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CAS has more than decade of experience in compliance reviews.
These engagements evaluate the effectiveness of the institution's
compliance program by assessing performance with the technical and
complex aspects of consumer protection and public interest topics.
During these engagements, our consultants sample transactions by
following procedures similar to those utilized by your regulatory
examiners.
While the scope of review is defined after discussion with
management, compliance with the following topics is usually monitored
during these engagements:
- Equal Credit Opportunity Act - Regulation B
- Fair Housing Act and implementing regulations
- Home Mortgage Disclosure Act - Regulation C
- Fair Credit Reporting Act
- Community Reinvestment Act
- Flood Disaster Protection Act
- Real Estate Settlement Procedures Act - HUD's Regulation X
- Unfair or Deceptive Acts or Practices - Regulation AA
- Truth in Lending Act - Regulation Z
- Financial Recordkeeping/Bank Secrecy Act
- Electronic Fund Transfer Act - Regulation E
- Expedited Funds Availability Act - Regulation CC
- Truth in Savings Act - Regulation DD
- NOW Account Eligibility & Money Market Deposit Account Procedures
- Insider Lending - Regulation
Consultants work with personnel in identifying any systemic
problems and in making necessary procedural changes to prevent
recurrence of problems. CAS consultants conduct meetings with
management to discuss engagement findings and to offer
recommendations regarding the institution's compliance program.
At the conclusion of the engagement, a report is prepared for the
Board of Directors which identifies the scope of review and findings
of the engagement. The report includes recommendations designed to
enhance compliance performance.
CAS provides services to assist management in taking a "pro-active" approach
to fair lending. CAS follows procedures utilized by the regulatory agencies when
comparing the credit terms and conditions extended to marginally-approved applicants
to the terms requested on applications received from members of protected groups.
This type of engagement emphasizes a comparative side-by-side file analysis
designed to identify discriminatory practices which are not easily detected
during a "technical" review. Consultants compare individual applications and
credit files, as well as, review loan policies and underwriting guidelines for
practices which could result in disparate treatment or have a disparate impact
towards members of protected groups.
CAS also provides an objective evaluation of loan policies, procedures, and
guidelines. Based on our findings, our consultants work with management in
developing an Action Plan to improve compliance with fair lending issues.
A financial institution's loan portfolio is probably its largest risk asset,
and the asset most subject to scrutiny and criticism by your primary regulator.
Most regulatory criticisms usually have an adverse or negative impact on the
institution's earnings and capital.
In today's regulatory environment, senior management continually seeks to
reduce the risk to the institution's earnings/capital and provide an adequate
reserve.
Our highly trained and experienced consultants offer a periodic qualified loan
review as an independent assessment of risk in the loan portfolio. Our
periodic update is provided at a price that is economical.
The procedure includes a review of the institution's compliance with its loan
policy, legal and other documentation required for each type of loan.
Network security is a moving target! The threat of malicious hackers demands constant attention, but
few companies have sufficient resources and personnel for the
battle. Did you know that: 99% of all hacking attacks result from
known vulnerabilities and misconfigurations which means....... 99%
are preventable!
It's not an exaggeration to say that hackers probably audit most
networks more often than administrators do.
HOW CAN CAS HELP?
In addition to being a premiere financial institution consulting
firm, CAS is also a network security consulting firm. Our services
include penetration testing, vulnerability assessments, audits,
security policy, and firewall product installation.
Our network security consulting practice includes:
- Vulnerability Assessment
- Penetration Testing
CAS has extensive experience in developing effective compliance policies and
procedures. Existing policies are examined for content and applicability. If
needed, policies are rewritten to provide appropriate guidance. Our consultants
can also provide assistance to the Board and management in the development of
needed policies.
Policy manuals are normally developed following a topical format. Each policy
identifies the senior officer responsible for compliance, the regulatory
source, and the established controls.
Policy manuals also include "compliance related" organizational charts, job
descriptions for the Compliance Officer(s), and if appropriate, Compliance
Committee, and recommended review schedules to be followed as part of the
institution's self-monitoring program.
CAS is nationally known as a provider of training services specializing in
issues related to compliance with federal regulations. In addition to
presentations made to state associations, regulatory agencies, and banking
departments, CAS provides numerous on-site, in-house training programs. This
environment allows management to discuss specific issues within the confines of
its own institution.
These sessions can be as detailed as needed, and are designed to provide
instructional benefit for the largest number of employees. While consultants
are accomplished in public speaking, they are also experienced in creating an
environment which puts attendees at ease and encourages active participation.
CAS is nationally known as a provider of training services specializing in
issues related to compliance with federal regulations. Also, CAS provides
numerous educational training programs for many state banking associations.
Our staff has been serving financial institutions for well over a decade and are
comprised of former regulators and bankers knowledgeable in all phases of banking.
Our educational training sessions are as detailed as needed, and are designed
to provide instructional benefit for the largest number of employees. While
consultants are accomplished in public speaking, they are also experienced in
creating an environment which puts attendees at ease and encourages active
participation, plus are blessed with a unique ability to reduce complex legal
concepts to plain English.
While it is virtually impossible to mention every educational training session
we offer, the following list outlines some of the most commonly requested
seminar topics:
- Basic Loan Compliance
- Advance Loan Compliance
- Real Estate Loan Documentation
- Deposit Compliance
- Bank Secrecy Act ("BSA") Compliance
- Avoiding Claims of Discrimination
- Fair Lending/Anti-discrimination
- Compliance Risk Management
- Loan Review
- Nondeposit Investment Product Compliance
- Real Estate Settlement Procedures Act ("RESPA") - In & Outs
- Developing an Effective Compliance Program
- Updates on new legislation/regulations
Serious compliance and/or loan deficiencies often result in more strict
regulatory supervision. These actions may range from informal Board Resolutions
to Cease and Desist Orders.
Regardless of the severity, immediate and focused corrective measures must be
implemented. CAS has worked with hundreds of institutions in developing and
overseeing action plans in response to regulatory mandates.
During these engagements, CAS monitors the institution's progress in complying
with each component of the agreement, helps prepare the institution's periodic
responses, conducts appropriate training for affected personnel, and advises
the Board as to progress.
CAS has extensive experience designing a Nondeposit investment products sales
program that complies with financial institution regulatory requirements. In
addition to performing compliance reviews, CAS assists management in:
- Matching products that link the institution's profitability goals to the customer's financial needs.
- Evaluating appropriate language for third-party vendor agreements.
- Designing policy statements that align the institution's program with sound banking practices.
- Creating disclosure forms that clearly communicate the nature of alternative investments and eliminate customer confusion.
- Designing compliance manuals that explain the rules and regulations governing the sale of nondeposit investment products and third part broker/dealers.
- Developing internal review programs to monitor the institution's total sales process.
CAS offers to its consulting clients complimentary use of our Compliance Hotline
support. As questions about regulatory issues arise, the Compliance Officer may
call and discuss the concerns with our consultants who provide workable solutions
to the day-to-day challenges of managing a financial institution.
Whether you are seeking an objective opinion of the effectiveness of your
institution's compliance program or are considering outsourcing the
institution's compliance or loan review program, CAS can help. If you would
like to discuss a particular service in more detail or receive a written
proposal for any of the services outlined on this site, please click here.
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