NEW PRODUCT & SERVICE REVIEW
COMPLIANCE ISSUE IDENTIFICATION
Product Name:
Implementation Manager:
Desired/Projected Launch Date:
TO-DO’S
Who
Task
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Review Agreement between Bank and vendor, if any, gain understanding of how the
product/program will work
o Review vendor due diligence materials to ensure all requirements are met
o Ensure vendor can comply with all federal and state regulatory requirements for the
product or service. If there are gaps, identify them and plan to address
Review the Risk Assessment, make comments as needed
Get any operational/due diligence questions answered
Consider regulatory impacts
o Outline of compliance aspects of program detailed below.
Review any new product codes developed for the product as established in Fiserv or other
vendor
o Review test outputs to ensure product works as intended, reg. issues, [below] as
relevant, are addressed
Review customer & Bank employee materials/fact sheet of how the product/program will
work
Review any brochures/advertisements/special information or procedures developed for the
customer
Develop/Assist in development of procedures for affected staff to follow.
o Publish to the intranet
Ensure a new workflow in Expedite or other systems needed to accommodate this product
and its unique paperwork are developed and compliance issues addressed as they arise in the
process
Compliance Dept. Signoff
If there are as yet unresolved operational tasks that need to be implemented to address identified and detailed
compliance issues, (identified below as a “GAP”), the Product Manager will keep the Compliance Officer informed
on progress to address those issues. Signoff indicates that the compliance issues and gaps have been identified.
Mitigation & follow up are ongoing post signoff.
Date
Compliance Officer
Date
Chief Risk Officer
1|P a g e
2/9/16
MECHANICS - HOW THE PRODUCT/PROGRAM WILL WORK
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REGULATORY ISSUES
Describe How Each Rule’s Requirements Will Be Impacted & Addressed By The New Service Or Product. A
“GAP” indicates that there is/could be additional steps the Bank must take to address the issue.
REGULATORY APPROVAL
N/A
YES
DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS
Will an application or notice need to be filed with our federal or state regulator(s), and,
if so, do we have the necessary information to submit with the application?
BSA – CIP, OFAC - Consider overall BSA risk profile and impact product may have
N/A
YES
GAP?
DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP
UNFAIR, DECEPTIVE, ABUSIVE ACTS & PRACTICES [UDAAP] – Also complete detailed UDAAP risk assessment
DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS
Are features, risks, and terms of the product explained clearly and conspicuously, or are they buried in a
lengthy document full of "legalese" that makes it difficult for the consumer to make a truly informed choice?
IMPACT
Are fees or penalties structured in such a way that unsuspecting, unsophisticated, or vulnerable
consumers could experience financial difficulties from which it would be difficult to extricate themselves?
IMPACT
Are there financial incentives for bank employees to offer this product over other products that may also
be suitable for the consumer?
IMPACT
Is this a product or service we would recommend to our families?
IMPACT
??
IMPACT
2|P a g e
2/9/16
DEPOSIT RULES
Rule
REG CC/EXPEDITED
FUNDS
AVAILABILITY ACT
REG E/ELECTRONIC
FUNDS TRANSFERS
(OD)
REG DD/TRUTH IN
SAVINGS
REG D/RESERVE
REQUIREMENTS
REG J/CHECK
COLLECTIONS
REG GG/
PROHIBITION ON
FUNDING
UNLAWFUL
INTERNET
GAMBLING
3|P a g e
2/9/16
Covered
or NA?
GAP?
DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP
LENDING RULES
Rule
REG Z/TRUTH IN
LENDING/CARD Act
REGULATION
B/EQUAL CREDIT
OPPORTUNITY ACT
REGULATION
C/HMDA
FAIR CREDIT
REPORTING ACT
COMMUNITY
REINVESTMENT
ACT
FAIR DEBT
COLLECTION
PRACTICES ACT
REAL ESTATE
SETTLEMENT
PROCEDURES ACT
REG O/LOANS TO
INSIDERS
SAFE
ACT/MORTGAGE
LICENSING
REG U/CREDIT BY
BANK FOR
PURPOSE OF
PURCHASING
MARGIN STOCK
REG
FF/OBTAININGUSING MEDICAL
INFORMATION IN
CONNECITON WITH
CREDIT
4|P a g e
2/9/16
Covered
or NA?
GAP?
DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP
OTHER RULES & REQUIREMENTS
Rule
ESIGN/ELECTRONIC
SIGNATURES
GLBA & RFPA/RIGHT TO
FINANCIAL PRIVACY
RED FLAG ID THEFT
FDIC INSURANCE
DORMANCY
STATE OF MD
ESCHEATMENT RULES
GARNISHMENT OF
ACCOUNTS
CONTAINING FEDERAL
BENEFITS PAYMENTS
SCRA/SERVICEMEMBERS
CIVIL RELIEF ACT
DEFENSE DEPARTMENT
REGULATION
LIMITATIONS ON TERMS
OF CONSUMER CREDIT
5|P a g e
2/9/16
Covered
or NA?
GAP?
DESCRIBE IMPACTS OF RULE/BANK’S ACTIONS/GAP