Center of Regulatory Intelligence
September 30, 2016
Regulatory Intelligence Briefing – Focus on the Department of Labor’s
Fiduciary Rule and the Military Lending Act
Regulatory Intelligence Briefing – September 2016
Table of Contents
A. Editorial Note from the Managing Director, Center of Regulatory Intelligence .......................3
B. Washington, D.C. Regulatory Roundup .................................................................................4
C. Congressional Summary – Modernizing the TCPA ................................................................5
D. FOCUS – DOL Fiduciary Rule ...............................................................................................7
E. Key Themes of Military Lending Act Amendments ............................................................... 12
F. Did You Know? ..................................................................................................................... 16
G. About FIS’ Center of Regulatory Intelligence ....................................................................... 17
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Regulatory Intelligence Briefing – September 2016
A. Editorial Note from the Managing Director, Center of Regulatory
Intelligence
During the past several years, the Consumer Financial Protection Bureau (CFPB) has dominated the financial
services industry’s newsfeed as it relates to consumer protection regulations. Since its inception, the agency’s
supervisory and rulemaking authority was built on a basic foundation of consumer protection. However, it is wise
to remain cognizant of additional sources of consumer-driven regulatory activities.
In this edition of the Regulatory Intelligence Briefing (RIB), we review final rules from the U.S. Department of
Labor (DOL) regarding the expansion of the definition of fiduciary and U.S. Department of Defense (DOD)
regarding the Military Lending Act (MLA) rule. These final rules represent ongoing developments in the consumer
protection regulatory space that exists outside the CFPB and have gained their fair share of headlines in recent
years. As 2017 approaches, they will continue to demand attention from financial institutions of all types.
First, we start with this month’s Washington, D.C. Regulatory Roundup of news items that may be of interest to
readers. Next, we provide a summary of a recent hearing by the House Energy and Commerce Committee’s
Subcommittee on Communications and Technology on “Modernizing the Telephone Consumer Protection Act.”
The subcommittee’s discussion of this Act (TCPA) explores a possible disconnect between the language of the
TCPA and the rapidly evolving technological environment in which we live. The impact of technology on consumer
behavior suggests that certain aspects of the TCPA may be difficult for institutions to manage from an operational,
compliance and legal perspective.
In our focus article, we provide an overview of the DOL’s Fiduciary Rule (Conflict of Interest Rule) and highlight
the elements of the rule that act as a gateway to understanding how the rule may impact an institution’s
investment advice activities. With the rule’s initial compliance date almost seven months away, the new fiduciary
responsibilities found in the rule may require a large amount of preparation, training and operational support from
various stakeholders within an institution. Ultimately, this rule is intended to ensure that retirement plan investors
receive advice in their best interest. At the end of the article, we include a list of important considerations and
action items to continue the discussion offline with colleagues.
Finally, we conclude this month’s RIB with a brief review of the DOD’s MLA final rule from July 2015. With the
rule’s initial compliance date about to take place (October 3), lending institutions may already have a plan in place
for compliance. But the wait is over, so we share this article as a reminder of the more provocative requirements
of the new MLA and the expanded protections for servicemembers.
Peter D. Dugas
Managing Director, Center of Regulatory Intelligence
Peter has more than 16 years of government and consulting experience in advising clients on supervisory matters before
the U.S. government and in the implementation of enterprise risk management programs. He is a thought leader in
government affairs and regulatory strategies in support of banks and financial institutions compliance with the DoddFrank Act and Basel Accords. Prior to joining FIS™, he served as a director of government relations at Clark Hill and in
senior government positions, including serving as a deputy assistant secretary at the United States Department of the
Treasury.
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B. Washington, D.C. Regulatory Roundup
Regulatory and Compliance Alerts
CFPB Releases August Complaints Report Spotlighting Bank Accounts and Services
On August 30, 2016, the CFPB released a monthly complaint report highlighting consumer complaints about bank
accounts and services. Common issues found in these complaints relate to the use of consumer reports to open
deposit accounts, funds availability and error resolution. Additionally, the geographic focus of the report highlights
trends seen in complaints coming from Ohio.
NCUA Issues Training on the Fundamentals of Strategic Planning
On September 8, 2016, the National Credit Union Association (NCUA) issued a four-part series of training videos
related to the strategic planning process including: effective board management, mergers and credit union
policies and procedures. The intended audience is credit union board members. An online test is also available
for completion after viewing the videos.
FFIEC Releases Revised Information Security Booklet
On September 9, 2016, the Federal Financial Institutions Examination Council (FFIEC) issued a revised
Information Security booklet, which is part of the FFIEC Information Technology Examination Handbook. The
revised booklet addresses the factors necessary to assess risk related to a financial institution’s information
systems. The booklet also helps examiners evaluate the adequacy of the information security program’s
integration into overall risk management.
CSBS Releases White Paper on Community Bank Collaboration
On September 12, 2016, the Conference of State Bank Supervisors (CSBS) released a white paper describing
the benefits of collaboration among community banks. Titled Shared Resource Arrangements: An Alternative to
Consolidation, the paper identifies a number of ways some financial institutions have successfully shared
resources to either improve compliance, increase efficiency or both.
FDIC Announces New Affordable Mortgage Lending Resources
On September 15, 2016, the Federal Deposit Insurance Corporation (FDIC) released The Affordable Lending
Guide, Part I, which organizes information about single-family mortgage products from federal agencies and
government-sponsored enterprises and provides technical assistance for community banks on affordable
mortgage credit options. Institutions can use the guide as a one-stop resource to learn about various program
resources, compare different products and understand Community Reinvestment Act implications.
Additionally, the Affordable Mortgage Lending Center provides a program matrix, program descriptions, data and
fact sheets from the FDIC and other federal resources.
HUD Issues Guidance on Fair Housing Protections for People with Limited English Proficiency
On September 15, 2016, the Department of Housing and Urban Development (HUD) issued new Limited English
Proficiency (LEP) guidance. The guidance addresses how the Fair Housing Act would apply to claims of housing
discrimination brought by people because they do not speak, read or write English proficiently.
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Regulatory Intelligence Briefing – September 2016
C. Congressional Summary – Modernizing the TCPA
On September 22, 2016, the House Energy and Commerce Committee, Subcommittee on Communications and
Technology held a hearing entitled “Modernizing the Telephone Consumer Protection Act.” The hearing
considered the challenges faced by consumers and companies in a world where technology and consumer
behavior may have outpaced the language of the Telephone Consumer Protection Act of 1991 (TCPA). The law
has triggered class action lawsuits filed against companies from all sectors, including many lawsuits filed against
financial institutions. Despite recent amendments to the act from a declaratory order and ruling by the Federal
Communications Commission (FCC) in July 2015, confusion still exists regarding the law.
At its heart, the TCPA was passed as a consumer protection and privacy measure with restrictions related to
telephone solicitations and the use of automated dialing equipment. According to a congressional statement of
findings, when passing the TCPA, Congress intended to strike a balance between “individuals’ privacy rights,
public safety interests, and commercial freedoms of speech and trade” and do so “in a way that protects the
privacy of individuals and permits legitimate telemarketing practices.”
The hearing consisted of a panel comprised of the following members:




Mr. Shaun W. Mock, chief financial officer, Snapping Shoals Electric Membership Corporation
Mr. Richard D. Shockey, principal, Shockey Consulting
Ms. Michelle Turano, vice president, Government Affairs, WellCare
Mr. Spencer W. Waller, Professor; director, Institute for Consumer Antitrust Studies, Loyola University
Chicago
In his testimony, Shaun W. Mock stated a need for change to the TCPA.
“
“
[W]e agree that consumer rights are of the utmost importance and every effort should be made to
prevent excessive and bothersome phone calls from unsolicited vendors. However, legitimate business
communication should not be hindered in the process. Some reasonable legislative changes, perhaps
even new legislation, should be considered as we learn how to manage and adapt to ever-changing
consumer communication preferences in the 21st century.
Shaun W. Mock, chief financial officer, Snapping Shoals Electric Membership Corporation.
The Subcommittee’s background memo highlights two major issues with the TCPA discussed at length during the
hearing:
1. The broad interpretation of the term “autodialer”
2. The increasing amount of reassigned numbers
Many TCPA lawsuits stem from provisions of the act that prohibit businesses from using autodialers, often
referred to as “robocalling,” to send mass-marketing phone calls or texts without receiving express permission
from the called parties. In a separate order issued in August 2016, the FCC amended the TCPA at the request of
the Obama administration to permit autodialed calls to wireless or residential phones without consent if the call is
made for the purpose of collecting a debt that is owed or guaranteed by the United States.
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Further, a person can be found liable if a previous caller has received expressed consent from the
intended recipient but the person has changed numbers. While the FCC rules allow a caller to make a first
call to obtain knowledge that a number has been reassigned, a caller can be liable for any calls thereafter
whether they have knowledge of the reassignment or not. The Wall Street Journal cited more than 37
million numbers are reassigned annually, making this problem more evident.
In his written testimony, Spencer Waller suggested the TCPA should be updated with particular attention paid to
improving federal and state government enforcement efforts and increasing the uniformity of interpreting the
statute. He recommended that the Federal Trade Commission (FTC) be given more enforcement responsibilities
due to the agency’s current role as an enforcement body (particularly related to the Do Not Call Rule). In
furtherance, Waller stated in his testimony, “The FTC’s continuing work towards a technical solution to robocalls is
commendable, and should be followed with respect to other types of media currently exposed to unsolicited
commercial messages such as text messages and email.”
Richard Shockey emphasized that the issues raised by the Subcommittee are not just limited to the TCPA.
Shockey stated in his testimony that the Truth in Caller-ID Act should also be revised. He points to The Improving
Rural Call Quality and Reliability Act of 2015 (H.R. 2566) and the Anti-Spoofing Act of 2015 (H.R. 2669), both
introduced in 2015 and still pending in the House, as types of legislation outside of amending the TCPA that could
improve consumer protections.
Compliance with the TCPA for financial institutions must be a priority. Whether using fax or email for marketing, engaging in
telemarketing, using artificial or pre-recorded voice telephone messages or using an automated dialing system, all of these
activities require specific compliance and record retention. For example, if your financial institution uses an automated
telephone dialing system:
•
•
•
•
•
Is the system programmed to prevent engaging multiple lines of a business simultaneously?
Are unanswered telemarketing calls disconnected in the appropriate manner?
Does the autodialing system comply with the rules once it does not detect compatible terminal equipment at the other end?
Are sequential dialers programmed correctly?
Is the autodialing system programmed to release the line in a compliant time period once the recipient hangs up?
Conclusion
While Subcommittee Chairman Greg Walden (OR-R) announced this would not be the last hearing on the issue, a
lag in congressional action could lead to large fines or costly litigation for institutions. Given the constant litigation
bred from the TCPA, along with broad interpretation of terms in the Act, compliance with the TCPA is challenging
but paramount, and institutions would be wise to implement enhanced processes and controls specific to TCPA
concerns.
Passed in 2012
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Regulatory Intelligence Briefing – September 2016
D. FOCUS – DOL Fiduciary Rule
On April 8, 2016, the Department of Labor (DOL) and Employee Benefits Security Administration (EBSA)
released the final fiduciary rule (DOL Rule), also known as the Conflict of Interest Rule, in the Federal Register,
with an initial compliance or applicability date of April 10, 2017. The rule includes certain delayed exemption
requirements, which will make the rule fully applicable by January 1, 2018.
The final rule results in a stricter version of the Employee Retirement Income Security Act of 1974 (ERISA), which
created a single, comprehensive set of rules to follow regarding employee benefit plans. The key aspects of the
final rule include the expanded definition of the term “fiduciary” and the imposition on investment advisers –
including broker-dealers and insurance agents – to abide by a fiduciary standard that previously was not in effect.
Starting in April 2017, four noteworthy provisions will come into play with the new DOL Rule.
1. Establishment of fiduciary standard – Registered advisers who receive compensation for providing
investment advice involving any non-ERISA retirement plan or Individual Retirement Account (IRA) will be
subject to this fiduciary standard. All financial advisers will be required to recommend what is in the best
interest of their clients when they offer guidance on 401(k) plan assets, IRAs or other qualified monies
saved for retirement. If this requirement is not followed, the adviser will be subject to possible litigation
and financial penalties.
2. Best Interest Contract Exemption (BICE) – This exemption allows firms to continue with commission
and revenue sharing-based compensation practices as long as:


Firms adopt policies and procedures designed to mitigate conflicts of interest.
Firms clearly and prominently disclose any conflicts of interest, like hidden fees, that might prevent
the adviser from providing advice in the client’s best interest.
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The intention of the BICE written agreement requirement is for an IRA and other non-ERISA-governed
clients to have a contractual cause of action against the adviser if the client suffers financial harm as a
result of the adviser’s conflict of interest. The DOL rule does not ban commission or revenue sharing, but
it requires advisers to have clients sign a BICE agreement. This contract ensures that the adviser will act
in the client's best interest and maintain a sensible level of compensation.
3. Principal Transaction Exemption (PTE) – This exemption allows advisers to recommend inventory
securities, fixed rate annuity contracts and insurance contracts. The nuance is that the adviser must
adhere to the exemption's proactive consumer-protection conditions and standards.
4. Pre-existing Transaction Exemption – This exemption allows advisers to receive ongoing
compensation payments in connection with a prohibited transaction that was completed before the
enactment of the proposed rule. This exemption is applicable as long as the adviser does not provide
additional advice to the plan or IRA regarding the same asset after the enactment of the proposed rule.
The rule imposes certain compliance requirements on small service providers, such as broker-dealers, registered
investment advisers, insurance companies and agents, pension consultants and others providing investment advice to
plans or IRA investors. Additionally, understanding the exemptions is critical to preparing for and maintaining
compliance with the rule.
What is a covered
investment under the
Fiduciary Rule?
What is NOT covered
investment advice:
Definition:
Exemptions:
Covered investment advice is a
recommendation to a plan, plan fiduciary
or IRA owner for a fee or other direct or
indirect compensation.
These do not constitute fiduciary investment advice communications
because they do not meet the definition of “recommendation.”
Covered investment
recommendations on:






advice
includes
The management of securities or other
investment property
Investment policies or strategies
Portfolio composition
Selection of other persons to provide
investment
advice
or
investment
management services
Selection
of
investment
account
arrangements (e.g., brokerage versus
advisory)
Recommendations with respect to
rollovers, transfers or distributions from a
plan or IRA, including whether, in what
amount, in what form and to what
destination such a rollover, transfer or
distribution should be made
 Education: Hypothetical asset allocation models or interactive investment
materials intended to educate participants and beneficiaries as to what
investment options are available.
 General Communication: Circulation newsletters; commentary in publicly
broadcast talk shows; remarks and presentations in widely attended speeches
and conferences; research or news reports prepared for general distribution.
 Platform Providers: Marketing or making available a platform of investment
alternatives without regard to the individualized needs of the plan, its
participants or beneficiaries if the plan fiduciary is independent of the service
provider.
 Transactions with Independent Plan Fiduciaries with Financial Expertise:
True arm's length transactions between advisers and investment professionals
or large asset managers who do not have a legitimate expectation that they are
in a relationship where they can rely on the other adviser for impartial advice.
 Swap and Security-Based Swap Transactions: Communications and
activities by counterparties to swap and security-based swap transactions do
not result in the counterparty being covered by this rule (conditions apply).
 Employee of Plan Sponsors, Affiliates, Employee Benefit Plans, Employee
Organizations or Plan Fiduciaries: Reports and recommendations routinely
developed by employees in a company's payroll, accounting, human resources
or finance departments for the company and other named fiduciaries of the
sponsors' plans.
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Potential Challenges
The DOL Rule may present challenges for
institutions and investors alike, forcing them to
re-evaluate their business models to ensure
they are in compliance. Some institutions may
move to fee-based services, while others will
choose not to offer certain products for
retirement accounts. For example, some firms
have hinted they will stop offering clients
mutual funds and exchange-traded funds
(ETFs) for commission-based retirement
accounts. Other possible reactions to the rule
include cutting prices and account minimums
or launching a fund-only brokerage IRA
option.
As firms prepare for compliance with the rule,
additional issues are likely to appear. An
example of this includes the delay of front-end
development work until firms determine the impact BICE may have on their business. Other considerations that
are necessary when managing these new requirements include:



Will the BICE need to be reviewed and tracked if there is an exemption prior to order submission? If so,
will the institution need to make it accessible for review (including in the audit trail)?
Will the BICE require that updates be shared between the adviser and investor?
Are electronic signatures and/or forms management required?
In addition to the issues above, firms may also find value in monitoring the lawsuits filed against the DOL
pertaining to the DOL Rule. Court judgments may impact how certain aspects of the rule will be interpreted and
implemented in the future.
Investor Challenges
Investors will receive more paperwork to review and store.
Investors may not have as much access to traditional non-fee-based advisers.
Fees may rise to offset the cost of compliance and implementation.
Investors may not have as many options as products are cut due to risk
or limited revenue opportunity.
COLLECTION
Investors mayACCURATE
have different DATA
experiences
from firm to firm.
While customers may enjoy the
benefit of lower costs as a result of
actions taken by some firms, there
may also be fewer investment
options. The DOL rule could create a
risk-based shift in the products firms
recommend to clients. According to
statistics gathered by Bloomberg,
advisers revealed that variable
annuities may be recommended less
often, with managed accounts being
recommended more often.
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Source: DOL, https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/fact-sheets/dol-final-rule-toaddress-conflicts-of-interest
Conclusion
The new rule comes with advantages and disadvantages for impacted institutions. The main consideration these
institutions may have to evaluate is how to balance the operational and legal implications with the heightened
responsibilities at the core of the investor relationship that could have a great effect on institutions. Significant
disruptions could occur for firms with a large non-fee based business and insurance companies selling variable
annuities and other high-risk products.
From a punitive perspective, prohibiting the adviser from recommending products that put their personal
compensation concerns in front of the best investment product for a particular customer opens the door for a
greater chance of legal difficulties. On the other side of the equation the operational impact could be great.
Brokers will have to track every non-fee based account transaction and whether or not the contents of the trade
have met the BICE requirements. The required audit trail could immensely impact the data storage requirements
for institutions.
As the compliance date approaches, institutions will need to take steps to ensure full understanding and
compliance within the institution. On the next page are some additional considerations to spark conversation for
stakeholders responsible for the implementation and ongoing oversight of these requirements.
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E. Key Themes of Military Lending Act Amendments
Overview
As the industry prepares to comply with the DOD amendments to its regulation that implements the MLA, there
are some key themes to hone in on. Below are the provisions discussed in this article and a timeline related to the
MLA amendments:




Expands the definition of “consumer credit” to be consistent with Regulation Z
Provides a safe harbor for creditors who use the DOD’s online database or a consumer credit report
when determining “covered borrower” status
Modifies the Military Annual Percentage Rate (MAPR) to include additional fees and charges
Changes the loan disclosures required for covered credit
Key Dates
July 22,
2015
DOD Issues
Final Rule
October 1,
2015
October 3,
2016
October 3,
2017
October 3,
2018
Effective
Date
Compliance
Deadline*
Credit Card
Compliance
Deadline
Possible
Extension of
Credit Card
Compliance
Deadline
REDUCE
*Credit Cards Exempt from 2016 Deadline
Expanded Definition of “Consumer Credit”
Perhaps most notably, the DOD revised the scope of “consumer credit” under the MLA to align with the definition
found in the Truth in Lending Act (TILA). Accordingly, “consumer credit” is now defined in the MLA as:



Credit offered or extended
To a covered borrower
Primarily for personal, family or household purposes, and that is
– Subject to a finance charge, or
– Payable by a written agreement in more than four installments.
This increases the MLA’s scope to include more types of open-end and closed-end credit transactions, which
consequently requires more creditors to comply with the law.
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Overview of Coverage
Existing Coverage
Certain types of closed-end:
New Coverage**
Credit cards

Payday loans
Lines of credit

Vehicle title loans
Student loans

Tax refund anticipation loans
Installment loans
Single pay loans
**Not a comprehensive list
It will be important for a financial institution offering covered
types of credit to ensure that it incorporates
MLA compliance into its compliance management system
and operations.
“Covered Borrower” and Safe Harbor
While the amendments do not change who is a covered
borrower under the MLA, they do change how a creditor can
obtain a safe harbor for compliance when establishing
whether a borrower is covered.
A “covered borrower” is defined in the Final Rule as:
 A member of the armed forces who is:
– Serving on active duty under a call order of
longer than 30 days or
– Serving on active Guard and Reserve duty
 Dependents of qualifying servicemembers
The MLA continues to offer creditors a safe harbor for
compliance when a covered-borrower check is performed in
conformity with the rule’s requirements; however, the
amendments change what constitutes a safe harbor.
Safe Harbor
Old Safe Harbor
New Safe Harbor
DOD online database
Use of covered borrower statement
Consumer report from a nationwide consumer
reporting agency
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For accounts consummated or established on or after October 3, 2016, a creditor seeking a safe harbor for
compliance with the rule may use either (or both) of the new methods listed above, however, these methods are
not required to be used.
Regarding frequency, a creditor is only required to conduct a covered-borrower check once:


When the consumer initiates the transaction or applies to establish an account, or
When the creditor develops or processes a firm offer of credit.
For “pre-screened offers,” a creditor may rely on its original covered-borrower check as long as the consumer
responds no more than 60 days after the offer date.
Important: A creditor must retain proof of the determination in order to receive the safe harbor.
Calculation of the MAPR
The MLA generally prohibits a creditor from charging a covered borrower a
MAPR that is greater than 36 percent. The framework for MAPR
computation is comprised of the traditional makeup of the annual
percentage rate (APR) found in Regulation Z plus other finance charges
and fees, including:
Credit insurance premiums
Application fees
Participation fees
Fees for ancillary “add-on” products
For example, the MAPR would include the fees and/or premiums related to
credit insurance, debt cancellation and debt suspension. For open-end
credit accounts, these fees must be included in the MAPR even if the fees
will be collected after the account is opened.
Loan Disclosures
The MLA final rule seeks to simplify the information that creditors must
provide to a covered borrower at the time they become obligated on the
transaction or establish an account for credit. The amendments eliminated
the requirements for a specific statement regarding protections available to
covered borrowers and for providing disclosures “clearly and
conspicuously.”
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New disclosure requirements include:

A statement of the applicable MAPR that describes the charges the creditor may impose, instead of the
periodic rate of the MAPR itself and the total dollar amount of all charges included in the MAPR


Any disclosure required by Regulation Z, delivered in accordance with the requirements of Regulation Z

Provision of the required MLA disclosures to the borrower both in writing and orally. A creditor may elect
to provide the oral disclosures either in person or by providing the covered borrower with a toll-free
telephone number.
A clear description of the payment obligation of the covered borrower, which may be satisfied by a
payment schedule (closed-end credit) or an account opening disclosure (open-end credit)
Key Takeaways
While impacted institutions may have taken steps to prepare for compliance with the MLA final rule, there may be
additional work to be done. Below are some key steps for ensuring compliance with the MLA amendments.
Please note this list is not exhaustive. It is intended to spark an institution’s internal discussion.
Update regulatory applicability matrix so all newly covered products are appropriately mapped to the
MLA.
Review written and oral disclosures and their accompanying procedures for compliance with
requirements.
For open-end credit accounts, establish procedures to monitor the MAPR each billing cycle and prevent
the MAPR from exceeding 36 percent.
Establish procedures on open-end credit accounts to address when the borrower is no longer covered.
Assess the institution’s usage (if any) of the safe harbor provision.
Evaluate methods for identifying covered borrowers and adjust those procedures if needed.
Update all impacted policies, procedures, job aids and training materials.
Train staff in affected business units on the changes.
Include MLA in upcoming monitoring and audit schedules for covered products and services.
Flag calendars for future credit card compliance deadlines and implement an action plan for implementing
the changes, including clear lines of responsibility, key milestones and deadlines.
Report to the board of directors on changes implemented to ensure compliance.
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Regulatory Intelligence Briefing – September 2016
F. Did You Know?
SECURITIES COMPLIANCE SERVICES
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practical, risk-based approach to securities compliance.
Our methodology is to first understand a firm’s business and then tailor a sound
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Compliance program assessments and remediation
Compliance program development and implementation
Compliance co-sourcing
Code of conduct and ethics
Regulatory impact assessments
Compliance reviews, audits, and mock examinations
Supervisory control testing
Advertising reviews
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Transaction monitoring and trade surveillance
Forensic investigations
Comprehensive training
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We specialize in identifying, measuring and mitigating securities compliance risks.
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G. About FIS’ Center of Regulatory Intelligence
FIS™ (NYSE: FIS), a global leader in banking and payments technology as well as consulting and outsourcing
solutions, opened its Center of Regulatory Intelligence (“Center”) in Washington, D.C. on June 16, 2015. The
primary goal of the Center is to translate policy, legislative and regulatory developments into actionable
intelligence for FIS clients to enable knowledge advantage. The unique perspective gained by monitoring
regulatory change at such close proximity to the policymakers and regulators enables the Center to empower FIS
clients to stay one step ahead, identify impact precisely, make smart business decisions and succeed. FIS clients
receive insights from the Center through regularly published regulatory intelligence briefings and thought
leadership insights intended to give client institutions deep intelligence into regulatory initiatives coming out of the
legislature, administration and regulatory agencies. Input from the Center also helps drive FIS research and
development efforts as well as consulting services aimed at helping institutions address regulatory changes prior
to implementation.
The Center provides the latest intelligence, thought leadership and cutting-edge regulatory insights into risk,
information security and compliance issues facing the financial services industry. This FIS thought leadership
center provides early insight on regulatory changes, helping financial services clients stay compliant with new
regulations. Through the Center, FIS interfaces with key policymakers to provide industry perspectives on the
potential impacts of regulatory mandates to financial institutions.
Contact Us
FIS Center of Regulatory Intelligence
1101 Pennsylvania Ave., NW Suite 300
Washington, DC 20004
E: [email protected]
P: 202.756.2263
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