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Crafting an Enterprise Risk Management Program for MSBs – Part 2

10-09-24

Crafting an Enterprise Risk Management Program for MSBs – Part 2

As MSBs and Fintechs get larger and more complex, they may find examiners, auditors, and bank partners asking about their ERM.  In Part 2 of this article, we address the role data, analytics, and quality reporting procedures play in terms of providing management with decision-supporting information across the two important areas of an ERM Program – specifically, the Risk Assessment and Monitoring.  

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Crafting an Enterprise Risk Management Program for MSBs

09-19-24

Crafting an Enterprise Risk Management Program for MSBs

As Money Services Businesses grow, implementing Enterprise Risk Management becomes crucial. This article guides Compliance Officers in starting development of an ERM Program, looking beyond financial crimes risks and focusing on comprehensive risk identification and risk appetite.

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A Very Active CFPB - Part 1: Paycheck Advance Loans

08-19-24

A Very Active CFPB - Part 1: Paycheck Advance Loans

The CFPB has proposed an interpretive rule classifying paycheck advance loans under TILA, which could require APR disclosures for these rapidly growing products. Financial institutions are reassessing their offerings amid increasing scrutiny and potential reputation risks. While supporters argue it protects consumers, opponents claim it's unnecessary for advances on earned wages.

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