Director’s Responsibility for Compliance

Directors are responsible for providing their banks with a compliance management program that includes preventive, detective and corrective measures to insure compliance with banking laws and regulations.

Preventive measures are those that help prevent violations from occurring, which can include:

  • policies,
  • procedures,
  • internal controls, and
  • training.

Detective measures are those that identify or notify of undesirable events, such as deliberate or accidental errors or violations of law. Detective measures can include:

  • audits or other operational reviews,
  • active board and management oversight, and
  • risk monitoring and management information systems (MIS).

Corrective measures prescribe actions to take in the event errors or violations are found. They can address specific issues or the conditions that allowed the issue to occur. Corrective measures can include:

  • corrective action plans that assign responsibility for correction to a specific individual or group, with a specific due date for completion, and a requirement for status reports showing progress of corrective action;
  • quality assurance or control processes to identify and correct conditions that led to the error or violation; and
  • information systems that keep problems in the forefront until they are corrected.