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Staying On Top of Vendor Risk Management News: Week of December 3

Dec 7, 2018 by Branan Cooper

There was so much news this week, I don’t even know where to start – the massive Marriott data breach, the CFPB Ombudsman’s report, the political controversy swirling at the CFPB (as well as its name change) and the first GDPR enforcement action.  Read for more details on each below. 

Industry News for the Week of December 3

Top compliance concerns from November – the first two can have third party implications: Read here

2018 CFPB Ombudsman’s report is here – interesting commentary on the consumer complaint database: Read here

OCC discusses how to modernize the Bank Secrecy Act – remember there can be serious consequences for failing to file SAR’s and there can also be third party implications in meeting BSA/AML requirements: Read here

Massive Marriott data breach: Read here

CFPB disclosure sandbox could put consumers’ data at risk: Read here

NAFCU on exam clarifications: Read here

NYDFS and OCC duke it out over fintech charter – no surprise!: Read here

Ballard Spahr on Chief Compliance Officers: Read here

Regulation revolution in financial services: Read here

Get creative, folks – the basic message from FinCEN and the regulators: Read here and here

OCC semi annual report spends a lot of time thinking about third parties, so you know that will be an exam focus: Read here

OCC Fall 2018 Semiannual Risk Perspective

The OCC has issued its Fall 2018 Semiannual Risk Perspective. The report highlights include:

  • Credit quality remains strong, but the OCC is monitoring the origination quality of new loans, the potential for increased lender complacency within credit risk identification and management, and the potential embedded risks from successive years of eased underwriting.
  • Operational risk is elevated as banks respond to an evolving and increasingly complex operating environment.
  • Compliance risk is elevated as banks manage money laundering risks and comply with amended consumer protection requirements.
  • Rising interest rates and increased competition for deposits may result in changes in funding mix or costs.

The report presents information in five main areas: the operating environment, bank performance, special topics in emerging risk, trends in key risks, and supervisory actions. It focuses on issues that pose threats to those financial institutions regulated by the OCC and is intended as a resource to the industry, examiners, and the public. See the full report: Read here 

Payment tech and fintech challenges as start up: Read here

What’s in a name?  CFPB name change backfires: Read here

States’ AG’s becoming most feared regulator as CFPB re-trenches: Read here

Treasury Department asks the post office to stay out of banking: Read here

How to truncate account numbers properly: Read here

Third Parties help the big banks ride the faster payment rails: Read here

Regulators disagree with FBI on elements of AML reform: Read here

I try not to focus on politics but this is worth reading, amid the 80% drop in enforcement actions and the new Democratic leadership aiming focus on CFPB: Read here

A very interesting first GDPR enforcement action: Read here

Are you prepared to address a vendor data breach if/when it happens? Download our infographic now. 

10 best practices when handling a vendor data breach

Branan Cooper

Written by Branan Cooper

Branan Cooper is the Chief Risk Officer at Venminder. Branan has nearly 30 years of experience in the financial services industry with a focus on the management of operational and regulatory processes and controls—most notably in the area of third party risk and operational compliance. Branan leads the Venminder delivery team as the third party risk management subject matter expert in residence.

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