the impact of compliance and security changes in...
TRANSCRIPT
The Impact of Compliance and Security Changes in Mercury
May 2017
Karla Alexander-White, CRCM Compliance Manager
Christina Schneider, Compliance Manager
Agenda
2
• Compliance Overview
• Known Regulatory Items
– Deposits
– Lending
• Potential Regulatory Items
– Deposits
– Lending
• Watch List Items
– Deposits
– Lending
• Questions
3
Product and Services Federal Regulatory Compliance
Corporate Compliance Overview:
Mission and Principles
4
Compliance Mission Statement
The Corporate Compliance mission is to
ensure that FIS, its Board members,
associates, contractors, vendors, and
clients can maintain compliance with the
letter and spirit of all applicable laws and
conducts business with the highest level
of honesty and integrity.
FIS Guiding Principles
At all levels of our organization, we are
champions of our client’s mission and are
guided by the following principles:
• Building Trust in all we do
• Inspiring a passion to act
• Fostering an entrepreneurial spirit
• Empowering employee growth
• Encouraging giving back
Compliance Overview
5
• Fulfilling our mission requires that we foster a culture of high ethical and moral standards by
establishing effective governance and oversight, policies and procedures, risk assessment,
testing, training and reporting.
• We accomplish this through a staff of over 50 full-time Compliance associates located across
the globe.
• The Chief Compliance and Customer Advocacy Officer leads nine distinct functional areas with a
leadership team that averages over 15 years of compliance experience.
Certifications/Degrees on the Compliance team include:• Certified Anti-Money Laundering Specialist (ACAMS)
• Certified Information Privacy Manager (CIPM)
• Certified Regulatory Compliance Manager (CRCM)
• Certified Information Privacy Professional (CIPP)
• Master of Business Administration (MBA)
• Juris Doctorate (JD)
Compliance Organization – By Functional Area
6
Risk
Committee
Audit
Committee
Chief Risk
Office
Chief
Compliance
Office
Enterprise
Product
Compliance
International,
Institutional &
Wholesale
Enterprise
Program
Consumer
Export &
Sanctions
Compliance
Model Risk
Management
BSA/AML
Anti-Bribery,
Corruption, Fraud
Privacy Office
Corporate Compliance Program
Governed by the
Executive Risk
Management Committee
and Board of Directors
The Corporate Compliance Playbook
serves as the program’s foundation
Reinforced by key
program pillars
Po
licy &
Pro
ce
dure
s
Ris
k A
sse
ssm
en
ts
Re
gu
latio
n M
an
ag
em
en
t
Mo
nito
rin
g
Te
stin
g
Tra
inin
g
Rep
ort
ing
Compliance Governance
& Oversight
Compliance Program Framework
7
Experience | | Expertise
8
Known Regulatory Items
Known Regulatory Items - Deposits
9
• NACHA Same Day ACH Phase 2 and 3
• Prepaid Final Rule
• Annual IRS Reporting Updates (December 2017)
• Call Report Revisions (March 2017)
• FinCEN CDD Final Rule
• NAICS
• FDIC Proposed Recordkeeping for Timely Deposit Insurance Determination
Known Regulatory Items - Lending
10
• Annual Credit Bureau Updates (September 2017)
• Credit Bureau Revisions under the NY AG Agreement
• Call Report Revisions (March 2017)
• FASB CECL (Early adopters 2018, remaining 2019/2020)
• CFPB Mortgage Servicing Amendments (Final)
• HMDA Revisions (Implementation begins 2017)
• FHLMC Investor Reporting Changes
• Military Lending (Phase 2)
11
Potential Regulatory Items
Potential Regulatory Items - Deposits
12
• NACHA RFC on IAT and Documentation
• Reg CC Final Rule
• GLBA Amendments to Reg P
• FinCEN Technical CTR Amendments
• ADA Final Rule
• IRS Proposed Rules For Reporting NRA Interest On Accountholders in Treaty Countries
Potential Regulatory Items - Lending
13
• TRID Proposal
• Payday, Vehicle Title, and Installment Proposal
• Debt Collections and Credit Bureau Reporting
• Private Flood Insurance Rule
14
Watch List Items
Watch List Items
15
• Business Lending Data for CFPB (ECOA/Reg B)
• Expanded HSAs with the Healthcare Rule
• Gramm Leach-Bliley Act (GLBA) Amendments
• Government Sponsored Enterprise (GSE) Reform
• Agency Regulatory Review
• Overdrafts
• CFPB Oversight of Nonbank Auto Finance Companies
Thank YouKarla Alexander-White, CRCM Compliance Manager
Christina Schneider, Compliance Manager