Over the last three years, and particularly since the enactment of the Dodd-Frank Act, a great deal has been written and said about the increased burden that will be placed upon compliance officers and banks of all sizes. As is too often the case, speculation has not led to much in the way of action. And it is abundantly clear that affordable help is needed.
At the Annual Meeting of the MRCG and MSRCG, we outlined a vision for a plan to provide just such help. We called for a Focus Group of the combined MRCG/MSRCG that would examine ways that the members of the two groups could pool their strengths and resources to gain the extra measure of help that is needed to cope with the growing burden of compliance, while allowing each member to only incur a small cost due to the cost-sharing power of 80 banks.
As you read this article, the Focus Group is in the process of meeting. A substantial number of members of both groups will meet February 1, 2012 in both Butler Snow’s Ridgeland and Memphis offices to brainstorm about the things we can do to make a compliance officer’s or a bank president’s life easier and more manageable. Among the things we plan to discuss are an overall Compliance Risk Assessment and a targeted Risk Assessment for Unfair and Deceptive Acts or Abusive Practices. (These are two new areas of compliance that examiners are currently stressing.) Training, a burden that every bank faces, is another area that will be considered. And a systematic way to quickly and affordably help a bank’s management and its board of directors stay informed regarding Page 4 changes and developments in banking laws and regulations is yet another possibility.
We plan to take the results of this Focus Group meeting and present it to the membership as a whole at the upcoming February meeting in hopes of getting off to a fast start in implementing this much needed help. Please bring your thoughts and ideas to the February meeting.