RADD LLC

PRESS RELEASE: Brian Montes to Take Reins as CEO of RADD LLC Rancho Santa Margarita, CA, September 19, 2024 – RADD LLC, is a boutique, compliance and internal audit consulting firm, focusing on Advisory as a Service®, has named Brian Montes as CEO, while Founder Radhika Lipton is stepping into an advisory role at the firm. Montes has been a consultant with RADD since 2019 and running operations and people management full-time for the last 18 months. “I fulfilled a lifelong dream of being an entrepreneur and starting up RADD in 2017 to help financial institutions with their compliance and internal audit needs,” said Lipton. “I am excited about the future of RADD knowing that it is in good hands with Brian Montes.” Lipton will move into an advisory capacity for RADD as she assumes the role of Chief Risk Officer at PCBB. “I look forward to building upon the solid foundation that was established under Radhika’s leadership. The company is well-positioned, and I look forward to continuing to operate it with a focus on a frictionless client experience coupled with ensuring RADD continues to be an employer of choice for our existing and future team members,” said Montes. Montes has achieved significant success across multiple areas, including sales, operations, leadership and strategic partnerships. He began his career in sales with a major global organization, quickly transitioning into managing complex partnerships across international markets. He later spearheaded the growth of a high-growth start-up, expanding its workforce and increasing revenues tenfold in just four years. Leveraging his experience, he launched a consulting firm focused on scaling businesses, helping them achieve sustainable growth. Montes also holds a Juris Doctorate, which broadens his ability to navigate highly regulated and complex industries. Montes brings all of his business experience and success to the RADD organization and has been contributing to the RADD team since 2019. RADD stands as the leading provider of Compliance and Internal Audit Services, thoughtfully designed to put their clients one step ahead of the competition. Through close collaboration with your dedicated compliance and audit departments, they offer a specialized solution that empowers their clients to seamlessly achieve and uphold rigorous regulatory mandates, ensuring not only adherence to regulations but also the cultivation of a robust operational framework. For more information about RADD, visit raddllc.com. Advisory as a Service® is a registered trademark of Radhika Lipton.  Contact:  Brian Montes, CEO RADD LLC 1-833-RADD-LLC brian@raddllc.com

On October 22, the Consumer Financial Protection Bureau (CFPB) issued a final rule for the much-debated Personal Financial Data Rights regulation, popularly known as "1033" and "CFPB open banking rule". The regulation, which has been in the works for years, requires significant changes to data access and sharing protocols. Here’s what compliance officers need to be prepared for: Key Requirements: The rule mandates that financial institutions set up secure digital interfaces to share consumer financial data upon request. This includes transaction history, account balances, payment details, and more. Compliance Timeline: The CFPB has outlined a phased compliance schedule. Institutions with $250 billion or more in assets need to meet the standards by April 2026. Those with smaller asset sizes have additional time, with the deadline extending to 2030 for institutions holding less than $1.5 billion. Security and Accuracy Focus: The rule emphasizes the importance of data security and accuracy. Financial institutions will need to establish secure consumer and developer interfaces, adhering to stringent performance standards. Exemptions to Consider: Certain types of data are excluded from sharing requirements, including sensitive commercial information, data related to fraud prevention, and information that is not retrievable in the ordinary course of business. Preparing for Audits: The CFPB’s new rule will require meticulous documentation and record retention. Compliance officers should ensure that their institutions have clear policies and procedures in place, especially around maintaining records of third-party authorizations, security protocols, and the rationale behind any denied data access requests. Differentiated Standards for Banks and Non-Banks: A significant aspect of the rule is the distinction between banks and non-banks in terms of data security. Banks are required to comply with Section 501 of the Gramm-Leach-Bliley Act (GLBA) standards, while non-bank companies involved in data access must adhere to the Federal Trade Commission’s (FTC's) Standards for Safeguarding Customer Information. Implications for Screen Scraping: The final rule introduces measures that will significantly restrict the practice of screen scraping. Data providers are now required to establish secure "developer interfaces" (such as APIs), preventing third parties from using consumer credentials to access banking data. Handling Data Aggregators: Large data aggregators, acting as intermediaries between data providers and third parties, will be subject to CFPB supervisory examinations. 📌 Stay ahead of the evolving compliance landscape. RADD's team of experts is here to guide you through the complexities of the 1033 rule. Learn more about our services: https://lnkd.in/eQvF5sj6 #RADDLLC #OpenBanking #CFPB #FinancialData #Compliance #DataSecurity #BSAAML #BankingRegulations

Key Compliance Insights from the OCC's October Enforcement Actions The OCC recently announced its October enforcement actions, impacting five banks, including a major national institution facing a Cease-and-Desist Order and a $450 million Civil Money Penalty. These actions offer critical lessons for banks of all sizes. Here are five key trends that institutions should pay attention to in order to strengthen compliance and reduce regulatory risks: 1. Focus on BSA/AML Compliance The OCC's emphasis on the Bank Secrecy Act and Anti-Money Laundering (BSA/AML) highlights the need for strong compliance programs. Actions against two banks illustrate the importance of robust transaction monitoring, timely reporting, and thorough customer due diligence. 2. Emphasis on Governance and Oversight All five actions required the creation of a Compliance Committee to ensure adherence to the orders. This trend underscores the expectation that boards actively engage in compliance matters with clear oversight. 3. Strategic and Capital Planning The OCC has called for improved strategic and capital planning, even among smaller regional banks. Institutions must adapt their plans to address long-term sustainability, risk management, and capital adequacy. 4. Risk Management Enhancements The enforcement actions underline the need for a comprehensive approach to risk management—covering everything from credit and liquidity risk to third-party relationships. 5. Training and Staffing Qualified personnel and continuous training remain essential, especially in BSA/AML compliance. The OCC's focus on maintaining adequate staffing and training programs is a reminder of the role that human capital plays in a successful compliance strategy. Is your institution prepared to meet evolving regulatory expectations? RADD’s compliance experts can help you build a robust compliance framework tailored to your needs. Schedule a strategy call with us today: https://lnkd.in/eQvF5sj6 #RADDLLC #Compliance #BSAAML #RiskManagement #FinancialRegulation #BankingCompliance #OCC #Governance

The Office of the Comptroller of the Currency's latest enforcement action against Wells Fargo shines a spotlight on a critical truth in banking: BSA/AML compliance is an ongoing journey, not a destination. Wells Fargo, a $1.74T asset institution, received a 26-page consent order revealing major shortcomings in its BSA/AML internal controls, including deficiencies in areas such as suspicious activity reporting, customer due diligence, and beneficial ownership. Here are 3 key takeaways from the order: 1. Comprehensive Risk Assessment Wells Fargo is required to conduct thorough risk assessments across all business lines, products, and geographies, with active board oversight. 2. Data Integrity and Systems Evaluation The bank must overhaul its data infrastructure with a robust Data Integrity Program, ensuring accuracy across its operations. 3. Enhanced Audit Functions A major focus on improving audit functions, with consistent test scripts across BSA/AML and OFAC Sanctions audits. This enforcement action is reminiscent of the Federal Reserve Board's recent C&D order on a $1.2B bank in Texas, which raises some important questions for all FIs: - Are our suspicious activity reporting mechanisms truly effective? - How robust is our customer due diligence process? - Is there accountability and oversight within our compliance structure? Regulatory scrutiny is intense, and BSA/AML compliance must be continuously evaluated, adapted, and improved. If you believe it's time for a review of your institution's BSA/AML program, RADD’s CAMS-certified specialists are ready to help you navigate compliance complexities. 👉 Learn more: https://lnkd.in/dZTabwkP #RADDLLC #BSACompliance #AMLCompliance #WellsFargo #RiskManagement #FinancialServices #InternalControls #BankingRegulations #ComplianceAudit

The Financial Crimes Enforcement Network (FinCEN) has introduced two important FAQs to its Beneficial Ownership Information (BOI) reporting guidance, mandatory as of January 1, 2024. Here are the key updates: 1. FAQ C.15 – Clarifies that anyone authorized by a company can file its BOI report, even if the company dissolves before the reporting deadline. This affects companies created or registered in 2024. 2. FAQ C.16 – Explains that foreign companies who fully withdrew their U.S. registration before January 1, 2024, are not required to report. Any registration post-January 1, however brief, mandates reporting. Need help navigating BOI reporting requirements? RADD LLC offers fractional compliance support, with part-time or temporary compliance officers available when you need them. Let us simplify your reporting process. 👉 Get Your Compliance and BOI Reporting Support: https://lnkd.in/eWg5qytt #RADDLLC #BOIReporting #FinCEN #Compliance #BeneficialOwnership #RiskManagement

Regulatory changes aren’t just administrative updates for financial institutions. They represent shifts that can significantly affect your risk profile, operations, and strategy. These changes, whether triggered by new rules or internal business evolution, are risks in themselves. So, what does it mean to manage regulatory change through internal audits? We've covered this topic in detail on our blog: Read more: https://lnkd.in/eDsvqS3e. For example, with the CFPB’s new rule on Small Business Lending Data Collection under the Dodd-Frank Act, financial institutions must now adjust audit plans and create new processes for documenting and reporting. At RADD LLC, we enhance compliance policies and procedures to ensure your internal audits cover every necessary regulation. Ready to align your institution’s audits with regulatory updates? Book your free strategy call today: Schedule here: https://lnkd.in/eQvF5sj6 #RADDLLC #RegulatoryCompliance #InternalAudit #RiskManagement #CFPB #DoddFrank #SmallBusinessLending #ComplianceStrategy

Acting Comptroller Hsu's recent remarks in Germany shed light on the evolving expectations for US bank supervision and outlined ways to make oversight more effective. Here are three key takeaways for compliance professionals: 1. Proactive Risk Assessment: Hsu stressed the value of "risk-based supervision" over "check-the-box" approaches. Financial institutions should prioritize adaptive strategies to address evolving threats, rather than rigidly following compliance checklists. 2. Learning from History: By referencing events from the 2008 financial crisis to recent crypto platform failures, Hsu emphasized the need for insights from past crises to inform future risk management. This historical context provides valuable lessons for anticipating and mitigating banking vulnerabilities. 3. Collaboration with Supervisors: Rather than seeing interactions with supervisors as just a compliance duty, banks should consider these relationships as strategic partnerships. Engaging in meaningful dialogue about regulatory expectations and emerging risks can help address potential compliance issues before they escalate. Strengthen Your Compliance Approach Today! RADD LLC helps financial institutions stay ahead with proactive risk assessments, historical analysis, and strategic regulatory partnerships. Learn more: https://lnkd.in/eQvF5sj6 #RADDLLC #Compliance #BankSupervision #RiskManagement #FinancialServices #Regulation #USBanking #RiskAssessment #FinancialCompliance

The CFPB's latest Supervisory Highlights (April-December 2023) revealed key violations and consumer harm across five areas of consumer financial services. These findings point to ongoing compliance risk challenges within the financial sector: 1. Auto Loan Servicing: Servicers failed to process final payments automatically, causing consumer confusion and potential late fees. The CFPB advises improving autopay systems and borrower communication. 2. Student Loan Servicing: Excessive wait times, inadequate dispute resolution, and misinformation were noted. The Bureau calls for better customer service and communication practices. 3. Debt Collection: Issues included aggressive tactics, abusive language, and ignoring consumer requests. Fair and respectful practices are emphasized. 4. Deposits and Prepaid Accounts: Institutions failed to notify consumers about account freezes and imposed excessive fees for basic account information. The CFPB encourages industry-wide improvements. 5. Credit Card Account Management: Medical credit cards were marketed with misleading promotions and undue pressure. The CFPB calls for enhanced oversight to ensure transparency and fairness. Institutions should act now to address these compliance issues and prevent consumer harm. Need guidance navigating these areas? Our team can help you strengthen your compliance program and address regulatory risks. Contact us today: https://lnkd.in/eQvF5sj6 #RADDLLC #CFPB #ConsumerProtection #Compliance #AutoLoans #StudentLoans #DebtCollection #PrepaidAccounts #CreditCards #FinancialServices #Regulation #RiskManagement

#LendingLaws | The Consumer Financial Protection Bureau (CFPB) has proposed a new interpretive rule that could significantly impact earned wage access (EWA) providers and the broader fintech environment. EWA products offer employees a payday flexibility option that allows them to access their earned wages on demand. Here's what we know about the new rule: The proposed rule suggests categorizing EWA products as credit under TILA and Regulation Z. This is a reversal of the CFPB's previous stance in November 2020, when it issued an advisory opinion stating that certain EWA programs meeting specific criteria would not be considered "credit." This reclassification of EWA products as credit will necessitate finance charge disclosures for certain fees associated. Notably, the two types of EWA-related payments categorized as a finance charge are fees for faster fund delivery options and "voluntary" payments like tips or donations, if the provider solicits them. Before the rule was proposed in July, states like Connecticut passed laws regulating EWA products as a form of loan, while California is currently considering similar legislation that would categorize these products as credit. The bureau is accepting public comment until August 30, 2024, but no implementation timeline has been provided, which could present operational challenges. What to do now: Whether you're an EWA provider, employer, or fintech company, now is the time to act. Review your current EWA offerings, assess potential impacts, and consider submitting your feedback to the CFPB. Need help navigating these changes? Contact our compliance experts today to ensure your business is prepared for what's ahead. Contact Us: https://lnkd.in/eQvF5sj6 #RADDLLC #FinTechRegulation #EWA #CFPB #RegZ #Compliance #WageAccess #FinancialRegulations #Fintech #TILA #EmployeeBenefits #FinancialServices

When we reviewed the CFPB's latest Supervisory Highlights covering examinations from April to December 2023, we found that the agency identified specific law violations and consumer harm in five key areas of consumer financial services. These findings suggest varied compliance risk management challenges in the examined institutions. The consumer protection agency highlighted issues in: 1) Auto Loan Servicing: The CFPB found that auto loan servicers often failed to process final payments automatically, leading to consumer confusion and potential late fees. Servicers are advised to improve their autopay systems and provide clearer communication to borrowers. 2) Student Loan Servicing: Student loan servicers were cited for excessive wait times, inadequate dispute resolution processes, and providing inaccurate information. The Bureau urged servicers to improve their customer service and communication practices. 3) Debt Collection (Including Credit Card Debt Collection): Debt collectors were found to engage in aggressive tactics, such as using abusive language and ignoring consumer requests. The CFPB emphasized the importance of fair and respectful debt collection practices. 4) Deposits and Prepaid Accounts: Institutions were criticized for failing to inform consumers about account freezes and for imposing excessive fees for basic account information. The CFPB is encouraging industry-wide improvements in these areas. 5) Credit Card Account Management: Medical credit cards were found to be marketed with misleading promotions and undue pressure on consumers. The CFPB called for improved oversight of these products to ensure transparency and fairness. Ensure Your Compliance Framework is Robust and Up to Date. RADD LLC can assist in navigating these findings and help strengthen your consumer compliance strategies. From customer communication improvements to fair debt collection practices, our experts are here to guide you every step of the way. Contact us today to ensure your compliance framework meets regulatory standards: https://lnkd.in/eQvF5sj6 #RADDLLC #CFPB #SupervisoryHighlights #ComplianceRisk #AutoLoanServicing #StudentLoanServicing #DebtCollection #CreditCardManagement #ConsumerProtection #FinancialServices