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Mortgage Servicing Compliance: Emerging Risks and Governance Priorities
Mortgage servicing compliance risk rarely resides in a single policy or regulatory requirement. It often emerges where processes, data, technology, employees, and third parties intersect, particularly in loss mitigation, borrower communications, error resolution, servicing transfers, and other activ...
Rob Walley
5 hours ago8 min read


AI Governance Policy: What Financial Institutions Should Include
An AI governance policy should do more than establish broad principles for responsible technology use. It should define who is accountable, which AI activities are subject to oversight, how risks are assessed and classified, what controls apply throughout the AI lifecycle, and how significant issues...
Rob Walley
5 hours ago9 min read


Third-Party Risk Management: Building a Risk-Based Vendor Inventory and Tiering Framework
Third-party relationships have become integral to how financial institutions deliver products, operate technology, serve customers, and manage critical business processes. As the number and complexity of these relationships grow, maintaining a list of vendors is no longer sufficient. Institutions ne...
Rob Walley
2 days ago10 min read


Consumer Lending Compliance Risk Assessment: A Practical Framework for Financial Institutions
A consumer lending compliance risk assessment should help management understand where the institution is most exposed to consumer compliance risk, how effectively existing controls address those risks, and where additional attention may be warranted. The assessment should reflect the institution's p...
Rob Walley
3 days ago7 min read


BSA/AML Governance: Building Effective Board and Management Oversight
Effective BSA/AML governance requires more than approving policies and receiving periodic reports. Boards and senior management need enough information, authority, and organizational visibility to understand the institution's financial crime risk profile, assess whether the program is operating as i...
Rob Walley
6 days ago8 min read


AI Vendor Due Diligence: 10 Questions Before Your Institution Signs a Contract
Engaging with third-party AI vendors introduces opportunities for operational efficiency, improved decision-making, and enhanced customer experiences. However, this engagement also brings complex risks that extend beyond the scope of traditional Third-Party Risk Management (TPRM). Standard TPRM fram...
Rob Walley
Aug 278 min read


OCC Examination Readiness: What Risk and Compliance Leaders Should Prepare
Table of Contents
Preparing for an OCC Examination: A Framework for Risk and Compliance Leaders
Foundations of Examination Readiness: Governance, Documentation, and Risk Assessment
Model Risk Governance Under the 2026 Interagency Guidance
Aligning Operations with Regulatory Expectations
## Prep...
Rob Walley
Aug 268 min read


Auto Finance Compliance: Managing Dealer and Third-Party Risk
Auto finance lenders operate through an extended network of dealers, technology providers, data vendors, and other third parties that can materially influence the consumer lending experience. Dealer pricing practices, add-on products, financing processes, vendor models, and data used in credit decis...
Rob Walley
Aug 259 min read


Managing Model Risk Across the AI Lifecycle
Artificial intelligence is expanding the use of models and automated decisioning across financial services, but managing the associated risk requires more than validating a model before it enters production. Model risk can arise from flawed assumptions, data limitations, inappropriate use, performan...
Rob Walley
Aug 248 min read


Digital Asset Risk Management: Integrating Crypto Activities Into Enterprise Risk
Digital asset activities can introduce new technologies and business models, but they do not eliminate the fundamental risk management disciplines financial institutions already use to govern complex products and activities. As institutions explore cryptocurrency, tokenization, stablecoins, custody,...
Rob Walley
Aug 218 min read


AI Implementation in Financial Services: From Pilot to Production
Financial institutions have moved quickly from experimenting with artificial intelligence to identifying opportunities for broader deployment. The challenge is no longer simply proving that an AI use case can work. It is determining how to move promising initiatives from isolated pilots into product...
Rob Walley
Aug 207 min read


Regulatory Exam Readiness: Turning Past Findings Into Sustainable Remediation
Financial institutions often treat regulatory examinations as cyclical emergencies, triggering resource-intensive “fire drills” to assemble documentation and prepare for supervisory review. This reactive posture, however, frequently fails to address the underlying issues that attract regulatory scru...
Rob Walley
Aug 197 min read


Financial Crime Risk Assessments: Five Mistakes That Weaken the Framework
A financial crime risk assessment should do more than document an institution's exposure to money laundering and other illicit finance risks. When designed effectively, it can help management understand how the institution's customers, products, services, geographies, delivery channels, and other ac...
Rob Walley
Aug 187 min read


AI Governance Maturity: A Roadmap for Financial Institutions
Financial institutions are moving from AI experimentation toward broader deployment across business, risk, compliance, and operational functions. As AI use expands, the governance challenge is not simply to create a new set of controls. It is to establish a practical framework for identifying AI use...
Rob Walley
Aug 187 min read


Auto Finance Compliance: Emerging Regulatory Risks and Governance
Auto finance compliance continues to evolve as lenders adapt to changes in products, technology, consumer expectations, and the legal and regulatory environment. For senior leadership, the challenge is to maintain governance and risk management practices that address consumer protection, fair lendin...
Rob Walley
Aug 186 min read


Preparing for Your Next Banking Regulatory Exam: 10 Common Compliance Gaps
Effective regulatory exam readiness is not achieved through a last-minute, document-collection exercise. Instead, it is the natural outcome of a well-designed and consistently maintained compliance and risk management framework. An institution that embeds strong governance into its daily operations...
Rob Walley
Aug 187 min read


BSA/AML Program Effectiveness: How Financial Institutions Should Test Their Programs
Table of Contents
Introduction: What Does “Program Effectiveness” Mean?
The Evolving Focus on AML/CFT Program Effectiveness
What Should Be Tested?
Independent Testing, Validation, and Internal Audit
## Introduction: What Does “Program Effectiveness” Mean?
BSA/AML program effectiveness is not m...
Rob Walley
Aug 187 min read


Consumer Lending Compliance: Preparing for Increased Regulatory Scrutiny
Table of Contents
The Modern Regulatory Landscape for Consumer Lending Compliance
Operationalizing Fair Lending and UDAAP Oversight
Governance Frameworks for AI and Automated Credit Models
Regulatory Examination Readiness: A Proactive Strategy
## The Modern Regulatory Landscape for Consumer Len...
Rob Walley
Aug 177 min read


Operational Risk Management in an AI-Enabled Financial Institution
Table of Contents
The Evolution of Operational Risk: Beyond Process Failures to Strategic Resilience
Architecting an Integrated Operational Risk Framework
Operationalizing Risk: From Self-Assessment to Strategic Transparency
Transitioning ORM from a Cost Center to an Innovation Enabler
## The E...
Rob Walley
Aug 177 min read


What Should a Board Know About AI Risk? A Practical Governance Guide
Table of Contents
What the Board Should Understand About AI Risk
Governance and Accountability
SR 26-2 and the Board's Oversight Role
The Questions Boards Should Ask Management
## What the Board Should Understand About AI Risk
Artificial intelligence is moving rapidly from experimentation into...
Rob Walley
Aug 177 min read
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