All in Compliance Management

Citibank CMP for Risk Management Deficiencies

Adam Witmer
Compliance Management, Regulatory Update

On October 7, 2020, the Office of the Comptroller of the Currency (OCC) announced that they had assessed a $400 million civil money penalty (CMP) against Citibank due to deficiencies in enterprise-wide risk management, compliance risk management, data governance, and internal controls. In their release, the OCC explained that these measure were taken “based on the bank’s unsafe or unsound banking practices for its long-standing failure to establish effective risk management and data governance programs and internal controls.”

FFIEC Statement on LIBOR Transition

Adam Witmer
Regulatory Update, Compliance Management

On 7/1/2020, the Federal Financial Institutions Examination Council (FFIEC) issued a statement to highlight the risks that will result from the transition away from LIBOR, which is used by the financial industry as a reference rate for many products and instruments like loans, investments, and deposits. In their release, the regulators encouraged financial institutions to continue working toward a transition to alternative reference rates so that financial, legal, operational, and consumer protection risks can be mitigated. While the transition away from the LIBOR will affect some institutions more than others, the regulators state that the impact will affect almost all institutions and, therefore, it would be beneficial for all financial institutions to consider the risks associated with the LIBOR transition.

FFIEC Announces APR & APY Calculation Tools

Adam Witmer
Regulation Z, Regulatory Update, Compliance Management

On April 2016, the FFIEC announced the availability of two new computational tools: one for calculating APY and one for calculating APR. According to the FFIEC, the APR Computational Tool is designed to streamline the process by which examiners and financial institutions can verify finance charges and annual percentage rates included on consumer loan disclosures subject to the Truth in Lending Act and its implementing regulation, Regulation Z. The FFIEC explains that…

FFIEC Statement on Pandemic Preparedness Guidance

Adam Witmer
Regulatory Update, Compliance Management

On March 6, 2020, the Federal Financial Institutions Examination Council updated guidance identifying actions that financial institutions should take to minimize the potential adverse effects of a pandemic. The guidance provides the FFIEC’s expectations that regulated institutions should periodically review related risk management plans, including continuity plans, to ensure their ability to continue to deliver their products and services in a wide range of scenarios and with minimal disruption.

OCC Hammers Former Wells Fargo Execs with Fines

Adam Witmer
Regulatory Update, Compliance Management

On January 23, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of charges against five former senior executives of Wells Fargo Bank, N.A., Sioux Falls, South Dakota, and announced settlements with the bank’s former Chief Executive Officer (CEO) and other members of the bank’s operating committee - including the former chief auditor, a former risk officer, former general counsel, and a former executive audit director.

This notice of charges is of particular interest to compliance and audit professionals as risk managers, auditors, and general counsel don’t typically appear in these types of charges.

The notice of charges alleges these executives…

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