Graduate School of Compliance Management
Renaissance Esmeralda Indian Wells in Palm Springs
This two and a half-day program will provide in depth guidance on developing, implementing, and maintaining an effective Compliance Management System (CMS) that fits the Institution’s strategic plans and footprint.
Our new graduate compliance school is designed for compliance officers and managers with at least five years of experience. We’ll weave the board’s and management’s perspective into all aspects of the program and focus on the intricacies of managing the compliance function.
Our instructors will also highlight the latest regulatory changes, and how to get your institution ready to deal with them. Using the CFPB’s standard, we’ll explore the component parts of the CMS and the importance of making sure your CMS Program is both consistent with requirements and appropriate for your institution’s goals.
You will leave better able to:
- Manage change in an environment of rapid growth and expansion into new financial products and services;
- Ensure effectiveness and integrity in audits and internal reviews;
- Negotiate and influence decision-making of various stakeholders including, senior management, the board of directors as well as regulators.
Who Should Attend
- Compliance Officers
- Lending Personnel
- Bank Directors
- CRA Officers
- Bank Counsel
- Graduates of CBA Compliance School
Dates & Accomodations
December 3 – 5, 2013
Renaissance Esmeralda Indian Wells Resort & Spa
44400 Indian Wells Lane
Indian Wells, CA 92210
CBA has arranged a block of rooms at the rate of $139/night plus taxes and resort fee*. Please call the hotel to arrange room reservations and reference the California Bankers Association by November 11, 2013, or click https://resweb.passkey.com/go/CABankersAssn to reserve online.
*Reduced rate of $10.00 for the resort fee includes self parking, guest room internet access, local calls, newspaper, in-room coffee, Fitness Center, resort bicycles and golf bag storage.
Early-Bird Registration (Register by November 4, 2013)
CBA Member: $1,500
CBA Member: $1,800
Cancellation & Complaint Resolution Policy:
Substitutions are allowed, at no additional cost. Written notice is required for all substitutions/cancellations. If written notice is received by November 11, 2013, the full registration fee will be refunded, minus a $500 processing fee. If written notice is received by November 20, 50 percent will be refunded. No refunds will be provided after November 20. Registrations made on or after November 20 are not subject to refund.
Complaints regarding this program should be directed to John Lingvall, VP & Director of Education at (916) 438-4428.
(Breakfast will be available from 7:00 – 8:00 each morning, with lunch about noon)
Sessions will run from 8:00 to 4:00 on days one and two, and 8:00 to Noon on day three.
- Review the components of an effective CMS
- Compliance Responsibilities – Exploring “How To” develop and implement a “Compliance Is Everyone’s Business” culture. Discussing how to speak the Board’s (and Management’s) language to discuss risks, resources, alternative mitigating strategies, and gain support for the CMS.
- Board of Directors – Speaking the Board’s language of risk
- Management – Matching the CMS to strategic plans
- Compliance – Establishing and managing the CMS program plan
- All Staff – Promoting the “Compliance is Everyone’s Job” culture
- Completing a baseline/annual risk assessment: Using multiple methodologies and several real-life examples of challenged programs, we’ll explore the risk assessment process. We’ll consider risk by regulation, risk by business unit/functional area, and a combination of both.
- Raw/Unmitigated Risk – Identifying the risks that are inherent in the institution’s footprint, strategic plan, and regulatory environment
- Risk Mitigating Controls – Recognizing ways to mitigate risk through various control mechanisms, we’ll explore effective mitigation and the art of knowing which mitigating controls work in which situations and which may not.
- Residual/Mitigated Risk – Recognizing and managing to the level of risk acceptable to the institution.
- Applying All Resources Based Upon the Assessed Risk: Building upon the risk profile, we’ll identify the resources necessary and alternatives possible to achieve the Board-approved risk levels.
- Speaking the Language of Management and the Board: This will include gaining an understanding of the institution’s performance, profitability, strategic business plans, and the successful integration of compliance in all institution activities.
- Managing Limited Time and Using Resources: We’ll discuss alternatives to meeting the CMS goals without sacrificing the ability to achieve the acceptable level or risk. We’ll also explore the importance of communicating the CMS plan consistent with the Board’s (and Management’s) plan and risk tolerance
Day Two: CMS Program Components
- Policies and Procedures: We’ll explore what policies and procedures are mandatory, what ones are expected, and what ones make sense for the institution. Using real life examples. We’ll take a case study approach to identify the appropriate policies and procedures that would be needed based upon the CMS status.
- Compliance Change Management: Recognizing that change is inevitable, we’ll build processes that consider regulatory changes, strategic business plan changes, products/services, changes, and the changes dictated by technology. We’ll use recent regulatory changes, common products/services changes from real life examples, and discuss recent and emerging technologies that drive the customer experience to make sure the compliance aspects are clearly and fully addressed.
- Implementing Strategic Plans: Establishing a comprehensive, strategic compliance plan is an often overlooked mandate to make sure the compliance program is properly managed and is consistent with the overall business strategy.
- Implementing New and Revised Rules (laws, regulations, agency guidance): There are multiple examples that will make up our deep-dive to identify the best approach to proper implementation of rules. This will include evaluation of proposed changes for potential impact and meaningful comment.
- Implementing New and Revised Products (products, services, and delivery channels): Similar to the process to implement rules changes, implementing product, service, and delivery channel changes requires the same level of diligent planning and active oversight.
- Compliance Vendor Management: It’s not enough to simply plug and play when it comes to service providers. We’ll dig deep into the process to follow to make sure that relationships with third party providers of compliance and compliance-related solutions meet the institution’s needs, accomplish desired goals, and are appropriately managed. Whether vendors are relied upon under one of the key CMS components or by business units to deliver compliant results, they need to be properly managed by the Compliance Officer.
- Scope of Work
- Adequacy/Accuracy of Deliverable
- Monitoring/Quality Assurance: Early and effective activities to detect and correct compliance weaknesses has always been an important part of the CMS, but it has never been more critical to ensuring the success of the CMS than it is in today’s environment. Based upon the risks identified, we’ll discuss various, successful monitoring and quality assurance plans that make sense for (and are consistent with) the institution’s strategic business plans. We’ll also explore various ways to effectively complete this vitally-important aspect of the CMS.
- Training: We’ll explore the training program as it needs to be built in light of the assessed risks. This will include discussion about minimum training on relevant rules, training on the way the institution operates, and training that is designed to fully support the institution’s strategic plan and the CMS plan. We’ll explore the many aspects of compliance-related training and the myriad of delivery mechanisms – identifying those that make sense as well as those that may not make sense given the cases studied.
- Annual Schedule
- Change Management
- Corrective Action
- Testing Understanding
- Corrective Action Responsiveness: It’s not enough to fix violations identified by examiners or even independent testing. We’ll explore the compliance professional’s methodology regarding violations of rules, exceptions to institution policies/procedures, and best practice recommendations. We’ll explore the process all the way through the confirmation that corrective action was effective.
- Identifying “root cause”
- Action Plan
- Independent Testing: Using recent criticisms of the independent testing component from our case studies, we’ll find solutions that make sense for the institution, are effective, are consistent with identified risks, and meet regulatory agency expectations. We’ll also explore alternatives and cost effective, when properly managed.
- Management Responses
- Consumer Complaints: Clearly among the CFPB’s highest objectives, we’ll make sense out of this process that carries so much importance and poses such significant reputation risk. Beyond the days of responding to written complaints from consumers, we’ll develop processes that provide solutions relevant to the institution – including those with fair lending or UDAAP implications.
- Board Reporting: Recognizing that the CMS must come full circle to the starting point, we’ll discuss the process to provide meaningful and useful information to the Board, so the Board can fulfill its responsibility to ensure an effective CMS. We’ll discuss strategies to help the Compliance Officer know the most effective way to provide necessary information to the Board in a form that meets the Board’s expectations.
- “State of Compliance” Presentation
- Regular Reports
- Special Reports
- Preparing for (and Surviving) Examinations: When the CMS is comprehensive and effective, the examination merely confirms what is already known by the institution. That doesn’t mean, however, that the examination process should be overlooked or taken lightly. We’ll explore proven methods that help ensure a successful examination. We’ll discuss the dos and don’ts that need to be considered, not the least of which is the need to make sure the institution’s staff, management, and Board are all prepared.
William (Wylli) J. Foote, CRCM
Wylli Foote, Director of Thomas Compliance Associates’ (TCA) unique VCM services, has more than 30 years of bank regulatory compliance and risk management experience. In addition to his involvement with our regulatory school, he is a trainer/speaker for the American Bankers Association. A graduate of the ABA’s Graduate School of Banking, National Compliance School and National Graduate Compliance School, Foote serves on the Editorial Advisory Board for the ABA Bank Compliance Magazine and has served on numerous IBA and ABA committees.
James (Jim) D. Dray, CRCM
Jim Dray, President of Thomas Compliance Associates (TCA), began his banking career in 1983 as a bank teller, progressing through the ranks to manage operations and compliance. When the bank merged with a multi-bank holding company, Jim helped manage the compliance function for the four banks in the holding company. During his career, he also oversaw operations, compliance and retail banking for various banks. Jim joined TCA in 2003, has a strong background in BSA/AML and has performed or overseen more than 150 BSA/AML reviews for clients. He was named Director of Audit and Education in 2006, Director of Client Services in 2007, and President in 2009
CPE Credit Information
Program Level: Intermediate/Advanced
Advance Preparation: None
Method of Presentation: Group – Live (Lecture, Discussion, and Table Exercises)
Recommended CPE Credits: TBD
Sponsored learning activities are measured by program length, with one 50-minute period equal to one CPE credit. One-half CPE credit increments (equal to 25 minutes) are permitted after the first credit has been earned in a given learning activity. Please note that not all state boards have adopted this rule. Some participants may not be able to use one-half credit increments
Frequently Asked Questions
Will I receive credits towards the CRCM designation?
Yes, you will. The program will be certified by the ABA, Institute of Certified Bankers