When "Should" Becomes "Shall:" Rethinking Compliance Management for Banks
In the world of banking supervision and regulation, there is a familiar, longstanding cadence to the issuance of new guidance: regulators issue new guidance; banks parse and interpret it, set a strategy for compliance, begin operationalizing it, and press forward with the knowledge that most new guidance is simply a set of expectations rather than hard-and-fast requirements.
Over the past few years, a new wrinkle has emerged, hinging on one small word: "should." Historically, regulatory guidance was delivered in the context of "should." As in, banks should do x, y, or z. Recent developments make it clear "should" is increasingly being interpreted as "shall," at least for larger organizations.
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