2 min read
Ruminations on the New Dodd-Frank Section 1033 Rule
When the Dodd-Frank Act was passed in 2010, it included Section 1033. This section required the Consumer Financial Protection Bureau (CFPB) to create...
Regulation
2 min read
Control Assessments Vs. Risk Assessments
When we first start working with new institutions, it is not unusual for us to see them struggling because they have focused their efforts on...
2 min read
Don't Forget the Bank Service Company Act
Let’s discuss an old regulation that seems to be picking up new life in recent regulatory examinations, the Bank Service Company Act (BSCA). This Act...
2 min read
Artificial Intelligence–How will it be regulated
Institutions are looking at services using Artificial Intelligence (AI), such as loan decisioning, resume review, and process automation. Using these...
1 min read
Regulatory Compliance vs True Security
Today, I’m going to tackle the tightrope walk between regulatory compliance and real-deal security within the financial sector. It’s like juggling...
2 min read
Consent Orders Put Focus on Third-Party Risk Management
There have been multiple consent orders issued recently which have made it clear that regulators are starting to enforce new third-party risk...
2 min read
Reviewing the New Interagency Third-Party Risk Management Guidance
On June 6th, the Federal Reserve, FDIC, and OCC released new interagency guidance on third-party risk management. The new guidance, based on existing...
1 min read
Regulators Becoming More Prescriptive
Recently, the New York Department of Financial Services (“DFS”) released a proposed update to its 2017 “Cybersecurity Requirements for Financial...
2 min read
Self-Assessing Authentication & Access Risk
A little over a year ago, banking regulators released the “Authentication and Access to Financial Institution Services and Systems” guidance. Since...
2 min read
5 Lessons I Learned From Interviewing A Crypto Expert
Last week, I had the chance to interview Wes Spencer, from FifthWall Solutions, on cryptocurrency in community banking. We’ve had so much good...