Below are just a few of the Compliance areas I can help implement or enhance with your organization:

Compliance Management System: I can help create or enhance your Compliance Management System (“CMS”), based on the Office of the Comptroller of the Currency (“OCC”) CMS Handbook. The Compliance Program will include a Compliance Program and Policy Manual, Compliance Department, Compliance Training, Compliance Audits, Complaints Management, Bank Secrecy Act (“BSA”) and Anti-Money Laundering (“AML”) Management, Privacy Management, Information Security Management, Contracts Management, Vendor Management, and the Board of Directors Audit Committee.

Compliance Department: I can help create or enhance the Compliance Department. The Chief Compliance Officer will oversee the Compliance Department, which provides compliance guidance to corporate business partners. Compliance will monitor and review new and revised regulations and guidance promulgated by the OCC, CFPB, FDIC, FTC, and the FCC. The Compliance Department will take a proactive monitoring approach to identify procedural or training weaknesses, to preclude regulatory violations. The Compliance Department will review and approve all communications to consumers and customers. Compliance will attend online legal and compliance webinars and subscribe to law firm compliance update communications to stay current with regulatory actions, statutory and regulatory changes, and case law developments.

Compliance Program and Policy Manual: I can help create or enhance your Compliance Program and Policy Manual, which can include the following Policies as applicable: Compliance Program and Policy; Bank Secrecy Act Policy; Office of Foreign Assets Control Policy; Federal Right to Financial Privacy Act Policy; Equal Credit Opportunity Act and Regulation B Policy; Fair Credit Reporting Act Policy; Privacy of Consumer Financial Information Policy; Servicemembers Civil Relief Act Policy; Code of Ethics Policy; Truth-in-Lending Act and Regulation Z Policy; Telephone Consumer Protection Act Policy; Unfair, Deceptive, or Abusive Acts or Practices Policy; CAN-SPAM Act Policy; Electronic Signatures in Global and National Commerce Policy; Social Media Policy; Vendor Management Policy; Fair Debt Collection Practices Act Policy; Identity Theft Protection Program Policy; Complaints and Inquiries Policy; and Community Reinvestment Act Policy. A quarterly Compliance Policy Report will be presented to the Board of Directors Audit Committee.

Compliance Training: I can help create or enhance your Compliance Training Program in the following areas: FDCPA, FCRA, ECOA/Fair Lending, TILA, GBLA, EFTA, TCPA, FTCA, UDAAP, SCRA, BSA/AML, and OFAC. I will ensure that the Board receives specific training on an annual basis, such as ECOA/Fair Lending and BSA/AML. A quarterly Compliance Training Report will be presented to the Board of Directors Audit Committee.

Compliance Audits: I can help create or enhance your Compliance Audits Program. An audit is an independent review of compliance with consumer protection laws and regulations and adherence to internal policies and procedures. An audit complements the internal monitoring system and it helps management ensure ongoing compliance and identify compliance risk conditions. I will help determine the scope of the audits and the frequency with which audits are to be conducted. A quarterly Audit Management Report will be presented to the Board of Directors Audit Committee.

Complaints Management: I can help create or enhance your Complaints Management Program. The Program will include the Board approved Complaints Policy. The Complaint Tracking System will track all Complaints by using specific codes. The codes will be assigned once a review of the Complaint response is completed. Compliance will review all responses to Complaints before they are sent. Using the codes, various reports can be generated regarding Complaints. These reports will be shared with the Complaint Committee and further discussed in the quarterly Complaints Meeting, which will include senior management from all departments. A quarterly Complaints Management Report will be presented to the Board of Directors Audit Committee.

Bank Secrecy and Anti-Money Laundering Management: I can help create or enhance your BSA/AML Program. We can help the Board appoint a BSA Officer to implement the BSA/AML Program. The Program will include the Board approved BSA Policy, the Office of Foreign Assets Control (“OFAC”) Policy, a BSA Risk Assessment, a BSA Officer, a Customer Identification Program (“CIP”), a system of internal controls, testing of BSA compliance and monitoring, and BSA training for all employees and members of the Board. A quarterly BSA and OFAC Management Report will be presented to the Board of Directors Audit Committee.

Privacy Management: I can help create or enhance your Privacy Program. The Program will include a Board approved Privacy of Consumer Financial Information Policy and the Federal Right to Financial Privacy Act Policy. The Policies will formalize the commitment to safeguard customers’ personal information, transactions and account records while providing guidance to employees in carrying out their responsibilities. The Compliance Department will ensure that the customers’ records are accurate and confidential and that the customer receives an annual Privacy Notice each calendar year. A quarterly Privacy Report will be presented to the Board of Directors Audit Committee.

Information Security Management: I can help create or enhance your Information Security Program. We can help the Board appoint an Information Security Officer to implement the Information Security Program. The Board will approve the Information Security Policy, which will communicate the requirements for secure use of company resources and represent the strategy for how to implement the information security principles and technologies. This Policy represents senior management’s commitment to maintaining a secure network, which will allow the IT Staff to do a more effective job of securing the information assets. The Policy also provides legal protection by specifying exactly how users can and cannot use the network, how they should treat confidential information, and the proper use of encryption. It is the intent of the Policy to clearly communicate the requirements necessary for compliance with any applicable regulations, as well as any data confidentiality agreements with third parties. A quarterly Information Security Report will be presented to the Board of Directors Audit Committee.

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