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October 17, 2007

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Deskdude

It appears the forthcoming FACT Act regulations will utilize the increasingly common "flexible risk-based approach" whereby your compliance implementation depends upon "the size and complexity...and the nature and scope of [your institution's] activities". This is an interesting (if controversial) trend worth discussing. Risk-based regulation represents an important acknowledgement that one size does not fit all. It's interesting though that among those who commented on the regulation, "small financial institutions" were highlighted as being likely to desire more clearly prescriptive guidance. (?)

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