EMEA COMPLIANCE SUMMIT 2017

Transcription

1 EMEA COMPLIANCE SUMMIT 2017 Regulatory Exam Management Anya Fainberg EMEA Regulatory Exam Governance and Compliance, Citi Citi Academy for Financial Institution Professionals 4 5 April 2017

2 2 Overview: Regulatory Interaction Era: period of time, usually in history, that is different from other periods because of particular characteristics or events [Oxford dictionary] Post Financial Crisis Issues, Fines, Breaches Heightened Expectations Changing Regulatory Landscape Macro Environment ERA of Increased Regulatory Interaction

3 3 Regulatory Protocols The Do s and Don ts.

4 How to prepare for a Regulatory Exam Citi Internal For Discussion Purposes 4 Regulatory Exam Life Cycle Stage 1 Pre-Exam Communication Notification Preparation The Exam Coordinator Primary contact with the Regulator Manages the exam stages Stage 2 The Exam Documents Onsite Meetings Status Updates Stage 3 Stage 4 Stage 5 Field Work Completed Response to Regulator Issues / CAPs Follow up Items Exit Meeting Report / Feedback Response Drafting Analysis / Assessment Review and Approval Recording Tracking

5 How to prepare for a Regulatory Exam Regulatory Exam Preparation Stage 1 Considerations Stage 1 Opening Day Letter Roles and Responsibilities Communication Schedule Regulatory Issues Prior Exams Pre-Exam Exam Scope / Objective Key Dates Identify potential challenges Exam Coordinator Business / Function Lead Product Compliance Communication Plan Exam Working Group Key Stakeholder Updates Communication with Regulator Previous Exam Issues Global and Regional Considerations Previous Exam Materials Relevant Exam Materials Communication Notification Preparation The Exam Coordinator Primary contact with the Regulator Manages the exam stages Status of CAPs Status Update on CAPs Housekeeping Relevant Policies and Procedures Key Reports and MIS Logistics Onsite Logistics Home/Host State Requirements Citi Internal For Discussion Purposes 5

6 6 How to prepare for a Regulatory Exam Regulatory Exam Preparation Stage 2 Considerations Stage 2 The Exam Documents Onsite Meetings Preparation Documents Onsite Meetings Presentations Preparation Information Request Items First Day Deliverables Onsite Request Items Collection, Collation and QC Tracking and Delivery Meeting Schedule Opening Day Meetings Targeted Sessions Interviews Agenda Topics Logistics Meeting Notes Deck Preparation Collection, Collation and QC Tracking and Delivery Prep Sessions / Dry Runs Training on Regulatory Protocol Debrief Meetings Status Updates

7 7 How to prepare for a Regulatory Exam Regulatory Exam Preparation Stage 3 Considerations Stage 3 Field Work Completed Follow up Items Exit Meeting Report / Feedback There are special requirements for certain Supervisory Letters! Follow Up Items Information Request Items Onsite Meeting Deliverables Clarification Items Exit Meetings Report / Feedback Schedule Meeting Logistics Meeting Notes Notification to Key Stakeholders Receipt of Report / Feedback Letter Notification to Key Stakeholders Regulatory Findings Tiers Establish Time Line

8 8 EMEA Regulatory Exam Management Regulatory Exam Preparation Stage 4 Considerations Stage 4 Response to Regulator Drafting Analysis and Assessment Review and Approval Drafting Engage all required parties Ensure IA are engaged in the process Agree roles and time lines Prepare Draft Response Letter Ensure that you have everyone required for the process! Analysis and Assessment Analysis of the issues raised Issues raised Recommendations Observations Assess proposed corrective actions Global and Regional considerations Review / Approval Circulate Final Draft Obtain required approvals Record and Track

9 9 EMEA Regulatory Exam Management Regulatory Exam Preparation Stage 5 Considerations Stage 5 Issues and CAPs Recording Tracking Recording RET record updated icaps record created Tracking / Reporting Regulatory Issue Tracking Various Reporting on open CAPs IA Validation process

10 10 Recent Regulatory Trends & Areas of Focus

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