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Compliance Management Systems

Comptroller's Handbook CC-CMS. Consumer Compliance (CC). Compliance Management Systems Version , June 2018. Version Contents Introduction ..1. Compliance Management Systems Defined .. 1. Use of this 1. CMS Examinations .. 2. Community Reinvestment Act Considerations .. 3. Heightened Standards .. 3. risks Associated With 4. Compliance Risk .. 4. Operational Risk .. 4. Strategic Risk .. 5. Reputation 5. CMS Components ..6. Board and Management Oversight .. 6. Oversight and Commitment .. 6. Change Management .. 8. Comprehension, Identification, and Management of Risk .. 9. Self-Identification and Corrective Action .. 11. Consumer Compliance Program .. 11. Policies and Procedures .. 11. Consumer Compliance Training .. 12. Monitoring and Audit .. 13. Consumer Complaint Resolution Process .. 15. Violations of Law and Consumer Harm .. 16. Examination Procedures ..17. Scope .. 17. Board and Management Oversight .. 18. Consumer Compliance Program .. 22. Conclusions .. 25.

The consumer compliance risk management principles in this booklet reflect the OCC’s risk-based supervision approach and are consistent with the OCC’s assessment of banks’ risk management systems and the interagency consumer compliance rating definition. The principles in this booklet do not set new or higher expectations for banks.

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