CONSUMER COMPLIANCE PROGRAM. (1) Within ninety (90) days, the Board shall adopt, implement, and thereafter ensure adherence to a written consumer compliance program designed to ensure that the Bank is operating in compliance with all applicable consumer protection laws, rules and regulations. This program shall include, but not be limited to:
(a) a written description of the duties and responsibilities of the compliance officer;
(b) adequate internal controls to ensure compliance with consumer protection laws, rules, and regulations;
(c) the preparation of a policies and procedures manual covering all consumer protection laws, rules and regulations for use by appropriate Bank personnel in the performance of their duties and responsibilities;
(d) semiannual updates of the written policies and procedures manual to ensure it remains current;
(e) an audit program to test for compliance with consumer protection laws, rules and regulations;
(f) procedures to ensure that exceptions noted in the audit reports are corrected and responded to by the appropriate Bank personnel;
(g) the education and training of all appropriate Bank personnel in the requirements of all federal and state consumer protection laws, rules and regulations; and
(h) periodic reporting of the results of the consumer compliance audit to the Board or a committee thereof.
(2) Upon adoption, a copy of the program shall be forwarded to the Assistant Deputy Comptroller for review.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONSUMER COMPLIANCE PROGRAM. (1) Within sixty (60) days, the Board shall review and revise the Bank’s consumer compliance program and implement the revised program, and thereafter ensure adherence to the written program which shall be designed to ensure the Bank is operating in compliance with all applicable consumer protection laws, rules and regulations. The program shall include:
(a) written descriptions of the duties and responsibilities of the Compliance Officer and other key positions in the Compliance area, that clearly define authority and accountability;
(b) adequate internal controls to ensure compliance with consumer protection laws, rules, and regulations, including quality assurance reviews to periodically evaluate compliance;
(c) a policies and procedures manual covering all applicable consumer protection laws, rules and regulations for use by appropriate Bank personnel in the performance of their duties and responsibilities, which identifies employee accountability for required procedures;
(d) updates of the written policies and procedures at least semi-annually, or as required by more frequent changes in laws or regulations, to ensure the program remains current;
(e) a formal compliance review process for new or changed products and services;
(f) procedures to ensure that exceptions noted in the audit reports are corrected and responded to by appropriate Bank personnel; and
(g) an education and training program for all appropriate Bank personnel in the requirements of all applicable federal and state consumer protection laws, rules and regulations, with training tailored to each individual’s responsibilities and duties.
(2) Upon adoption, a copy of the program shall be forwarded to the Assistant Deputy Comptroller for review.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONSUMER COMPLIANCE PROGRAM. (1) Within ninety (90) days, the Board shall adopt a written consumer compliance program designed to ensure that the Bank is operating in compliance with all applicable consumer protection laws, rules and regulations. This program shall include, but not be limited to:
(a) a written description of the duties and responsibilities of the compliance officer;
(b) adequate internal controls to ensure compliance with consumer protection laws, rules, and regulations;
(c) the preparation of a policies and procedures manual covering all consumer protection laws, rules and regulations for use by appropriate Bank personnel in the performance of their duties and responsibilities;
(d) periodic updates of the written policies and procedures manual to ensure it remains current;
(e) an independent audit program to test for compliance with consumer protection laws, rules and regulations, including procedures and sampling adequate to cover laws, rules, and regulations;
(f) procedures to ensure that exceptions noted in the audit reports are corrected and responded to by the appropriate Bank personnel;
(g) the education and training of all appropriate Bank personnel in the requirements of all applicable federal and state consumer protection laws, rules and regulations; and
(h) periodic reporting of the results of the consumer compliance audit to the Board or a committee thereof.
(2) Upon adoption, the Board shall submit a copy of the program required by this Article, and any subsequent amendments or changes to that program, to the Assistant Deputy Comptroller for determination of no supervisory objection. Upon receiving a determination of no supervisory objection from the Assistant Deputy Comptroller, the Board shall implement and thereafter ensure the Bank’s adherence to the program.
CONSUMER COMPLIANCE PROGRAM. (1) Within 60 days, the Bank shall adopt, implement, and thereafter ensure adherence to a written consumer compliance program designed to ensure that the Bank is operating in compliance with all applicable consumer protection laws, rules and regulations. This program shall include, but not be limited to:
(a) a written description of the duties and responsibilities of the compliance officer;
(b) adequate internal controls to ensure compliance with consumer protection laws, rules, and regulations;
(c) the preparation of a policies and procedures manual covering all consumer protection laws, rules and regulations for use by appropriate Bank personnel in the performance of their duties and responsibilities;
(d) annual updates of the written policies and procedures manual to ensure it remains current;
(e) an audit program to test for compliance with consumer protection laws, rules and regulations;
(f) procedures to provide that exceptions noted in the audit reports are corrected and responded to by the appropriate Bank personnel;
(g) the education and training of all appropriate Bank personnel in the requirements of all applicable federal and state consumer protection laws, rules and regulations; and
(h) periodic reporting of the results of the consumer compliance audit to the Board or a committee thereof.
(2) Upon adoption, a copy of the program shall be forwarded to the Assistant Deputy Comptroller for review.
CONSUMER COMPLIANCE PROGRAM. (1) Within ninety (90) days of this Agreement, the Board shall adopt, implement, and thereafter ensure adherence to a written consumer compliance program designed to ensure that the Bank is operating in compliance with all applicable consumer protection laws, rules, and regulations. This program shall include at a minimum:
(a) a written description of the duties and responsibilities of the individual individual(s) responsible for the oversight and management of the compliance management program;
(b) adequate internal controls to ensure compliance with consumer protection laws, rules, and regulations;
(c) the preparation of a policies and procedures manual covering all consumer protection laws, rules, and regulations for use by appropriate Bank personnel in the performance of their duties and responsibilities and specifically tailored to your deposit and lending practices;
(d) timely updates of the written policies and procedures manual to ensure it remains current;
(e) a formalized risk assessment process and annual audit plan to use in determining the frequency and scope of ongoing compliance monitoring and audit;
(f) an independent audit program to adequately test for compliance with consumer protection laws, rules and regulations;
(g) procedures to ensure that exceptions noted in the audit reports are corrected and responded to by the appropriate Bank personnel;
(h) the education and training of all appropriate Bank personnel in the requirements of all applicable federal and state consumer protection laws, rules and regulations;
(i) procedures for the dissemination of changes in laws, rules, regulations and OCC policy changes to affected Bank personnel; and
(j) periodic reporting of the results of the consumer compliance audit to the Board or a committee thereof.
CONSUMER COMPLIANCE PROGRAM. (1) Within sixty (60) days, the Bank shall adopt, implement, and thereafter ensure adherence to a written consumer compliance program designed to ensure that the Bank is operating in compliance with all applicable consumer protection laws, rules and regulations. This program shall include, but not be limited to:
(a) written description of the duties and responsibilities of the compliance officer, including any duties in addition to consumer compliance;
(b) adequate internal controls to ensure compliance with consumer protection laws, rules, and regulations;
(c) an audit program to test for compliance with consumer protection laws, rules and regulations;
(d) procedures to ensure that exceptions noted in the audit reports are corrected and responded to by the appropriate Bank personnel;
(e) the education and training of all appropriate Bank personnel in the requirements of all federal and state consumer protection laws, rules and regulations; and
(f) periodic reporting of the results of the consumer compliance audit to the Board or a committee thereof.
(2) Upon adoption, a copy of the program shall be forwarded to the Assistant Deputy Comptroller for review.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
CONSUMER COMPLIANCE PROGRAM. Within sixty (60) days of the date of this Agreement, the Board shall employ a capable person to serve as a full-time internal Compliance officer who shall be responsible for ensuring the Bank complies with all applicable consumer laws and regulations.
CONSUMER COMPLIANCE PROGRAM. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to a written consumer compliance program designed to ensure that the Bank is operating in compliance with all applicable consumer protection laws, rules and regulations. This program shall include, but not be limited to:
(a) a written description of the duties and responsibilities of the compliance officer;
(b) adequate internal controls to ensure compliance with consumer protection laws, rules, and regulations;
(c) semiannual updates of the written policies and procedures manual to ensure it remains current;
(d) an audit program to test for compliance with consumer protection laws, rules and regulations;
(e) procedures to ensure that exceptions noted in the audit reports are corrected and responded to by the appropriate Bank personnel;
(f) the education and training of all appropriate Bank personnel in the requirements of all federal and state consumer protection laws, rules and regulations; and
(g) periodic reporting of the results of the consumer compliance audit to the Board or a committee thereof.
(2) Upon adoption, a copy of the program shall be forwarded to the ADC for review.
CONSUMER COMPLIANCE PROGRAM. Within sixty (60) days, the Association shall revise its written consumer compliance program (Compliance Program) to address all corrective actions set forth in the 2010 XXX relating to consumer compliance. The Association’s Compliance Program shall comply with all applicable consumer and other compliance laws, regulations and regulatory guidance 1 A modification shall be considered material under this Section of the Agreement if the Association plans to: (a) engage in any activity that is inconsistent with the Business Plan; or (b) exceed the level of any activity contemplated in the Business Plan or fail to meet target amounts established in the Business Plan by more than ten percent (10%), unless the activity involves assets risk-weighted fifty percent (50%) or less, in which case a variance of more than twenty-five percent (25%) shall be deemed to be a material modification. (Compliance Laws and Regulations)2 and be appropriate for the Association’s size, complexity, product lines and business operations.
CONSUMER COMPLIANCE PROGRAM. (1) Within sixty (60) days, the Board shall adopt, implement, and thereafter ensure adherence to an improved consumer compliance program designed to ensure that the Bank is operating in compliance with all applicable consumer protection laws, rules and regulations. This program shall include, but not be limited to:
(a) ensuring sufficient time and resources to assigned staff to successfully carry out their duties;
(b) ongoing and timely board reporting on compliance audit activities that detail all audit findings and required corrective actions;
(c) systems to document and report to the Board on follow-up of identified violations or weaknesses;
(d) developing a training schedule for all applicable laws and regulations, with initial emphasis on the additional training for compliance with the Bank Secrecy Act, Real Estate Settlement Procedures Act, Truth In Lending Act, Flood Disaster Protection Act, and insider regulations for all affected employees.
(e) assigning clear accountability for compliance with all applicable consumer laws and regulation.
(2) Upon adoption, the Board shall submit a copy of the policy to the Assistant Deputy Comptroller for review.
