Compliance Management Assessment and Plan
The objectives of the Compliance Assessment are to ensure that Bank’s consumer policies and procedures and supporting management, operational and information reporting systems are in place and meet regulatory compliance requirements. Cadre will review the adequacy of the consumer compliance management function, including:
Organization and staffing
Methods used to monitor changing consumer compliance requirements and needs
Consumer compliance policies, including CRA, lending, electronic banking and others
Consumer compliance training programs
Cadre will conduct appropriate tests of compliance with applicable compliance regulations in those areas specified by the Bank. Where compliance practice and/or procedures require improvement, Cadre will draft appropriate compliance procedures and develop recommendations for changes to supporting operating systems and management information reporting systems. The scope of the compliance audit tests will include all applicable regulations as well as the Compliance function.
Cadre will review policies, observe operations in those areas governed by the regulations and interview appropriate management and staff, review existing compliance procedures documentation and related management information reports and other information, such as forms, templates, disclosures and worksheets, as appropriate. In each area, Cadre will determine whether existing procedures comprehensively address applicable compliance regulations. Where procedures require improvement, Cadre will provide appropriate recommendations for changes to policies, procedures, supporting operating systems, management information reporting systems, training and testing programs, and compliance organization and staffing.