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REGULATORY

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COMPREHENSIVE, TAILORED

SERVICES

Proactive Regulatory Guidance

Today’s complex regulatory environment is presenting many diffi cult challenges to fi nancial institutions of all sizes. Many are re-evaluating their regulatory management practices, and in most cases have discovered that they now require enhanced compliance expertise, additional resources or both. Accume Partners is prepared to help. We work with our compliance clients to prevent potential problems, correct existing issues and proactively provide guidance to effi ciently stay ahead of a rapidly changing regulatory landscape.

Experienced Professionals

Accume Partners’ compliance team is comprised of former compliance offi cers, regulatory examiners and specialists. Each of our professionals is highly experienced and continuously focused on emerging regulatory issues. Our expertise allows us to provide a full range of practical, cost-effective solutions for fi nancial institutions of any size and complexity.

Accume Partners can help your organization to meet any compliance challenge through our comprehensive array of services, each tailored to meet your specifi c needs.

Services Include:

• Compliance Administration Program (Outsource) • Compliance Consulting

• Compliance Audit (regulation specifi c) • BSA/AML Audit and Consulting Services • CRA/HMDA/Fair Lending Services

• Dodd-Frank and CFPB Implementation and Readiness

• Compliance Training

Our comprehensive experience includes all areas of regulatory compliance, such as:

• Lending Compliance

• Deposit Compliance

• Websites/Advertising/Social Media

• Unfair, Deceptive or Abusive Acts or Practices (UDAAP)

• Red Flags and Identity Theft • Servicemembers Civil Relief Act • Electronic Funds Transfer Act

- Risk Assessments - Enforcement Action Assistance/Remediation - Monitoring Reviews

- Due Diligence - Policy & Procedure

Development - Exam Assistance

- Residential Mortgage - Consumer

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Compliance Co-Sourcing and Support

Whether you need to address a shortage of staff or require specialized compliance expertise, we are prepared to assist. Accume Partners’ seasoned professionals are able to provide fi nancial institutions with the regulatory resources they require, on-demand, without the need to hire full-time staff. Having your own specialists on hand to meet every compliance need at all times is not practical or feasible for today’s fi nancial institutions, especially given the complexities of this regulatory environment. The breadth and depth of our expertise enables us to serve as an invaluable compliance asset.

Regulatory Compliance Audit

Accume Partners’ specialists can assist your institution with planning, developing and/or executing your compliance-related audits. We can provide a full outsource solution or provide a support resource for your existing audit function. Our compliance audit services are customized to meet each of our clients’ unique needs.

Compliance Consulting

Accume Partners offers a full range of consulting services that are designed to help you cope with today’s multifaceted regulatory challenges. We can support your institution’s entire compliance program or simply provide guidance on specifi c areas, such as implementing new and amended regulations. Whatever your need, size or complexity, we will develop and execute practical solutions that put your institution on a solid compliance foundation.

ADDRESSING TODAY’S

COMPLIANCE NEEDS

Compliance Administration Program

Many institutions outsource the administration of their compliance function due to the need for enhanced expertise, a desire to focus greater attention on core competencies, and/or the need to control or reduce costs. Our regulatory compliance professionals will maintain an ongoing comprehensive compliance program for your institution with our tailored solution that can include:

• A compliance risk assessment to determine your institution’s specifi c compliance needs

• Development and execution of a risk-based monitoring program

• Ongoing compliance program support that can include:

- Compliance committee participation - Compliance “hotline” for answering

compliance questions, reviewing ads and disclosures and evaluating new products - Examiner and Audit Committee meeting

attendance and support

• Proactive regulatory updates and assistance with the implementation of new/amended laws and regulations

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SPECIALIZED EXPERTISE

Below is a sampling of our services that are specifi cally designed to address the evolving requirements of today’s regulatory environment.

Pre-Regulatory Examination Evaluation: An evaluation of your institution’s overall compliance function compared to regulatory requirements is necessary to validate that your institution is appropriately identifying, monitoring and mitigating compliance risks. We assist institutions with their preparation for regulatory examinations by

identifying potential regulatory gaps and providing specifi c actionable recommendations. Our

vantage point of assisting institutions of varying sizes and complexities allows us to provide meaningful and valuable best practices enhancements. We can also confi rm your institution’s ability to comply with new regulations, such as Dodd-Frank and changes to existing regulations.

Dodd-Frank and CFPB Implementation and Readiness: It is imperative for your institution to stay up-to-date on pronouncements prior to their effective dates so that the necessary changes can be effectively implemented in a timely manner. We will keep you informed of the information you need to know prior to new regulations going into effect and will assist you in developing the required structure, processes, procedures and training to be compliant. As a fi rm, Accume Partners has gained valuable experience by serving hundreds of clients, and that knowledge is instrumental to understanding what is required by the regulators and how best to move forward.

Compliance Risk Assessment: The supervisory agencies are turning toward risk assessments as a key element of the bank examination since the risk assessment is key to identifying risk factors across all lines of business. The process of identifying and rating risk is challenging for many institutions; however, it is essential to the development of an effective compliance program.

Development and Testing of Policies, Procedures and Processes: Our services include the

design of enterprise-wide compliance risk management frameworks and the development of written compliance programs consistent with management objectives and regulatory requirements. We also perform transaction testing to determine an institution’s adherence with applicable safety & soundness and consumer protection laws, regulations and supervisory guidance.

Enforcement Action Remediation: Accume Partners will assist your institution with remediating compliance program and performance issues arising from regulatory examinations. Through our specialized expertise, we will develop the necessary remedial action plans and perform transaction testing to ensure the correction of any defi ciencies.

Compliance Training: Training is an essential component of a successful regulatory compliance program. Employees and board members must be kept current on hot topics and changes in regulations. In addition, regulations such as BSA require annual training. Accume Partners offers comprehensive compliance training on a variety of regulatory topics to ensure your institution is up-to-date and knowledgeable. You can keep your staff informed of regulatory and in-house requirements through training that will be tailored to your institution.

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BSA/AML COMPLIANCE

The Bank Secrecy Act (BSA) is one of the most aggressively enforced banking regulations facing today’s fi nancial institutions. BSA/AML, USA PATRIOT ACT and OFAC compliance violations can expose an institution to serious regulatory and reputational risks. Few institutions maintain the necessary in-house expertise to meet today’s demands. Our BSA/AML specialists are prepared to provide institutions of all sizes and complexities with the assistance necessary to develop, implement and maintain an effective program. Specifi cally, we can provide your institution with:

BSA/AML Compliance Audit/Independent Testing • Continuous Audit Model

• Comprehensive Scope • Enterprise-wide Approach

Advisory Services

• BSA/AML and OFAC Compliance Program Design and Implementation

• BSA/AML and OFAC Compliance Training - Board of Directors

- Management - Staff

• BSA/AML and OFAC Risk Assessment - Conduct annual risk assessment - Evaluate existing risk assessment

• Enforcement Action Assistance/Remediation • BSA/AML and OFAC Policies and Procedures

- Develop

- Update for new requirements

• BSA/AML and OFAC Monitoring

- Review applicable requirements across all business lines

• AML Software

- Assist in vendor discussions and in selecting AML software

- Perform post-implementation review of AML software

- Assist in customizing and parameterization of AML software to suit your needs

- Assess existing parameters • AML System Validation

- Conduct validation required for new AML systems and for changes to existing AML systems

- Verify data integrity • Look-back Reviews

- Identify potentially suspicious activity for SAR fi ling purposes

- File suspicious activity reports as required - Quality Assurance reviews to ensure SARs are

thorough and suffi cient for the applicable regulatory authorities

- Conduct follow-up for SARs

- Maintain required documentation of SAR investigations

- Assess adequacy of “Know Your Customer” and “Customer Identifi cation Program”

Our enterprise-wide advisory services provide the assurance you seek by:

• Identifying gaps in your BSA/AML compliance program

• Addressing key strategic issues

• Maintaining an effective testing and reporting strategy

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For more information about our regulatory

compliance services, please contact:

Please visit us at

ACCUMEPARTNERS.COM

Steven Peck

Managing Director, Compliance 610.803.1617 speck@accumepartners.com James Nemecek Director 215.565.6576 jnemecek@accumepartners.com David Smith Director 570.606.7423 dlsmith@accumepartners.com

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