Our friends over at Pacific Coast Bankers Bank publish a daily bulletin for their readers and there was a story in this morning’s issue that really caught our attention. It’s about the deluge of regulatory guidance that has come out this year and how PCBB found that FDIC Financial Institution Letters (not including FRB, OCC or CFPB Bulletins) have increased 61% so far in 2016 over the total number issued in 2015. They went on to say that all that guidance, on an annualized basis, will amount to roughly 5400 pages of regulatory information! That’s a lotta stuff bankers have to receive, study, interpret and act upon in order to stay current with regulatory expectations regarding risk management, corporate governance, compliance and safety & soundness.
OK, that’s the UGLY part.
Then comes the BAD part: How in the world are you supposed to cope with all that guidance? Remember, all this new guidance is not “in place of” but rather, it’s “in addition to” what you’re already doing and that’s a baaaad proposition. Think about it, who’s supposed to implement all that guidance? Who’s supposed to perform the risk assessments relative to all that guidance? Who’s supposed to report to the Board and/or its Risk Committee on the outcome of all that guidance? Is that person YOU?
Are you as exhausted as we are thinking about all this stuff?
Well, here’s the GOOD part. The team at TraceRisk sat around the table this morning with a big pot of hot coffee and a box of donuts (yeah, we like ’em, too) and we re-imagined our role in helping banks assess the risks outlined by the FDIC, OCC, FRB and CFPB in all those guidance letters. We already know that our clients look to us for innovation when helping them keep pace with all that guidance. Our discussion revolved around what more could we do. First, we’re going to continue to provide useful answers to questions posed on the CBANC website. We love this forum and we hope you like our offerings.
Next, we decided that the Content and Features teams at TraceRisk will focus on delivering risk assessment modules (we call ’em Subjects) that have a one-to-one relationship with emerging regulatory guidance and do it within 30 business days of issuance. In this way, we believe that Chief Risk Officers (or those bankers tasked with risk management responsibilities) will be able to perform timely risk assessments on “hot” topics and be ready to confidently report to their Boards on the latest issues. Moreover, CROs want to be ready for the examiners when they show up and start asking tough questions. We concluded that in a thankless job like risk management, CROs can be heroes if properly equipped and informed and that is a GOOD thing. And, that’s where we can help most.
If you’re looking for a partner and not just a vendor to help you with your enterprise risk assessments, and, you want to avoid producing complicated charts and graphs that require heavy interpretation and are not “actionable”, give us a call at TraceRisk. You’ve got a lots of important things to do – let us help you get this one done.