Compliance Program Management for Financial Services Institutions in Today's Environment

摘要

FSIs are likely to continue to face compliance challenges for the foreseeable future as may be seen from the range of the Program Requirements and enforcement actions described above. One challenge on the horizon is the implementation of Basel II, an integrated global risk capital and risk management framework, under which regulatory capital requirements and compliance will converge. Strong and effective compliance programs will be effectively rewarded in terms of capital and FSIs with strong compliance may enjoy a competitive advantage. In the future, some expect compliance programs to evolve to the point that FSIs will become subject to a regulatory framework for "compliance controls" just as today there is one for internal controls over financial reporting—perhaps Program Requirements are the beginning of this process. The field of compliance programs and management will continue to grow with the changing enforcement and regulatory landscape, and FSI's will need to develop practices to meet these challenges, hopefully to the benefit of their businesses and customers.