Challenge
A U.S. bank holding company need to comply with the Federal Reserve Bank’s Comprehensive Capital Analysis and Review (CCAR) process and the Dodd-Frank Act’s Annual Stress Test (DFAST) for this client was unmanageable due to its numerous and individually managed risk management offices across the enterprise.
Solution
Mobilized a team to rapidly implement a full compliant CCAR/DFAST stress test program by:
- Forming a management office (PMO) that involved risk groups across the lines of businesses and enterprise
- Defining communication methods and cadences within teams, across teams, lines of businesses, and to executive management
- Training team members on compliance requirements and how risk management concepts, methodologies, and internal controls testing enable regulatory compliance
- Defining processes for documenting Risk and Control Self-Assessments (and creating templates for risk analysts to archive critical controls and self-assessments
- Creating content management governance to store project artifacts and results
- Implementing and deploying change control methods for managing documentation updates
Outcome
Our client was able to immediately adhere to federally mandated regulations and plan for long-term success by:
- Instituting a consistent approach, toolset, and guidance across the enterprise and within lines of businesses (LOB)
- Educating each LOB to understand compliance expectations and ensure full compliance with CCAR and DFAST on a semi-annual and annual basis
- Enabling ongoing compliance adoption and sustainability through clear and consistent organizational structure, processes, and tools
Published March 17, 2020