• Tax allocation agreement revision required by Oct. 31

    In June 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued an addendum to the “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure”.
  • Risk governance: What to expect

    For years, risk governance meant risk management, with a relatively narrow focus on specific areas: loans, legal, and possibly IT. Then, everything went sideways in 2008-2009, and regulators saw the need for a more proactive, comprehensive risk governance strategy. Within the past five years, new rules and guidelines have begun changing the flaws regulators could see boards of directors were not engaged at the right level; board members and executives weren’t getting the right information to make informed decisions; and management didn’t have tools in place to facilitate a timely and comprehensive analysis of overall risk.
  • New recommendations for bank audits

    External bank auditors have new guidance from the Basel Committee on Banking Supervision as of March 31, and banks should understand the updated guidelines before their next audit. The new guidelines, 46 pages in all, replace The Relationship Between Banking Supervisors and Banks' External Auditors, published in 2002, and External Audit Quality and Banking Supervision, from 2008.
  • Distributed Denial of Service (DDoS) attacks on public facing websites

    On April 2, 2014 the Federal Financial Institutions Examination Council (FFIEC) released a statement related to Distributed Denial of Service (DDoS) attacks on public facing websites. The statement highlights that DDoS attacks have increased since late 2012 and, in many cases, have been executed by politically motivated groups.