•  Implement firm-wide policies and procedures that ensure that the financial institution obtains a thorough understanding of the business purposes and economic substance of transactions identified as involving heightened legal or reputational risk and that these transactions are approved by appropriate senior management.
•  Clearly define the framework for approval of a complex structured finance transaction or a new complex structured finance product. •  Implement monitoring, risk reporting, and compliance processes for creating, analyzing, offering, and marketing complex structured finance products. Of course, these internal controls need to be supported and enforced by a strong “tone at the top” and a firm-wide culture of compliance.