(As published in American Banker)
When regulators drafted guidance in the wake of the 2008 global financial crisis, establishing requirements for enterprise-wide compliance programs, they envisioned a relatively unified regulatory landscape where federal guidelines provided clear direction. That policy statement provided guidance for financial services firms on board culture, conduct, roles and responsibilities, and technology compliance. As one of the original authors, I can attest that we built it on the principles established by the Basel Committee on Banking Supervision, with the goal of creating standardized frameworks that institutions could implement consistently across their operations.
That world no longer exists.
According to Wolters Kluwer's 2024 Indicator survey, banks' concerns in managing regulatory change continue to persist at high levels as state rules diverge from federal standards and from each other. This splintering regulatory environment, combined with unprecedented political uncertainty now under a new presidential administration, is forcing institutions to fundamentally rethink compliance frameworks that were designed for a more standardized era…
