In August of 1996, as part of the “Comptroller’s Handbook” series of publications, the Office of the Comptroller of Currency (OCC) published a booklet entitled “Compliance Management System” (CCC-CMS). This booklet describes what the OCC expects in an effective compliance management system. In addition, the booklet provides information on the examination objectives and procedures when reviewing a bank’s compliance management system. The OCC’s booklet describes a compliance management system as:
the method by which the bank manages the entire consumer compliance process. It includes the compliance program and the compliance audit function, sometimes referred to as compliance review or self-assessment (fair lending). The compliance program consists of the policies and procedures which guide employees’ adherence to laws and regulations. The compliance audit function is independent testing of an institution’s transactions to determine its level of compliance with consumer protection laws, as well as the effectiveness of, and adherence with, policies and procedures.
This publication can be viewed by going to the OCC website (www.occ.gov) and searching for "Comptroller's Handbook."