Will the Focus of Enforcement Change?

During the past several years, as the health of the banking industry generally has been good and the industry experienced a record period without a failure, the focus of the most widely publicized enforcement actions has been on Bank Secrecy Act and other compliance issues. In recent years, as the vast majority of banks were well-capitalized and profitable, the spotlight placed on consumer protection and compliance activities by the regulators was intense. However the industry and the financial markets are changing, and the number of enforcement actions is likely to increase. One of the positive results of the emphasis on compliance with consumer protection laws and Bank Secrecy Act requirements is that many insured institutions have implemented more well-defined compliance management programs. Community banks can learn from the lessons of the past two decades to keep a focus on compliance and anti-money laundering while paying attention to the financial operations of the bank in the current economic environment.