Shaver is a Senior Director II with Treliant. She is a compliance executive with over 30 years of banking experience, including more than 20 years in a compliance role. Before joining Treliant, she was Senior Vice President and Chief Compliance Officer at FirstMerit Bank, a mid-size bank with assets of over $25 billion.
- Source: occ.treas.gov
We frequently receive questions from institutions on appropriate compliance testing sampling strategies. A Compliance Management System includes all three lines of defense and the testing and monitoring conducted through each of the respective lines. The questions are typically asked by the first line of defense (lines of business) and the second line of defense (compliance). Treliant can help establish a compliance testing framework including adequate sampling.
On May 26, 2020 the Office of the Comptroller of the Currency (OCC) issued the revised “Sampling Methodologies” booklet of the Comptroller’s Handbook. This new booklet replaces the booklet of the same title dated August 1998.
The revised booklet includes good information on sampling; including topics such as:
- A glossary with definition of sampling terms;
- Explanation of the differences between statistical and judgmental sampling, including the appropriate use of each;
- Examples of the application of judgmental and statistical sampling; and
- How to determine population, confidence level, tolerance level, and sample size.
While this booklet is for use by OCC examiners in connection with their examination and supervisory activities the booklet has useful details on the approach OCC supervised institutions may experience as well as some practices institutions may want to consider.