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Crafting an Enterprise Risk Management Program for MSBs – Part 2

10-03-24

Crafting an Enterprise Risk Management Program for MSBs – Part 2

As MSBs and Fintechs get larger and more complex, they may find examiners, auditors, and bank partners asking about their ERM.  In Part 2 of this article, we address the role data, analytics, and quality reporting procedures play in terms of providing management with decision-supporting information across the two important areas of an ERM Program – specifically, the Risk Assessment and Monitoring.  

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Crafting an Enterprise Risk Management Program for MSBs

09-19-24

Crafting an Enterprise Risk Management Program for MSBs

As Money Services Businesses grow, implementing Enterprise Risk Management becomes crucial. This article guides Compliance Officers in starting development of an ERM Program, looking beyond financial crimes risks and focusing on comprehensive risk identification and risk appetite.

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A Very Active CFPB - Part 1: Paycheck Advance Loans

08-19-24

A Very Active CFPB - Part 1: Paycheck Advance Loans

The CFPB has proposed an interpretive rule classifying paycheck advance loans under TILA, which could require APR disclosures for these rapidly growing products. Financial institutions are reassessing their offerings amid increasing scrutiny and potential reputation risks. While supporters argue it protects consumers, opponents claim it's unnecessary for advances on earned wages.

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New Data Insights on U-5 Defamation Cases

08-14-24

New Data Insights on U-5 Defamation Cases

Understanding the true impact of U-5 commentary on employment prospects is critical for both advisors and firms. Our latest analysis of FINRA data provides insights for assessing damages and potential risks.

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Common Examination Criticisms of the BSA Compliance Officer
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07-03-24

Common Examination Criticisms of the BSA Compliance Officer

BSA examiners hold institutions dealing with Fintechs to a higher standard. Bates Group explores how examiner criticisms regarding the BSA Officer role can be a sign of a broader BSA/AML program issue. Read the full article to learn the five key areas examiners scrutinize and how institutions can strengthen their AML programs to navigate the complexities of Fintech firms.

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The Importance of SBOM Compliance in Financial Services
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06-12-24

The Importance of SBOM Compliance in Financial Services

The Software Bill of Materials (SBOM) can be an action-oriented and powerful tool to help you maintain the security, transparency, and compliance of your software systems, especially when incorporating AI and Machine Learning (ML).

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Community Banks and BaaS: New Guidance on Managing Risks
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05-28-24

Community Banks and BaaS: New Guidance on Managing Risks

New guidance from regulators highlights the importance of strong Third-Party Risk Management (TPRM) for community banks offering Banking-as-a-Service (BaaS). The article explores the benefits and risks of BaaS relationships and provides key next steps for Risk Managers in community banks.

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Common Examination Criticisms with Data and Technology Systems
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05-22-24

Common Examination Criticisms with Data and Technology Systems

Recent reports indicate a rise in Bank Secrecy Act (BSA) enforcement actions. However, consent orders focus on data & tech across compliance areas instead of in a dedicated section. This article unveils how regulators address these critical elements – and what it might mean for your institution.

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Managing the Privacy Function in a Financial Institution
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05-01-24

Managing the Privacy Function in a Financial Institution

In a financial institution dedicated to Privacy compliance, the Privacy Officer does much more than manage the Privacy Policy and oversee the sending of the initial and annual Privacy Notices. In this article we look at the multiple departments, disciplines, and skillsets needed for effective management of the Privacy function.

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Avoiding Technology, Data, and Staffing Disconnects when Banking Fintechs
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04-17-24

Avoiding Technology, Data, and Staffing Disconnects when Banking Fintechs

With the increase in the number of financial institutions that are banking Fintechs, there has been a corresponding increase in regulatory scrutiny over this space. In this article, we look at the three fundamental disconnects occurring in the AML and Fraud risk management systems of financial institutions that bank Fintechs, and what can be done to avoid falling under a regulatory consent order.

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AI Inventory and Risk Assessment: What a Financial Institution Risk Officer Needs to Know
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03-14-24

AI Inventory and Risk Assessment: What a Financial Institution Risk Officer Needs to Know

For managers at financial institutions to understand AI risk, they first need to conduct a thorough inventory of what AI is being used, by whom, and for what purpose inside their firm. Regardless of where an institution is in its AI journey, it’s best to take the time to conduct an AI inventory and risk assessment to identify and remediate risks in order to stay safe and sound.

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2023 FINRA Dispute Resolution Statistics: A Look Back
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03-06-24

2023 FINRA Dispute Resolution Statistics: A Look Back

2023 was an interesting year in FINRA dispute resolution. While customer filings dipped to a near-decade low, intra-industry cases grew 50% year-over-year. Despite the shift, core dispute themes remained stable, with top customer-member controversies and security types holding steady. We take a look at the entire year's statistics and trends in this new report.

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