Thomas Grundy | Wolters Kluwer
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  • Thomas Grundy

    Thomas Grundy

    Senior Regulatory Consultant

    Thomas Grundy joined Wolters Kluwer risk and compliance consulting practice as senior regulatory consultant in January 2013. With 31 years of experience as a former regulator, compliance professional, and consultant, he puts his experience to work advising compliance and risk management executives on practical solutions to effectively manage compliance in a complex and rapidly changing regulatory environment.

    Mr. Grundy has years of experience in risk-based enterprise compliance program assessment, development and implementation, governance processes, compliance training, pre-charter conversion reviews, regulatory examination management and response, and practical experience performing targeted assessments for compliance with a wide range of federal consumer protection and safety and soundness laws and regulations impacting lending, deposits, electronic banking, information privacy and security, trust and fiduciary operations, community reinvestment, and anti-money laundering. In addition to consulting, he has served as a compliance officer for nationally recognized traditional and online financial service providers. He started his career as a field examiner for the Office of the Comptroller of the Currency and later served as an oversight examiner for the Federal Reserve Board in the Fed’s Division of Consumer and Community Affairs.

    Mr. Grundy is a graduate of the University of Kentucky, the Graduate School of Banking at the University of Wisconsin, and the American Bankers Association National Graduate Compliance School. He is a Certified Regulatory Compliance Manager (CRCM).

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    Coming of Age: Fintech Matures
    (Published Summer 2017) In this article, Senior Regulatory Consultant Tom Grundy explores the evolution of technology over the past 20 years. From Sony Walkmans and VCR’s to Bitcoin and digital wallets, there’ve been tremendous advances over the years. And, for competitive financial institutions, innovation will continue to play a critical role in their success, although not without some challenges.
    ECOA Baseline Basics…Getting to Know Your Fair Lending Program
    (Published January 11, 2016) In this article, Tom Grundy a Senior Regulatory Consultant at Wolters Kluwer provides a high-level walkthrough of the ECOA Baseline Review (“Baseline”) with respect to fair lending, published by the Consumer Financial Protection Bureau (CFPB).
    Third Party Vendor Management: Taking Due Diligence and Oversight Beyond the Checklist
    (Recorded June 4, 2015) Third-party vendor management has become one of the most hotly scrutinized management issues in the banking industry, and several recent high profile security breaches have brought sharp attention to vulnerabilities created by engaging third parties. Banks have responded by putting in place oversight measures focused on addressing the potential gaps and pitfalls outlined in regulatory guidance from the OCC, Federal Reserve, CFPB and the FDIC. But do those measures go far enough? This session outlines the need for differing risk approaches and, based on a recently completed survey of over 200 bank executives, details how leading banks are managing due diligence and ongoing oversight of third-party service providers to minimize risk exposure. View a recording of this webinar to hear about emerging areas of risk, approaches to monitoring exposure, and insight into how your peers are approaching third party relationships.
    Heightened Expectations for Some—a Message for All to Consider: The Evolution of the 3 Lines of Defense
    (Published April 23, 2015) Mark Twain once said that, "Climate is what we expect, weather is what we get." The words and wisdom of this great American author and humorist succinctly describe the mindset and experience leading up to and following the most recent global financial crisis. From what seemed like endless sunny days of possibilities for an economy riding the real estate boom, the weather took a significant turn. Whether your institution falls under the direct coverage of the OCC's late 2014 Guidelines, risk management practices in all aspects are being scrutinized across the industry. The concepts covered by the Guidelines provide a good indication of what regulators might consider when reviewing your risk management practices. You can expect that your system of checks and balances along the three lines of defense will be reviewed by your regulator like never before. In this white paper, Mr. Grundy discusses how risk governance frameworks should be developed with a view to addressing risks relating to the core categories of risk by each of the three lines of defense.
    Compliance Zen: Finding the Path to a Strong Compliance Management System
    (Published April 2015) The Federal Reserve Board expects that institutions embrace a top down culture of compliance. Learn how financial institutions can move beyond “mere compliance” and find their path to a stronger compliance management system.
    Strengthening Risk Compliance Along Three Lines of Defense
    (Published January 2015) The changing regulatory landscape has introduced increased focus and heightened expectations for financial institutions around risk management and compliance risk management. Building a strong compliance culture and program starts with strategic planning built with the input from frontline units (the first line of defense), compliance units (the second line) and audit (the third line). This article, co-authored by Stephen Cross and Thomas Grundy, provides an overview of the three lines of defense and the role each plays in supporting compliance risk management.  It was published in the January 2015 issue of ABA Bank Compliance magazine.
    Third-Party Service Providers: Diligently Building and Maintaining Vital Relationships
    (Published November 2014) Banking is not unlike other industries when it is faced with the question of how to get the job done—do you keep it in-house and invest in the resources necessary to support a particular task, service or product delivery, or do you look outside of the company for a qualified third party or strategic partner to meet the need? This question often is raised by individual business units deep within the enterprise and by business people who are focused on productivity and profitability. The danger presented by this situation is only as threatening as the controls established to manage third-party risks.
    Risk Management: Best Practices for Effective Monitoring and Testing
    (Recorded April 22, 2014) Ongoing monitoring and testing of controls is a critical component of your organization’s Enterprise Risk Management program. Identification of controls, attestation of key controls and testing of control efficiency are intertwined with the risk management program and should be conducted in harmony across the organization. View this recording to learn best practices for breaking down organizational silos and achieving a “Zen-like” control environment which is proactive, informative and timely.
    Private Student Lending: Time to Meet a Higher Standard
    (Published April 2014) Private student loans are receiving attention from federal and state regulators and enforcement agencies. In February 2014, for example, the CFPB filed a lawsuit against a for-profit college and private student lender accusing the entity of pushing students into higher-cost private student loans that were likely to end in default. This paper is therefore intended to provide guidance to private student lenders to help them meet consumer needs and avoid potentially unfair, deceptive or abusive practices.
    Consumer Complaint Management: Understanding Regulatory Expectations
    (Published February 2014) The role of the Consumer Financial Protection Bureau (CFPB) is to receive, record, and process complaints pertaining to financial services offered by banks, thrifts, and other providers of financial services. In this article we will look at complaint handling from the examiner’s point of view and help you identify effective processes that meet or exceed the expectations of the CFPB and the federal banking regulators. The specific elements of an effective complaint management system will vary across institutions, but the key areas to be addressed include complaint intake, escalation, analysis, response, and final resolution.
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