The CFPB recently published their Summer 2013 Supervisory Highlights. The purpose of this publication is to periodically review the development of the Bureau’s supervision program and share certain key findings from their supervisory activities in order to help the industry limit risks to consumers and comply with Federal consumer financial laws.
This edition states:
The most common weakness identified during CFPB CMS (compliance management system) reviews in banks is a deficient system of periodic monitoring and independent compliance audits…
Although the CFPB does not require any specific CMS structure, supervisory experience has found that an effective CMS commonly has four interdependent control components:
1. Board of directors and management oversight;â€¨
2. A compliance program;
3. A consumer complaint management program; and
4. An independent compliance audit.
Although not required by regulation, it’s clear that the CFPB has an “expectation” of an independent compliance audit.
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar, or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups, and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru.
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