Bankway 2017 Regulatory Review

Transcription

1 Bankway 2017 Regulatory Review Bankway 2017 Regulatory Review How to Overcome Regulatory Obstacles Karla Alexander-White, CRCM Compliance Manager Christina Schneider, Compliance Manager May 2017

2 Agenda Compliance Overview Known Regulatory Items Deposits Lending Potential Regulatory Items Deposits Lending Watch List Items Deposits Lending Questions 2

3 Corporate Compliance Overview - Product and Services Federal Regulatory Compliance 3

4 Mission and Principles Compliance Mission Statement FIS Guiding Principles The Corporate Compliance mission is to ensure that FIS, its Board members, associates, contractors, vendors, and clients can maintain compliance with the letter and spirit of all applicable laws and conducts business with the highest level of honesty and integrity. At all levels of our organization, we are champions of our client s mission and are guided by the following principles: Building Trust in all we do Inspiring a passion to act Fostering an entrepreneurial spirit Empowering employee growth Encouraging giving back 4

5 Corporate Compliance Overview Fulfilling our mission requires that we foster a culture of high ethical and moral standards by establishing effective governance and oversight, policies and procedures, risk assessment, testing, training and reporting. We accomplish this through a staff of over 50 full-time Compliance associates located across the globe. The Chief Compliance and Customer Advocacy Officer leads nine distinct functional areas with a leadership team that averages over 15 years of compliance experience. Certifications/Degrees on the Compliance team include: Certified Anti-Money Laundering Specialist (ACAMS) Certified Information Privacy Manager (CIPM) Certified Regulatory Compliance Manager (CRCM) Certified Information Privacy Professional (CIPP) Master of Business Administration (MBA) Juris Doctorate (JD) 5

6 Compliance Organization By Functional Area Risk Committee Chief Risk Office Audit Committee Chief Compliance Office Enterprise Product Compliance Model Risk Management International, Institutional & Wholesale BSA/AML Enterprise Program Anti-Bribery, Corruption, Fraud Consumer Privacy Office Export & Sanctions Compliance 6

7 Policy & Procedures Risk Assessments Regulation Management Monitoring Testing Training Reporting Compliance Program Framework Compliance Governance & Oversight Governed by the Executive Risk Management Committee and Board of Directors Reinforced by key program pillars Experience Corporate Compliance Program Expertise The Corporate Compliance Playbook serves as the program s foundation 7

8 Known Regulatory Items 8

9 Known Regulatory Items - Deposits NACHA Same Day ACH Phase 2 and 3 Prepaid Final Rule Annual IRS Reporting Updates (December 2017) Call Report Revisions (March 2017) FinCEN CDD Final Rule NAICS FDIC Proposed Recordkeeping for Timely Deposit Insurance Determination 9

10 Known Regulatory Items - Lending Annual Credit Bureau Updates (September 2017) Credit Bureau Revisions under the NY AG Agreement Call Report Revisions (March 2017) FASB CECL (Early adopters 2018, remaining 2019/2020) CFPB Mortgage Servicing Amendments (Final) HMDA Revisions (Implementation begins 2017) FHLMC Investor Reporting Changes Military Lending (Phase 2) 10

11 Potential Regulatory Items 11

12 Potential Regulatory Items - Deposits NACHA RFC on IAT and Documentation Reg CC Final Rule GLBA Amendments to Reg P FinCEN Technical CTR Amendments ADA Final Rule IRS Proposed Rules For Reporting NRA Interest On Accountholders in Treaty Countries 12

13 Potential Regulatory Items - Lending TRID Proposal Payday, Vehicle Title and Installment Proposal Debt Collections and Credit Bureau Reporting Private Flood Insurance Rule 13

14 Watch List Items 14

15 Watch List Items Business Lending Data for CFPB (ECOA/Reg B) Expanded HSAs with the Healthcare Rule Gramm Leach-Bliley Act (GLBA) Amendments Government Sponsored Enterprise (GSE) Reform Agency Regulatory Review Overdrafts CFPB Oversight of Nonbank Auto Finance Companies 15

16 Karla Alexander-White, CRCM Compliance Manager Christina Schneider, Compliance Manager