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A compliance manager's responsibilities generally include direct compliance risk program management and/or validation of compliance risk control effectiveness. The execution of operational business processes incorporating compliance risk controls is not a function or duty generally performed by a compliance manager as a normal and customary job responsibility and thus does not qualify towards meeting the experience requirement.
To satisfy the Professional Experience requirement, primary responsibility for the full range of compliance risk functions is required. Compliance risk functions include, but are not limited to:
Performing compliance risk exams, audits or examinations, or Developing, implementing, and/or managing all aspects of a compliance risk management program to ensure compliance with U.S. federal laws and regulations.
These jobs are typically found within corporate compliance, legal, audit departments (internal or external), Regulatory Agencies, or dedicated compliance practices within consulting firms. Job responsibilities must be primarily focused on compliance risk management:
Program design, implementation and oversight, Consultation as a subject-matter expert, Administration, enforcement or audit of compliance-related policies, procedures and processes to manage compliance risk, and/or exam of a bank's compliance program.
Task 1: Act as a compliance subject matter expert on projects and committees.
Task 2: Evaluate development of, or changes to, products, services, processes, and systems to determine compliance risk and impacts and ensure policies remain compliant.
Task 3: Provide compliance support to internal and external parties (e.g., answer questions, review marketing and external communications, conduct research and analysis).
Task 4: Review and/or provide compliance training to applicable parties.
Task 5: Participate in conducting due diligence for vendors.
Task 6: Design and maintain a comprehensive compliance risk exam program to identify and mitigate risk within the organizations risk appetite.
Task 7: Conduct compliance risk exams in accordance with the risk exam program to evaluate relevant information (e.g., inherent risk, control environment, residual risk, potential for consumer harm) and communicate results to applicable parties.
The following knowledge is required to perform the tasks within Domain 1:
• Banks products, services, processes, and operations
• Employee roles and responsibilities
• Compliance risk exam results
• Regulatory change environment
• Compliance monitoring results
• Compliance audit/exam findings
• Compliance management policy (CMP)
• Volume and severity of known compliance incidents, breakdowns, and/or customer complaints
Domain 4: Regulatory Change Management (15%)
Task 1: Monitor and evaluate applicable regulatory agency notifications for new compliance regulations or changes to existing regulations to assess potential regulatory impacts and remediation needs.
Task 2: Assess new, revised, or proposed regulatory changes for compliance impacts, communicate to the appropriate parties, and develop action plans as needed.
Task 3: Assess regulatory guidance and compliance enforcement actions to determine if remediation is required to address potential compliance impacts.
Task 4: Report on the status of regulatory changes and implementation to appropriate parties.
Task 5: Monitor and validate action plans for confirmed regulatory impacts to ensure timely adherence to the mandatory compliance date.
The following knowledge is required to perform the tasks within Domain 4:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Banks products, services, processes, market area, and operations
• Key stakeholders
• Timeline and extent of impact to business units
• Planned changes to critical systems
• New or revised compliance policies, procedures, controls, and training
• Changes to banks products, services, processes, market area, and operations
• Penalties and potential restitution for non-compliance
• Scope of impacts
Domain 5: Regulator and Auditor Compliance Management (11%)
Task 1: Prepare and review requested audit/exam materials to ensure timely and accurate fulfillment and self-identify potential areas of concern.
Task 2: Participate in audit/exam meetings to provide business overviews, address questions, discuss findings, or provide updates to appropriate parties.
Task 3: Review and draft responses to audit/exam results and ensure action plans are developed and communicated to appropriate parties.
Task 4: Report on action plan status to appropriate levels of management and auditors/examiners.
Task 5: Coordinate and submit ongoing regulatory reports to auditors/examiners.
The following knowledge is required to perform the tasks within Domain 5:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Banks products, services, processes, market area, and operations
• Key stakeholders
• Compliance policies, procedures, and controls
• Critical systems and usage by the business units
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