographically
- Cost effectiveness"
Catalyst Response
Catalyst offers administration of a startup or an existing compliance program to serve you on a short- or long-term basis.
Similar to the responsibilities of a compliance officer, our full service compliance solution offers all the elements of an effective compliance solution:
- Performing a comprehensive risk assessment and developing a customized solution
- Establishing and directing the compliance committee
- Developing and implementing a compliance monitoring program
- Performing customized compliance training
- Maintaining the bank’s awareness of the regulatory environment and assisting with the implementation of new and amended regulations
- Participating in new product/service development and recommending appropriate compliance controls
- Reviewing new advertisements and disclosures
- Assisting with regulatory examinations
Benefits
You have the option of outsourcing the effective administration of this program for the entire company or for particular products or business units. We can also assist with strategies for gaining enterprise support for compliance activities.
Monitoring
"A review of any business activity, product or service engaged in or provided by your bank to verify its compliance with applicable regulations. This review will be focused on identifying actual and potential issues and will include recommended remedial actions."
Catalyst Deliverables
As part of our Compliance Administration Program or as a special project, we will review and deliver a written report detailing the strengths, weaknesses, compliance failures and corresponding corrective actions. The review may be conducted on the basis of your bank’s review procedures, checklists and procedures used by federal bank examiners, or using review-specific procedures.
A compliance monitoring review typically includes:
- Identification and analysis of the business activity, product or service components being reviewed
- A review of relevant documentation, including policies, procedures, disclosures, contracts, and marketing materials
- Interviews with key staff and management involved in conducting or delivering the business activity, product or service
- A review of prior examination or audit reports addressing the business activity, product or service
- A review of existing controls
- Development of a regulatory applicability matrix showing which regulations apply to the business activity, product or service
- Testing, as appropriate, of transactions, procedures and controls
Benefits
An excellent means of identifying potential compliance risk and avoiding the consequences of a compliance failure is to conduct a compliance review by an independent third party unbiased by internal corporate pressures.
Regulation Specific
"Detection and prevention are critical elements of a financial institution’s compliance program with the intent to minimize exposure to transaction, compliance and reputation risk."
Catalyst Deliverables
Our expert team of former bank examiners, compliance officers and regulatory attorneys can provide insights and practical advice on a wide range of transaction-related or other specific issues. A representative sampling of the diverse topics we have addressed for other institutions includes the following:
- CRA Performance Evaluations
- HMDA and CRA Data Collection/Reporting
- Fair Lending
- BSA/AML
- Proving consulting services to support the BSA/AML program or to develop a customized risk based BSA/AML Program and or perform independent testing
- BSA/AML Look-backs
- Customer Re-Profiling
- Customer Risk Scoring
- USA Patriot Act
- OFAC
- Privacy / Information Security
- New and Amended Regulations
- Customer Risk Scoring
- Customer Profiles
Risk Asssesments
"An effective compliance program starts with an evaluation of the compliance risks specific to a bank’s operations and structure."
Catalyst Deliverables
Either as part of our Compliance Administration program or as a special project we will review business operations to identify potential compliance risks and develop and implement appropriate solutions and controls. These services are provided on a company-wide basis or for specific products, services, regulations, or lines of business. For example, some clients have requested assistance with the enterprise-wide application of Bank Secrecy Act/Anti-Money Laundering rules, and others have requested such assistance with respect to selected activities such as Private Banking, Call Centers, or Internet Banking.
We will:
- Evaluate the current compliance function
- Review all existing compliance documentation
- Identify the specific compliance requirements associated with the bank’s products and services
- Evaluate policies and procedures
- Test transactions in selected operating departments
- Interview key personnel
- Ascertain compliance systems and controls
- Review prior examination and audit findings
- Develop a compliance risk profile
Benefit
The assessment results will recommend an effective compliance program and deploy resources to the compliance areas with the greatest risk.
Auditing
"Review your compliance program to determine whether it meets the standards established by the Basel Committee on Banking Supervision and the federal banking agencies."
Catalyst Deliverables
Our professionals will provide a point-by-point report on the results of our review, recommend the most effective structure for a compliance program or program component, and assist in implementing the appropriate solution.
Areas addressed include:
- Organizational structure
- The role of the board of directors, any board committee and senior management
- Reporting relationships (external and internal)
- Compliance policies and procedures (including code of conduct)
- Identification of applicable laws and regulations
- Compliance risk assessments and controls
- Compliance monitoring/testing process
- Reporting of monitoring results and other compliance issues to senior management and board of directors
- Corrective action process
- Compliance information to senior management and staff, including the implementation of new and amended regulations
- Compliance training
Benefit
- Confidence in detailed reviews based on up-to-date procedures, applicable laws and regulations
- Written reports and discussions with management and/or audit committee
- Recommendations based on "best practices"
- Assistance with corrective actions
Training
"An effective compliance training program includes training mandated by regulation (e.g. anti-money laundering, security, and funds availability), as well as training in response to regulatory changes, new products or services, and audit and examination findings. Either as part of our Compliance Administration Program or as a stand-alone product, our training programs are customized to your specific operation. A combination of on-site training, webinars, and computer-based training is designed to meet your needs."
Catalyst Deliverables
We have delivered countless sessions of compliance training in all areas, including:
- BSA/Anti-Money Laundering
- CRA
- Fair Lending
- Deposit Operations
- OFAC
- Real-Estate Lending
- Non-Deposit Investment Products
Even if you have an in-house training department, compliance training is particularly specialized. We can work with your in-house trainers or supervisors so that they are providing the most up-to-date information ("train-the-trainer" sessions).
Benefit
Compliance is everyone’s responsibility. If compliance knowledge was restricted to just the compliance officer, few transactions would be in compliance. An effective compliance program ensures front-line staff, those performing transactions, have the knowledge and tools to perform the transaction in compliance with declared bank practices of applicable laws and regulations.
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