Rethinking compliance management
In the world of banking supervision and regulation, there is a familiar, longstanding cadence to the issuance of new guidance: regulators issue new guidance; banks parse and interpret it, set a strategy for compliance, begin operationalizing it, and press forward with the knowledge that most new guidance is simply a set of expectations rather than hard-and-fast requirements. In today’s environment, the assumption that guidance is just an expectation, not required, is no longer acceptable.
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Over the past few years, a new wrinkle has emerged, hinging on one small word: "should." Historically, regulatory guidance was delivered in the context of "should." As in, banks should do x, y, or z. Recent developments make it clear "should" is increasingly being interpreted as "shall," at least for larger organizations. This environment is creating a new challenge for bank leaders and boards, which must come to terms with the new reality of compliance. Which “shoulds” are really sometimes “shalls?”
This paper explores many of the important tools and considerations being used by industry leaders as they respond to more stringent and forceful regulatory scrutiny.