Investment accounting compliance risks
U.S. bank and credit union regulators expect financial institutions to implement robust internal controls for managing the credit, market, liquidity, and operational and legal risks associated with investment holdings.
At the same time, financial institutions face increasing pressure to streamline investment accounting, enhance compliance, and reduce operational risk—all while ensuring leadership has timely and accurate financial data to drive decision-making. Manual processes, reliance on key individuals, and fragmented systems create inefficiencies, regulatory exposure, and reporting delays.
Relevant regulations for investment portfolios
The OCC states:
Like loans, investments are credit extensions involving risks that carry commensurate rewards. However, risks in the investment portfolio should be minimized to ensure that liquidity and marketability are maintained. Bank management must recognize that the investment account is primarily a secondary reserve for liquidity rather than a vehicle to generate speculative profits.
— OCC Handbook (Section 203): Investment Securities
The National Credit Union Administration (NCUA) also emphasizes that a credit union’s board must take full responsibility for investment oversight, ensuring proper reporting structures are in place.
Investment compliance and regulatory requirements can pose operational challenges regardless of institution size, from community banks under $10 billion in assets to large, multinational firms.
The Federal Reserve highlights operational risks as a critical area of concern for institutions engaged in investment activities, noting that:
“Inaccurately assessing or controlling operating risks is one of the more likely sources of problems facing institutions involved in securities and derivative activities.”
Regulators point to these specific operational risks tied to investment accounting and regulatory compliance:
- Inadequate procedures
- Human error
- System failures
- Fraud
Many of these risks can be linked to outdated investment accounting processes, particularly reliance on manual reporting, single employees, and disjointed information systems.