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A compliance manager's responsibilities generally include direct compliance risk program management and/or validation of compliance risk control effectiveness. The execution of operational business processes incorporating compliance risk controls is not a function or duty generally performed by a compliance manager as a normal and customary job responsibility and thus does not qualify towards meeting the experience requirement.
To satisfy the Professional Experience requirement, primary responsibility for the full range of compliance risk functions is required. Compliance risk functions include, but are not limited to:
Performing compliance risk assessments, audits or examinations, or Developing, implementing, and/or managing all aspects of a compliance risk management program to ensure compliance with U.S. federal laws and regulations.
These jobs are typically found within corporate compliance, legal, audit departments (internal or external), Regulatory Agencies, or dedicated compliance practices within consulting firms. Job responsibilities must be primarily focused on compliance risk management:
Program design, implementation and oversight, Consultation as a subject-matter expert, Administration, enforcement or audit of compliance-related policies, procedures and processes to manage compliance risk, and/or Examination of a bank's compliance program.
Task 1: Act as a compliance subject matter expert on projects and committees.
Task 2: Evaluate development of, or changes to, products, services, processes, and systems to determine compliance risk and impacts and ensure policies remain compliant.
Task 3: Provide compliance support to internal and external parties (e.g., answer questions, review marketing and external communications, conduct research and analysis).
Task 4: Review and/or provide compliance training to applicable parties.
Task 5: Participate in conducting due diligence for vendors.
Task 6: Design and maintain a comprehensive compliance risk assessment program to identify and mitigate risk within the organizations risk appetite.
Task 7: Conduct compliance risk assessments in accordance with the risk assessment program to evaluate relevant information (e.g., inherent risk, control environment, residual risk, potential for consumer harm) and communicate results to applicable parties.
The following knowledge is required to perform the tasks within Domain 1:
• All applicable laws, regulations, and guidance
Other essential CRCM knowledge:
• Risk assessment program scope and objectives
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Banks products, services, processes, market area, and operations
• Regulatory and industry landscape
• Risk rating methodology
• Key risk indicators (KRIs)
• Volume and severity of known compliance incidents, breakdowns, and/or customer complaints
• Compliance policies, procedures, and other internal controls (e.g., quality assurance, independent testing)
• Exam/audit and internal compliance monitoring results
• Volume and complexity of products, transactions, and customer base
• Recent changes to compliance regulations, key personnel, products, services, systems, and/or processes
• Volume and complexity of products and services provided by third parties
Domain 2: Compliance Monitoring (25%)
Task 1: Define the scope of a specific monitoring or testing activity.
Task 2: Test compliance policies, procedures, controls, and transactions against regulatory requirements to identify risks and potential exceptions.
Task 3: Review and confirm potential exceptions, findings, and recommendations with business units and issue final report to senior management.
Task 4: Validate that any required remediation was completed accurately and within required timelines.
Task 5: Administer a complaint management program.
Task 6: Review first line compliance monitoring results and develop an action plan as needed.
Task 7: Evaluate the reliability of systems of record and the validity of data within those systems that areused for compliance monitoring.
The following knowledge is required to perform the tasks within Domain 2:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Regulator expectations
• Banks products, services, processes, market area, and operations
• Compliance policies, procedures, and controls
• Applicable source data
• Target audience
• Compliance risk rating methodology
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Complaints received internally and externally, including volumes, sources, trends, and root causes
• Regulatory expectations on complaint management program administration
• Complaint handling procedures
• Critical systems and usage by the business units
• Recent changes to critical systems or processes
Domain 3: Governance and Oversight (10%)
Task 1: Establish and maintain a compliance management policy to set expectations for board, senior management, and business unit responsibilities.
Task 2: Develop, conduct, and track enterprise-wide and/or job-specific compliance training.
Task 3: Conduct periodic reviews of the compliance management program to evaluate its effectiveness and communicate results to appropriate parties.
The following knowledge is required to perform the tasks within Domain 3:
• Regulatory expectations
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Banks products, services, processes, and operations
• Employee roles and responsibilities
• Compliance risk assessment results
• Regulatory change environment
• Compliance monitoring results
• Compliance audit/exam findings
• Compliance management policy (CMP)
• Volume and severity of known compliance incidents, breakdowns, and/or customer complaints
Domain 4: Regulatory Change Management (15%)
Task 1: Monitor and evaluate applicable regulatory agency notifications for new compliance regulations or changes to existing regulations to assess potential regulatory impacts and remediation needs.
Task 2: Assess new, revised, or proposed regulatory changes for compliance impacts, communicate to the appropriate parties, and develop action plans as needed.
Task 3: Assess regulatory guidance and compliance enforcement actions to determine if remediation is required to address potential compliance impacts.
Task 4: Report on the status of regulatory changes and implementation to appropriate parties.
Task 5: Monitor and validate action plans for confirmed regulatory impacts to ensure timely adherence to the mandatory compliance date.
The following knowledge is required to perform the tasks within Domain 4:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Banks products, services, processes, market area, and operations
• Key stakeholders
• Timeline and extent of impact to business units
• Planned changes to critical systems
• New or revised compliance policies, procedures, controls, and training
• Changes to banks products, services, processes, market area, and operations
• Penalties and potential restitution for non-compliance
• Scope of impacts
Domain 5: Regulator and Auditor Compliance Management (11%)
Task 1: Prepare and review requested audit/exam materials to ensure timely and accurate fulfillment and self-identify potential areas of concern.
Task 2: Participate in audit/exam meetings to provide business overviews, address questions, discuss findings, or provide updates to appropriate parties.
Task 3: Review and draft responses to audit/exam results and ensure action plans are developed and communicated to appropriate parties.
Task 4: Report on action plan status to appropriate levels of management and auditors/examiners.
Task 5: Coordinate and submit ongoing regulatory reports to auditors/examiners.
The following knowledge is required to perform the tasks within Domain 5:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Banks products, services, processes, market area, and operations
• Key stakeholders
• Compliance policies, procedures, and controls
• Critical systems and usage by the business units
• Services provided by third parties
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Effectiveness of actions taken
• Regulatory expectations
• Top risk, emerging risk, and areas of continued focus
• New bank products, services, processes, market area, and operations
Domain 6: Compliance Analysis and Internal/External Reporting (11%)
Task 1: Analyze and validate data to support regulatory reporting and ensure accuracy and comprehensiveness.
Task 2: Complete required reporting, ensure timely submission to the appropriate agency, and resubmit when required.
Task 3: Develop, implement, and monitor a plan of action to prevent future reporting errors or breakdowns.
The following knowledge is required to perform the tasks within Domain 6:
• CRA
• HMDA
• BSA (CTR, SARS)
• OFAC
• Regulation Z (Credit card agreements, marketing on college campuses)
• Regulation II
• Banks products, services, processes, market area, and operations
• Critical systems and usage by the business units
• Findings and root causes
• Compliance policies, procedures, and controls
• Regulator expectations
• Compliance risk appetite (e.g., thresholds, escalation points)
• Penalties and potential restitution for non-compliance
• Scope of impacts
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