Compliance Monitoring Plan (Example / Template)

for New Card Credit Marketing

Review Period: 1st January 2019 - 30th March 2019

1) Terms of Reference

Risk & Compliance Committee New Product Committee Working Group – New
Credit Card
Senior Management Committee

2) Distribution List

To: Risk & Compliance Committee, Senior Management Committee, New Product Committee Working
Group – New Credit Card, Senior Management Committee

Cc: CEO, Head of Compliance, Head of Internal Audit

3) Dates & Resources

New marketing & advertisement materials 1st March 2019

Training materials and records (staff attendance 5th March 2019

and assessment)

Customer complaints and feedback log 10th March 2019

Policy & procedures for credit card marketing 12th March 2019
(retail banking)

Account opening and clients’ profiles 15th March 2019

4) Deliverables & Reports

Initial draft review report by Compliance 20th March 2019

Discussion over findings with business 25th March 2019

Final report by compliance 1st April 2019

5) Previous compliance monitoring results, risk events or breaches, internal audit reviews, regulatory
inspection report (if any)

Not applicable (New credit card)

6) Executive Summary
 • To assess whether the marketing materials of our new launched credit cards comply with
regulatory guidelines by the MAS.
• There have been a recent steady increased in number of complaints from customers who alleged
that they were misled by the marketing materials to sign up for the new credit card.

7) Objectives:
• The purpose of the review was to ensure that all our marketing materials for our newly launched
credit cards comply with the regulatory guidelines. This includes marketing materials in the forms
of brochure and online, through our Bank’s websites.
• The other purpose is to review the marketing materials to reduce misleading and complaints of
customers.

8) Scope:
• The review will only cover on the newly launched credit card products in the retail banking
segment.
• The review will exclude private banking and commercial clients.
• The marketing materials and customers complaints sampled and reviewed will be within the period
of Q1 2019.

9) Methodology:
i. Review both online and hardcopy marketing materials of the newly launched credit cards to
ensure no misleading terms used in the materials and the marketing materials follow MAS
regulatory guidelines under:

• MAS Banking (Credit Card and Charge Card) Regulations 2013

• MAS Notice 635 Unsecured Credit Facilities to Individuals.
• MAS Guidelines on Issuing Credit Cards
• MAS Guidelines on Standards of Conduct for Marketing and Distribution Activities

ii. Screening of marketing materials will be performed through desk basked monitoring and
interviews with staffs involved in the designing of the marketing materials.
iii. Investigating a sample of complaints on misleading marketing materials by clients to find out
exact misleading terms used in the brochure and online marketing materials.
iv. A random sample of 20% of the total number of complaints will be selected for review and
when necessary, interviews with clients may be conducted to further understand the
misleading issues.
v. Sample will be selected from the total number of complaints on marketing materials for credit
card only. The period of complaints will fall between Quarter 4 of 2018 to Quarter 1 of 2019

10) Risk Monitoring & Control Assessment

The purpose of the review was to review customer complaints on marketing materials for newly
launched credit cards and ensure that all marketing materials for the newly launched credit cards are
in line with the regulatory guidelines.

Controls that are adequate and effective in managing risks result in a high (strong) control rating
whereas controls that are inadequate or do not mitigate the risk result in a low (weak) control rating.

Control Rating Definition

1 Control not present or significant weaknesses in controls identified
2 Some controls exist but does not fully mitigate inherent risk or control not
performed adequately
3 Control exists and is performed adequately and largely mitigates inherent
risk
4 Control fully mitigates inherent risk; automated system has embedded
preventative and detective controls which are known to be robust
1) Detailed findings, recommendations and corrective plans

Findings Recommendation Owner and due date

1. Staffs in marketing 1.1 Ensure that all staff to 1.1 Department to list down
materials department do undergo compulsory the relevant training
not have the relevant proper training before programs and to go a skill
experience and do not discharging their gap test to shortlist staff
have sufficient training for responsibility and to go for that needs to go for the
the role compulsory refresher training. Attendance of
course. the training needs to be
Control rating: 1 (Current) 1.2 Hiring manager to ensure taken. These needs to be
next new hire has the properly and clearly
relevant background and documented.
experience.
Target Date: 15th June
2017

Manager Responsible:
Retail Marketing
Department Manager &
HR

1.2 Request human resource

department to do a more
stringent screening of
potential candidate to
ensure that we interview
and shortlist the right
candidate with relevant
experience and skills.

Target Date: 31st May 2017

Manager Responsible:
Retail Marketing
Department Manager &
HR

2. Complicated terminologies 2.1 Implement 4 eye checks 2.1 Carry out random
identified in the marketing before approving the interviews/ surveys with
materials marketing materials (Eg. general public to ensure
Maker and Checker) and that understand the terms
Control rating: 2 (Current) ensure independency of used in the draft
both roles. marketing materials. Edit
2.2 Conduct random where necessary and
interviews/ surveys to repeat process until final
check on public’s marketing materials is
understanding of the accepted and validated
marketing materials before
launching the marketing Target Date: 31st July 2017
materials
Manager Responsible:
Retail Marketing
Department Manager
Findings Recommendation Owner and due date
3. Ambiguity in the usage and 3.1 Implement 4 eye checks 3.1 Department to list down
explanation of terms before approving the marketing the relevant training
stated. Omission of critical materials (Eg. Maker and programs and to go a skill
information eg, interest Checker) and ensure gap test to shortlist staff
rates, penalty charges independency of both roles that needs to go for the
training. Attendance of
3.2 Conduct random the training needs to be
interviews/ surveys to check on taken. These needs to be
public’s understanding of the properly and clearly
marketing materials before documented
launching the marketing
materials Target Date: 15th June
2017

Manager Responsible:
Marketing Department
Manager & Compliance
Department

3.2 Carry out random

interviews/ surveys with
general public to ensure
that understand the terms
used in the draft
marketing materials

Legal to assist to edit

where necessary and
repeat process until final
marketing materials is
accepted and validated

Target Date: 31st July 2017

Manager Responsible:
Marketing Department
Manager & Legal &
Compliance Department