Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I take a deep dive into the recent Bankrate DOJ enforcement action in which the company garnered a NPA and for which it paid a total penalty of $28.5 million. We feature a discussion of internal control overrides.
Some of the highlights include:
- What are the background facts of the matter?
- Why should you never name a slush fund “Ed’s Cushion?
- What is the difference between management over-ride of internal controls and abuse of management control override?
- Why is robust accounting required when there is a single source of data?
- What is the straight line from internal controls and accounting to the Board and the audit committee?
- Where was the Audit Committee?
For additional reading see Matt’s blog post Bankrate pays $28.5 million in fraud case on Radical Compliance.