What's at stake?

What's at stake here for OCC regulated trust companies: more than just operational and reputational risk - now also regulatory risk, as "life insurance" was specifically addressed in the newly issued (August 2012) OCC Comptrollers' Unique and Hard to Value Handbook.
What's at stake: not just liability, but perhaps more severe- the consequences of bringing to light that the "Matter Requiring Action" was caused by a systemic "not having a system in place, and not a non-systemic one time human error.
There is no pathway to adequate risk management defensibility, or compliance demonstrability without a rationalized and programmatic best practices system that manages the multiple policies within a trust "collectively."
There is also no way to deliver to client expectations to garner client satisfaction without it.


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