Evaluation of the Compliance Program Risk Assessment
ProBank Austin will conduct a risk assessment related to regulatory compliance. The primary objective is to provide a general assessment of the overall quantity of compliance risk and quality of compliance risk management. Typically, this review is conducted first to establish a baseline of compliance thus assisting with appropriate scheduling from a risk perspective for ongoing reviews.
At the conclusion of fieldwork, ProBank Austin will detail the high risks in the industry, as well as Bank-specific areas requiring management’s attention. During this assessment, our professional will:
- Assess the Bank’s mix of products and services to evaluate regulatory applicability and risk.
- For high-risk areas, discuss with key personnel various processes for meeting compliance requirements.
- Evaluate the auditing and monitoring systems in place for compliance assurance.
- Review prior regulatory agency and internal audit examinations, as well as management’s responses to those exams.
- Evaluate employee responsibilities and accountability for compliance and noncompliance.
- Review and evaluate written compliance policies and procedures to determine if they are comprehensive and provide sufficient guidance to employees.
- Evaluate compliance training programs and employee participation.
Fair Lending Risk Assessment
ProBank Austin will conduct a risk assessment designed to help determine the focus and size of the Bank’s fair lending/non-discrimination analysis. When conducting this risk assessment, our professional will follow guidelines similar to those used by the federal regulatory agencies and will consider:
- Advertising and Marketing
- Audits-Regulatory Examinations
- Community Reinvestment Act Performance
- Demographic Characteristics of the CRA Assessment Area including Branch Distribution
- Employee Training
- Exception Reports
- Loan Officer Compensation Practices
- Loan Officer Decision Making Practices
- Management Oversight – Internal Controls
- Policies and Procedures
- Pricing and Risk-Based Pricing
- Products and Services Offered
- Response to Complaints
- Second Reviews of Declined Loans
- Underwriting Standards