Federal Financial Institutions Examination Council

If you're a state bank that's regulated by the Fed, then you're gonna have a different rule than if you're a state bank that is regulated at the federal level by the FDIC.

This seemed to me to call out for FFIEC action, but they each went their own way.

Depending on who you're regulated by, you should look at the proposal.

But in addition, the thing to understand is that the effective date for the Genius Act is mid-January of next year, and we're running pretty close to the end of when you can get a final rule.

Banks are required by law to prepare these call reports on a regular basis for the regulators and, and for the public.

So I said, again, you can go to the FDIC or the FFIEC website to find out, uh, more information to, to upload or download, excuse me, content there.

For publicly held bank holding companies, they will file with the SEC.

They'll file their financial statements typically on Form 10-K, then quarterly on 10-Q.

So like in construction, JCT, NEC contract standards.

Whereas in finance, we do work with FCA, FFIEC compliance in the US, and we built capability around that.

Every business in finance pretty much has to think about AML, KYC, and other elements like that.

So those patterns are quite similar.

Honestly, we're, we're looking at the documentation.

So the biggest one we always talk about FFIEC, which is US regulations on that.

That's a very descriptive, conceptual regulation of here's, here's what you should, should be having.

It's not saying you need to have this switch or anything like that.

[laughs]

Yeah.

Is that, is that correct, or should you be moving out more Midwest? But FFIEC doesn't, it's not descriptive enough on that.

It's just saying you should have those redundancies.

which my guess is probably talks about material financial risk there.

And then also material financial risk, if I remember right, I'm almost certain I am, the proposed CAMELS rule that has been put up by the FFIEC for all banking regulators, including NCUA, relies heavily on the material financial risk.

So this rewrite of this letter, I think, also positions them so they don't have to rewrite it when that happens.

New Campbell's rule is finalized by the FFIEC after they take their comment period.

Does that make sense?

Yep.

What's the problem with reporting it? It's just the next step.

You just All the software that's out there today, including the free FFIEC software, you just click a button to upload the data that you've been collecting to monitor your own CRA performance.

So to me, it more or less encourages irresponsibility on the part of banks to ignore their compliance with the regulation until an exam comes up.

And then it's a keystone cop's drill to try to collect the data and monitor I don't know how any responsible CRA officer or compliance officer would not be collecting the information.

When there was a relatively small number, so I mentioned the core providers, but you also had maybe some of the big issuer processors like Atesis or First Data or whoever.

There was a relatively small scope of large providers that could be supervised either directly under the auspices of the FFIEC or sort of indirectly by proxy through the banks that are using those service providers.

According to third-party risk management guidance.

TPRM, vendor due diligence and whatnot.