EMEA COMPLIANCE SUMMIT 2017 - Citibank · EMEA COMPLIANCE SUMMIT 2017 Regulatory Exam Management...

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 Citi Internal – For Discussion Purposes

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 Changing Regulatory

Landscape

Macro Environment

Issues, Fines, Breaches

Heightened Expectations

“ERA” of Increased Regulatory Interaction


• The Do’s and Don’ts ….

Regulatory Protocols


How to prepare for a Regulatory Exam

Stage 1

Stage 2

Stage 3

Stage 4

Stage 5

• Communication • Notification • Preparation

Pre-Exam

The Exam

Field Work Completed

Response to Regulator

Issues / CAPs

• Documents • Onsite Meetings • Status Updates

• Follow up Items • Exit Meeting • Report / Feedback

• Response Drafting • Analysis / Assessment • Review and Approval

• Recording • Tracking

Regulatory Exam “Life Cycle”

The Exam Coordinator • Primary contact with the Regulator • Manages the exam stages



Stage 1

• Communication • Notification

• Preparation

Pre-Exam

Opening Day Letter • Exam Scope / Objective • Key Dates • Identify potential challenges

Roles and Responsibilities

• Exam Coordinator • Business / Function Lead • Product Compliance

Communication Schedule

• Communication Plan Exam Working Group Key Stakeholder Updates Communication with Regulator

Regulatory Issues • Previous Exam Issues • Global and Regional Considerations

Prior Exams • Previous Exam Materials • Relevant Exam Materials

Status of CAPs • Status Update on CAPs

“Housekeeping” • Relevant Policies and Procedures • Key Reports and MIS

Logistics • Onsite Logistics • Home/Host State Requirements

The Exam Coordinator • Primary contact with the Regulator • Manages the exam stages

Regulatory Exam Preparation – Stage 1 Considerations



Stage 2

• Documents • Onsite Meetings

• Preparation

The Exam

Documents

• Information Request Items “First Day Deliverables” Onsite Request Items • Collection, Collation and QC • Tracking and Delivery

Onsite Meetings

• Meeting Schedule Opening Day Meetings Targeted Sessions Interviews • Agenda Topics • Logistics • Meeting Notes

Presentations • Deck Preparation • Collection, Collation and QC • Tracking and Delivery

Preparation

• Prep Sessions / “Dry Runs” • Training on Regulatory Protocol • Debrief Meetings • Status Updates




Stage 3

• Follow up Items • Exit Meeting

• Report / Feedback

Field Work Completed

Follow Up Items • Information Request Items Onsite Meeting Deliverables Clarification Items

Exit Meetings

• Schedule Meeting • Logistics • Meeting Notes • Notification to Key Stakeholders

Report / Feedback

• Receipt of Report / Feedback Letter Notification to Key Stakeholders Regulatory Findings – Tiers Establish Time Line


There are special requirements for certain

Supervisory Letters !


EMEA Regulatory Exam Management

Stage 4

• Drafting • Analysis and Assessment

• Review and Approval

Response to Regulator

Drafting

• Engage all required parties Ensure IA are engaged in the process • Agree roles and time lines • Prepare Draft Response Letter

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


Ensure that you have everyone required for the process !


EMEA Regulatory Exam Management

Stage 5

• Recording • Tracking

Issues and CAPs

Recording • RET record updated • iCAPs record created

Tracking / Reporting • Regulatory Issue Tracking • Various Reporting on open CAPs • IA Validation process



Recent Regulatory Trends & Areas of Focus

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EMEA COMPLIANCE SUMMIT 2017 - Citibank · EMEA COMPLIANCE SUMMIT 2017 Regulatory Exam Management...

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