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Core Compliance (deep, role critical expertise) |
- Electronic Fund Transfers Act / Regulation E
Knowledge of:
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Definitions and Coverage
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Error Resolution
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Disclosures (e.g., initial, subsequent, periodic statements)
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Prepaid Accounts
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Remittance Transfers
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Overdraft Services
- Truth in Savings Act / Regulation DD
Knowledge of:
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Definitions
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Advertising
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Disclosures (e.g., initial, subsequent, periodic statements)
- Equal Credit Opportunity Act / Regulation B
Knowledge of:
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Definitions, Exceptions, and General Rules
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Applications
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Notifications
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Appraisals and other valuations
- Flood Insurance Laws and Regulations including Interagency Q&A
Knowledge of:
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Definitions and Exemptions
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Determination and Purchase of Insurance Requirements
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Escrow
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Force Placement
- Truth in Lending Act / Regulation Z
Knowledge of:
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Definitions, Exemptions, and Finance Charge
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Open End Credit (e.g., credit cards, general lines of credit, HELOCs)
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Closed End Credit (e.g., mortgages, installment loans)
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Private Education Loans
- Home Mortgage Disclosure Act / Regulation C
Knowledge of:
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Definitions and Exemptions
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Compilation of Reportable Data
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Disclosure and Reporting
- Community Reinvestment Act, Implementing Regulations and Interagency Q&A
Knowledge of:
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Definitions
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Delineation of Assessment Area(s)
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Community Development Activities
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Tests (i.e., Lending, Investments, Services)
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Records, Reports, and Disclosure Requirements
- Unfair, Deceptive, or (Abusive) Acts or Practices (UDAP/UDAAP)
Knowledge of:
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Definitions (i.e., Unfair, Deceptive, Abusive, Consumer Harm)
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Deposits (e.g., disclosures)
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Lending (e.g., credit practices)
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Complaints
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Advertising (e.g., sales practice, social media)
- Bank Secrecy Act (BSA)
Knowledge of:
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Five pillars of BSA (i.e., BSA Officer, Internal Controls, Training, Independent Testing, Customer Due Diligence)
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Suspicious activity reporting
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OFAC and sanctions
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37% |
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Compliance Management System (CMS) |
Area 1: Governance and Oversight
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Reporting to Board and Senior Management
Knowledge of:
- Reporting on the status of the compliance program
- Reporting periodic reviews of the compliance management program results and management’s response
- Reporting on the status of regulatory changes and implementation
- Escalating matters outside the institution’s risk appetite to senior management and the board of directors
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Risk Assessments
Knowledge of:
- Designing, conducting, and maintaining comprehensive compliance risk assessment programs (e.g., compliance, fair lending, UDAAP/UDAP)
- Communicating the results of compliance risk assessments to applicable parties (e.g., management, committees, business lines)
- Evaluating the compliance risk within the development of, or changes to products, services, processes, and systems
Area 2 – Compliance Program Components
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Policies and Procedures
Knowledge of:
- Establishing, reviewing, and maintaining a compliance management policy appropriate for the size and complexity of the institution
- Establishing, reviewing, and maintaining regulatory compliance policies appropriate for the size and complexity of the institution
- Establishing and maintaining effective compliance program procedures needed to administer the program
- Reviewing first line procedures to ensure regulatory requirements are being met (e.g., Fair Lending, Regulation E, Regulation Z)
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Training
Knowledge of:
- Developing and conducting appropriate regulatory compliance training for board of directors, management and staff
- Reviewing training materials and tracking enterprise-wide and/or jobspecific regulatory compliance training
- Providing compliance support to internal parties (e.g., answering questions, conducting research and analysis)
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Complaint Management
Knowledge of:
- Administering and/or monitoring a complaint management program
- Developing, reviewing, and/or maintaining procedures for a complaint management program
- Ensuring timely resolution of complaints with a regulatory compliance impact
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Third-Party Risk Management
Knowledge of:
- Assessing new vendors through documentation to ensure regulatory compliance risks are properly addressed
- Participating in conducting ongoing due diligence for vendors with regulatory impact (e.g., periodic reporting, scripts, training)
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Compliance Monitoring
Knowledge of:
- Developing and maintaining a regulatory compliance monitoring plan based on the institution’s strategic plans (e.g., overall compliance risk assessment, fair lending risk assessment, new products and services)
- Defining the scope and test regulatory compliance policies, procedures, controls, reportable data, and transactions against regulatory requirements to identify risks and potential exceptions
- Reviewing and confirming potential exceptions, findings, monitoring results, and recommendations with business units and issue final report to senior management, including amounts to be remediated
- Reviewing the development of, or changes to, products, services, processes, and systems
- Reviewing marketing and external communications
Area 3 – Managing Regulatory Expectations
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Issue Management
Knowledge of:
- Identifying and conducting root cause analysis to determine the scope of the issue
- Collaborating with appropriate parties to develop a complete and timely corrective/resolution action plan
- Reviewing and approving the implementation of the corrective/resolution action plan
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Regulatory Reporting
Knowledge of:
- Completing required reporting, ensuring timely submission to the appropriate agency, and resubmitting when required (e.g., CRA, HMDA, credit card information)
- Coordinating and submitting ongoing regulatory reports to auditors/examiners (e.g., reporting related regulatory enforcement actions, governance reporting requested from regulators)
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Regulatory Change Management
Knowledge of:
- Assessing new, revised, or proposed regulatory changes for compliance impacts, communicating with the appropriate parties, and developing action plans as needed
- Assessing regulatory guidance and compliance enforcement actions to determine if remediation is required to address potential compliance impacts
- Monitoring and validating action plans for confirmed regulatory impacts to ensure timely adherence to the mandatory compliance date
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Examination Management
Knowledge of:
- Preparing and reviewing requested examination materials to ensure timely and accurate fulfillment and identifying potential areas of concern
- Participating in examination meetings to provide business overviews, address questions, discuss findings, or provide updates to appropriate parties
- Reviewing and drafting responses to validated examination results and ensuring action plans are developed and communicated to appropriate parties
- Reporting on action plan status to appropriate levels of management and auditors/examiners
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26% |