Examiners will evaluate the extent to which management controls reflect the risk associated with the institution's lending strategy. As with the broader area of compliance-risk management, examiners will look closely at how the compliance culture established at the top of the organization filters down into the everyday responsibilities of business-line managers and how those managers are held accountable for compliance.
Conclusion Because of the growing complexity of banking organizations, the Federal Reserve is currently considering whether more-tailored guidance in the area of enterprise-wide compliance-risk management is warranted. In the coming months, we will continue to engage with you to better understand your successful approaches to identifying, monitoring, and managing risk across your organizations. Thank you. BIS Review 56/2006  5