Now What? Economic Growth, Regulatory Relief and Consumer Protection Act Signed into Law.

Now What? President Trump signs Economic Growth, Regulatory Relief and Consumer Protection Act into law!

OK, if you are like anyone in the financial space (or at least the majority, most likely), you are cheering and possibly breathing a sigh of relief now that President Trump has signed the Economic Growth, Regulatory Relief and Consumer Protection Act into law.

So Now What?

Value Creation!

Your ERM Team has been providing effective risk management related to all things Dodd-Frank from its inception into law. We saw this as a lot of Compliance, Reputation and Transaction risk to name a few, and certainly required value preservation for our institutions. Now that same ERM Team should be utilizing all that data to provide some much-needed value creation.

Over the years there were many controls and risk responses put into place across multiple strategies and processes within our institution that may now no longer be needed or at least not to the stringency we originally created. This is where ERM can shine by creating tangle value from the changes in the law.

Where To Begin?

1. Review all the changes in the new law to determine exactly which parts impact your institution;
2. Determine which Strategies, Policies, Processes & Procedures were deemed to be impacted originally by Dodd-Frank;
3. Compare those changes in the law from #1 above to your impacted Strategies, Policies, Processes & Procedures determined above in #2;
4. Determine the existing Controls and/or Risk Responses currently in place from #3 to outline which ones are impacted by the changes;
5. Create a Mitigation Strategy Plan to present to your ERM Committee, Executive Committee and/or Board for how and why those impacted existing Controls and/or Risk Responses can be eliminated and/or reduced based upon the changes in the law. The subsequent approval of this plan should also be shared with your Internal Auditors, 3rd Party Auditors and Examiners as well.

Once you have created your Mitigation Strategy Plan you should be able to effectively and with confidence show how these changes in the law not only save you time, but also by potential dollar cost quantification through processing and/or employee engagement savings.

Is It Worth the Effort?

Until you complete the basic analysis from above how will you know? However, there are so many changes that impact all institutions in some form or fashion that completing the analysis is entirely worth the effort in my opinion. Even if you don’t have the resources to make the changes immediately, you will have a plan that can be enacted once you do. Whether you start now, complete the plan incrementally, or simply wait for a future date, don’t let these significant changes in the law keep you from demonstrating your ERM program’s value creation. Your institution, board, executive management and most importantly, your departmental employees, will thank you for it!