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Compliance Management Systems: Who needs ‘em?
Chuck Cain, SVP-Agency
Rick Diamond, SVP, Information Technology-Agency Operations
Who started this?
• CFPB 2012-03 (April, 2012) Lender may be liable for the actions of its service providers
• OCC Bulletin 2013-29 on vendor oversight (April, 2013) The shift from “safety and soundness” to UDAAP
• Federal Reserve Bank Guidance letter of December 2013 Lenders will be held responsible for all actions of the settlement
2012 CFPB Supervision & Examination Manual
“The CFPB expects every regulated entity under its supervision and enforcement authority to have an effective compliance management system adapted to its business strategy and operations.”
So what is a CMS?
It’s a program that
1. Establishes compliance practices and procedures
2. Communicates responsibilities to employees
3. Ensures that compliance responsibilities and policies are incorporated into business practices.
4. Provides for review of policies and procedures to ensure compliance
5. Provides for necessary corrective action
Components of a CMS
• Must have Board and management oversight and responsibility
• Must be a comprehensive compliance program
• Must have a established procedures to respond to consumer complaints
• Must have a compliance audit procedure
WFG Compliance Management System “CMS”
Tour http://www.wfgagent.com/compliance
ARE YOU COMPLIANT?
www.wfgagent.com/compliance
AGENCY TRUSTED PARTNERS
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AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY TRUSTED PARTNERS
www.wfgagent.com
AGENCY CMS TOUR
www.wfgagent.com
AGENCY CMS TOUR
About
AGENCY CMS TOUR
About
AGENCY CMS TOUR
About
AGENCY CMS TOUR
About
AGENCY CMS TOUR
About
AGENCY CMS TOUR
User Guide
AGENCY CMS TOUR
User Guide
AGENCY CMS TOUR
Compliance Standards
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Policies and Procedures
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Technology Solutions
AGENCY CMS TOUR
Technology Solutions
AGENCY CMS TOUR
Create a Compliance Package
AGENCY CMS TOUR
Technology Solutions
AGENCY CMS TOUR
Technology Solutions
AGENCY CMS TOUR
Compliance Training
AGENCY CMS TOUR
Compliance News
Agency Compliance Management System “CMS” Tour
