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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
4 Citi Internal – For Discussion Purposes
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
5 Citi Internal – For Discussion Purposes
How to prepare for a Regulatory Exam
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
6 Citi Internal – For Discussion Purposes
How to prepare for a Regulatory Exam
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
Regulatory Exam Preparation – Stage 2 Considerations
7 Citi Internal – For Discussion Purposes
How to prepare for a Regulatory Exam
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
Regulatory Exam Preparation – Stage 3 Considerations
There are special requirements for certain
Supervisory Letters !
8 Citi Internal – For Discussion Purposes
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
Regulatory Exam Preparation – Stage 4 Considerations
Ensure that you have everyone required for the process !
9 Citi Internal – For Discussion Purposes
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
Regulatory Exam Preparation – Stage 5 Considerations
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