Business Partner Engagement:
•
Supports business leaders in the effective implementation, maintenance, and administration of 1st Line compliance programs.
•
Maintains an inventory of regulations and associated controls in GRCE (Compliance book of record) to ensure the completeness of the regulations mapped to the business and ensure controls to support regulatory compliance are documented and appropriately risk assessed such that they can be tested by the Monitoring & Testing Team.
•
Develops and maintains an understanding of the business/group strategies and objectives, products and services, internal and external stakeholders, and business processes as well as the underlying technology infrastructure to identify and manage compliance risk exposures for the business/group.
•
Participates in discussions with relevant stakeholders to review, edit and approve changes to policies, processes, procedures, controls, and technology needs to ensure they comply with regulatory developments/requirements.
•
Builds change management plans of varying scope and type; leads or participates in a variety of change management activities including regulatory readiness assessments, planning, stakeholder management, execution, evaluation, and sustainment of initiatives.
•
Completes supplier compliance risk assessments.
Collaborate and maintain positive relationships with individuals across the business listed below:
•
Primary Support: BPIC – Multiple individuals in the business including Regional Directors, Data Team Supervision and Governance team, Legal, 2nd Line Compliance
•
Secondary Support: GAM – Investment Team (Portfolio Managers, Traders), Operations, Product, Sales & Distribution Team, 2nd Line Compliance, Legal
Regulatory Compliance Issue Management
•
Identifies, investigates, analyzes, documents, and establishes plans to mitigate program risks, considering jurisdictional/provincial requirements, issues, and raises any issues or concerns to senior leaders and other stakeholders.
•
Breaks down strategic problems, and analyses data and information to provide insights and recommendations.
Supports the business on regulatory compliance Issues:
•
Identify Issues: Interpreting requirements (existing, new, and emerging) and identifying, analyzing, and addressing resultant gaps and issues, including those raised through the review of change initiatives. Work with the business to identify root cause of issues.
•
Develop/Assess Action Plans: Work with the business to establish/review action plans to ensure plans have sufficient level of detail and target dates are reasonable and supportable. Compliance issues can be identified by any of the following: self-identified by the business, 1st Line Monitoring & Testing, 2nd Line Monitoring & Testing, 2nd Line Chief Compliance Officer, Corporate Audit or Regulators
•
Monitor Remediation: Oversees and/or monitors the satisfactory resolution of such complex, contentious, or sensitive regulatory compliance issues, keeping in mind significant business unit implications. Using professional judgement escalate concerns with respect to remediation to allow for sufficient time.
•
Report to Senior Management: Provide regular updates to senior management in the business on the progress of remediation.
Personal Trade Monitoring - BPIC:
Manages and executes the personal trade monitoring program using the Personal Trading Application (PTA) including:
•
On boarding and offboarding access persons to PTA
•
Reviewing pre-clearance trade submissions and breaches
•
Reviewing external broker statements
•
Managing the annual certification of accounts by access persons
•
Providing quarterly reporting to the Chief Compliance Officer (CCO) on violations and trading volumes
Regulatory Compliance Risk Assessment (RCRA)
•
Accountable for leading the annual and trigger based Regulatory Compliance Risk Assessment (RCRA) which encompasses the principles, accountabilities, expected outcomes, processes and procedures for the identification and assessment of Regulatory Risk across the Enterprise.
•
Document rationales to support risk assessments and discuss/respond/address questions/challenge raised by 2nd Line oversight functions.
•
Separate risk assessments are required for:
•
All other remaining regulations.
Compliance Policy and Procedure Support
•
Provide compliance feedback on policies owned by the business: Acts as a subject matter expert in the evaluation, development, and implementation of a compliance internal control system.
•
Participate in the regular cyclical review of policies that contain and/or address regulatory requirements.
Client Focused Reforms (CFR) requires a documented inventory of conflicts of interest.
This role maintains the COI Log i.e., initiates an annual review by engaging key stakeholders (Business, Tier 2 Compliance, 2nd Line Compliance and Legal) to review and to confirm accuracy.
This role understands and assesses business and regulatory change in order to identify and assess new and/or changing conflicts for materiality, outside of the regular annual review, and engage the appropriate stakeholders, along with Legal Regulatory Compliance (LRC) to update the COI Log accordingly.
Make recommendations and provide solutions and enhancements to existing practices to keep pace with regulatory changes and provide requisite support in the implementation of regulatory change initiatives:
•
Understand, assess, and monitor industry and regulatory/legislative developments and continuously updates compliance programs to ensure they continue to be effective.
•
Analyze new and pending laws, regulations and industry commitments that affect areas of business responsibility ensuring that relevant issues and organizational risks are identified and raised.
•
Conduct and document impact assessments for new regulatory requirements and communicate conclusions to the business, 2nd Line Compliance and Legal.
•
Participate in regulatory development project meetings as required.
•
Attend industry association meetings on Compliance related matters.
Compliance Training - GAM:
•
Provides support to the development and delivery of compliance training and awareness programs within the business/group to increase awareness of and compliance to risk management requirements.
•
Provides training to ensure business unit employees fully understand regulatory requirements and associated controls. Builds awareness, knowledge, and skills and, as necessary, provides communication, practical tools and ongoing support including making presentations – attend and communicate changes at national calls.
Compliance Review Support (Audit, 1st Line M&T, 2nd Line Regulatory Compliance Testing):
•
Provides support for compliance related information requests associated with investigations, reviews, or examinations conducted by internal and external stakeholders, including regulators, providing verbal and written responses to requests for information and/or documentation.
•
Meet with reviewers to execute walkthroughs of key processes/controls and answer questions.
Business Specific Support:
BMO Private Investment Counsel BPIC – Investment Fund Manager and Dealer
•
Manage/execute personal trade monitoring.
•
Compliance reporting - prepare monthly and quarterly reporting.
•
Provide issue management support.
•
Facilitate foreign jurisdiction.
•
Review and update compliance related Policies
•
Facilitate/lead monthly meetings with the 2nd Line Compliance to discuss various topics including regulatory development, compliance issue updates, control updates, RCRA updates, etc.
BMO Global Asset Management (GAM) - Investment Fund Manager and Dealer
•
Facilitate/lead monthly meetings with the 2nd Line Compliance to discuss various topics including regulatory development, compliance issue updates, control updates, RCRA updates, etc.
•
Draft, review and update compliance related Policies