Page 3 - Compliance Monthly - November 2019
P. 3

Focus




     Of the Month







        Initial Preparations for 2020!

        The new year will continue to present challenges for financial institutions with balancing expectations
        and resources.  Our accounting, audit, compliance and IT professionals work with a wide range of
        financial institutions and interact regularly with the regulatory agencies.  These relationships give us
        a broad perspective regarding industry best practices and regulatory expectation and put us in a
        unique position to assist our clients in navigating current challenges and prepare those the future
        may present.  Here are some of the topics we want to put on your radar as you start to plan for  2020:

            •   BSA
                   o  Customers Due Diligence. Increasing focus on Enhanced Due Diligence
                      methodology and validating the customer’s baseline activity (expected vs actual
                      activity).
                   o  Oversight.  Sufficiency of independent testing concerning scope and expertise.
                   o  Account Ownership.  Ultimate beneficial ownership.
                   o  Emerging topics. Marijuana banking, digital currency

            •   Information Technology
                                                 th
                   o  Vendor Management.  3rd and 4  party vendor management processes and user
                      controls.
                   o  Remediation Efforts.  Robust evidence of remediation/validation of security
                      vulnerabilities that are cited in independent or in-house Vulnerability
                      Assessments and Penetration Tests.
                   o  Privacy.  Data protection.
                   o  Cybersecurity.

            •   Compliance
                   o  FinTech and Technology.  Innovation, high risk products and UDAAP.
                   o  Fair lending. Program architecture and the use of analytics.
                   o  CRA.
                   o  Flood Requirements.

         Action Plan Checklist:

              Policies and Procedures.  Review the impact of these topics for your institution.  Ensure that
               policies and procedures are updated to address and remediate risk.
              Educate.    Look  for  knowledge  gaps.    Schedule  training  for  affected  departments  and
               compliance personnel.
              Documentation.  Update  documentation,  procedures  and  processes  to  ensure  that
               compliance is evidenced.
              Monitoring.  Review and revise monitoring and internal audit programs to ensure robust
               testing.  Review  the  credentials  of  those  conducting  such  reviews  to  ensure  adequate
               knowledge.  Analyze the results of such reviews to identify and address red flags and root
               causes of systemic issues.







                                                 www.accumepartners.com                                             3
   1   2   3   4   5   6   7   8