In addition
to full-scale risk management, internal audit, or CSA implementations,
VA is often used for both full-scale and specifically focused compliance
assessments. A compliance department could implement VA to provide an
assessment methodology for all areas in which the organization is required
to comply, whether for compliance with laws and regulations, or internal
or industry best practices. Taking practical advantage of the proliferation
of available industry and regulatory materials can present management
with a logistical nightmare. VA provides a simple, practical mechanism
for formatting these materials into smart electronic questionnaires
ready for immediate use as templates within VA. Some specifically focused
compliance assessments in which VA has proven its effectiveness include
the following:
- FDICIA
Control Assessments for U.S. banking companies
- U.K.
financial institution compliance with the requirements of the FSA
Handbook
- Canadian
financial institution compliance with OSFI standards and practices
- Compliance
with corporate governance and control frameworks such as COSO in the
U.S., the Combined Code in the U.K., and CoCo in Canada
- Compliance
with risk management standards as issued in AS/NZS4360-1999
-
Compliance with sound information technology practices as issued by
CoBit
The
uses of VA as a compliance assessment tool are unlimited. Any standard,
practices guide, law, or regulation can be formatted for use in performing
assessments with VA. Kilclare has taken some of this publicly available
material and formatted it for assessment use in VA.
These templates can be a good starting point from which an organization
can build its compliance assessments. Many of Kilclare's U.S. bank clients
use VA to perform their FDICIA control assessments. Beginning with either
Kilclare templates or those prepared by others, they customize the provided
content to best suit their organization and then complete the assessment
by providing evaluations for the listed controls. Once completed throughout
the organization, VA provides the necessary reports to the attesting
auditors.
Click on the CONTENT
link at the left to review the template materials available from Kilclare.
Compliance Example:
One
Kilclare client, a securities firm with offices nationwide, accomplishes
its branch compliance assessments for U.S. securities laws using VA.
Having translated its branch compliance program into VA knowledgebases,
local branches now perform assessments covering:
- asset
manager selection due diligence
- client
contracting, account setup, and billing
- client
correspondence and complaint handling
- custody
- advising
and The Uniform Code of Fiduciary Conduct
- recordkeeping
- sales
literature and performance advertising
- suitability
- trading
Branch assessments
are scheduled and monitored centrally by the compliance group. Remedial
action plans are entered directly into VA and also monitored for implementation.
This user cites a significant reduction in regulatory comments since
having implemented VA to assist in the branch compliance program.
