Private Sector Professional Experience

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Representative Engagements


  • Conducted numerous, comprehensive, reviews of enterprise risk management practices for institutions ranging in size from $2 Billion to $1 Trillion. These engagements included reviewing all aspects of enterprise risk management, across all risks, to include culture and tone at the top, governance and structure, risk measurement, monitoring and reporting and management, control and mitigation, and independent review functions.
  • Advised and assisted the implementation of enhancements to enterprise risk functions, in whole and in part, of numerous financial institutions, including:
    • Enterprise risk frameworks;
    • Development of risk appetites and supporting tolerance and limit structures;
    • Board and management governance and oversight;
    • Structural realignment of roles and responsibilities to ensure proper stature and independence;
    • Risk control and assessment programs and processes, and risk measurement metrics and KRIs;
    • Board and management level risk reporting and risk dashboards;
    • Quantitative risk measurement, Economic Capital, Stress Testing, and Model Risk Management;
    • Capital and liquidity assessment planning and contingency planning; and,
    • Independent review functions (Audit, credit risk review, model risk review, etc.).
  • Performed gap analyses of large financial institutions’ compliance-management programs, policies, and procedures to identify gaps relative to the expectations of the federal banking regulators and CFPB. Reviews covered the institutions’ processes for managing consumer complaints, issue resolution and remediation, fair-lending compliance, the adequacy of UDAAP procedures, and compliance with federal consumer laws and regulations.
  • Assisted several financial institutions under intense compliance scrutiny from regulators in developing and implementing comprehensive enhancements to their compliance programs. Recommended detailed action plans acceptable to the banks’ regulators, and assisted bank management with the implementation of the action plans to substantially strengthen both corporate and business unit compliance programs. In addition, advised and assisted the negotiation of required redress to customers.
  • Reviewed the business practices of financial institutions for potential UDAAP or practices issues, focusing on credit add-on products, marketing, product structure and pricing, and collection practices. Also provided advice on supervisory expectations.
  • Advised and assisted several commercial (non-bank) entities with subsidiary banks and ILCs in dealing with “sanctity of bank”, affiliate reliance, and affiliate risk management issues.
  • Advised and assisted the implementation of complaint risk management and issue management, prioritization and remediation processes for use in both business and risk management.
  • Advised numerous institutions on regulatory risk (safety and soundness, and compliance) remediation and regulatory relations strategies. Many resulted in the avoidance of formal enforcement actions while others resulted in timely restoration of satisfactory condition and removal of enforcement documents as well as much improved regulatory relations.

About David D. Gibbons & Company

Banking, Bank Supervision, Regulation and Enforcement, Troubled Institutions, Regulatory Relations, Credit and Credit Risk Management, Enterprise Risk Management, Bank Safety and Soundness and Compliance Risk Matters

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