We have the resources, knowledge, and experience to assist you in managing your compliance responsibilities and risks now and into the future. The assessment scope includes a detailed examination of your financial institution’s compliance with the consumer protection laws and regulations applicable to your Bank’s deposit and loan products and services.
The Capsa Group approach is based on leveraging our detailed understanding of bank regulatory requirements with the knowledge and experience of the Bank’s operations and compliance personnel. We closely follow the process and procedures in the Consumer Compliance Handbook established by the Federal Reserve Board to ensure alignment with the most current regulations as well as to facilitate the successful completion of any subsequent compliance exam initiated by the FDIC or Federal Reserve Board. The Capsa Group also develops and maintains compliance programs based on guidance and procedures established and published by the FFIEC and FDIC to ensure the completeness and accuracy of our assessment.
Our approach is also based on the following:
• the knowledge level and attitude of management and personnel;
• management’s responsiveness to emerging issues and past or self-identified compliance deficiencies;
• compliance organizational structure such as reporting relationships and recent experiences with staff turnover;
• management information systems;
• policies and procedures;
• training; and
• monitoring and audit programs.
• Regulation BB: Community Reinvestment Act
The following additional regulations, rules, policies and statutes can also be addressed during the assessment if management deems them necessary:
• Regulation G: Disclosure and Reporting of CRA-related agreements
• Regulation H: Section 109 of the Riegle-Neal Interstate Banking and Branching
• Efficiency Act
• Regulation P: Privacy of Consumer Financial Information
• Federal Trade Commission Act – Section 5
• Children’s Online Privacy Protection Act
• Right to Financial Privacy Act
• Service members Civil Relief Act
• Warner Military Lending Act (Talent Amendment)
• Dodd-Frank Act
The Capsa Group utilizes on the requirements outlined by the Financial Crimes Enforcement Network of the U.S. Treasury (Known as FINEN). Federal Financial Institutions Examination Council's (“FFIEC”) BSA/AML Examination Manual as well as the most up-to-date guidance applicable to consumer protection laws and regulations related to the financial institution’s products and services. However, The Capsa Group is in the unique position of having team members who have had active roles in bank operations, compliance, and working with information technology personnel in recent years as well as having a thorough understanding of procedures, protocols, and information systems similar to yours. This knowledge is a catalyst in facilitating the compliance assessment process and reducing the number of hours that otherwise might be required to gain the detailed understanding of the compliance risks and bank operations procedures, which includes both approval versus denial matters and pricing.
Our approach to fair lending review will include examination of your institution’s training policies and procedures for regulatory issues, as well as file reviews for actual compliance. The training should be consistent with Board of Directors’ policies as implemented by management. Where possible, the file reviews for fair lending will be concurrent with compliance reviews.
The Gramm-Leach-Bliley Act (GLBA) of 1999 requires financial institutions to create, document, and audit security procedures to protect the nonpublic personal information of their clients, including precautions to prevent unauthorized electronic access.
• Regulation C and Z: Home Mortgage Disclosure/Truth in Lending
• Regulation H: Flood Insurance
• Fair Credit Reporting
• Fair Debt Collection Practices Act
• Homeowners Protection Act
• Homeownership Counseling
• Real Estate Settlement Procedures Act
• Flood Disaster Protection Act
• Loans to Executive Officer, Directors, and Principal Shareholders – Regulation O
• Regulation E: Electronic Fund Transfers (including overdraft rules)
• Regulations Q and D: Interest on Demand Deposits/Reserve Requirements, NOW Eligibility and Money Market Account Procedures
• Regulation CC: Availability of Funds and Collection of Checks
• Regulation DD: Truth in Savings
Capsa partners with our clients to manage technology risks associated with safeguarding data and information system resources. Capsa’s technology assurance services are designed to meet the plethora of compliance requirements facing financial institutions as well as any business with IT security risks. Our approach provides a stream-lined and cost effective solution to your IT audit needs.
We offer the following comprehensive information technology solutions:
• Information Technology Audit, Compliance, and Regulatory Services;
• Service Organization Control (“SOC”) 1 and 2 Audits; and
• Network Vulnerability Assessment and Penetration Testing