#compliance

So, in 2012, Citibank paid $158.3 million to settle federal allegations tied to defective FHA loans. In the DOJ’s complaint is a line that still matters. In 2010, Ross Leckie, then a senior leader at CitiMortgage, told staff to “drive this rate down by brute force” to meet a 5% defect target, even as quality-control teams flagged serious loan problems. The goal wasn’t fixing defects. It was fixing the number. That email is quoted in a federal complaint.
Today, the same individual is a Vice President at Fannie Mae. This isn’t about criminal charges. It’s about leadership judgment, tone, and culture.
“Drive it down by brute force” isn’t just a bad line. It reflects a culture where optics beat substance and targets beat controls. That culture is exactly what regulators, taxpayers, and markets expect GSEs to leave behind. It also raises an unavoidable question:
If defect rates were something to be pushed down rather than examined, what else could be getting massaged, minimized, or buried?
This is how systemic failures form. Not from one bad loan, but from leadership that treats controls as obstacles instead of safeguards.
FHFA talks about fraud prevention and data integrity. Culture change gets mentioned a lot too. But culture doesn’t change through training decks or rewritten policies. It changes when leadership changes. Leadership overhaul isn’t about punishment. It’s about credibility. It’s about signaling that the old way of protecting metrics, protecting reputations, and protecting insiders is over.
Because until leadership changes, the culture won’t. And until the culture changes, the same question will linger:
If they were willing to “drive it down by brute force” then, what are they driving down now?
If the culture is broken, the fix starts at the top. Paper trails don’t disappear.
And neither do patterns.

https://shublawyers.com/in-the-news/gainwell-technologies-reportedly-exposes-americans-private-information-overseas/

https://news.bloomberglaw.com/health-law-and-business/medicaid-firm-struggles-to-block-patient-data-from-india-workers

Hey DP,
You know we believe your teams in India are doing the same.
Do our customers know this?
Better clean this up.
Keep on sending those jobs to your friends.
This is what happens.

Numerous UK newspapers picking this one up over the weekend, including The Times, The Daily Mail, and others.

No doubt their risk exposure / scrutiny with the regulators will increase as they continue to offshore UK and USA product roles and resources to India on the cheap. Looking at the numbers cited in their financial reports, JustGiving is a total cash cow!

https://www.thetimes.com/uk/law/article/justgiving-investigated-misled-profit-tips-bdnjdhqnz

https://www.dailymail.co.uk/news/article-15450203/JustGiving-investigated-claims-uses-underhand-tactics-money-donors-order-boost-profits.html

The New York State Department of Labor has confirmed that no wages were reported for my Paramount employment for any quarter in 2025 to any state unemployment system.

Employers are generally required to report wages quarterly for unemployment insurance purposes, which is how states determine benefit eligibility and jurisdiction.

Because I worked remotely, I initially filed in my state of residence and was then instructed to file in New York. New York redirected me back to my state, since unemployment jurisdiction depends on where unemployment insurance contributions are paid.

As of January 9, nearly two months after separation, there is still no wage record in any state, which means no unemployment benefits can be paid. I also did not accept any severance.

I’m trying to understand whether this is an isolated payroll reporting issue or something affecting multiple people.

If you were laid off or separated recently, do you see Paramount wages for 2025 in your state’s unemployment system? If so, how long did it take or who did you contact?

Doesn't affect me I'm in the office 5 days already.

They will be tracking our badges for compliance. Also told that more of the old buildings are being opened up to accommodate.

Question for those that didn't RTO 4 days, what is for status?

https://www.investing.com/news/stock-market-news/cvs-unitedhealth-cigna-accused-of-diverting-billions-via-shell-firms-93CH-4433238

Has anyone had experience with having a meeting with the compliance investigation unit that can give me insight? We’ve had several on our team go through these meetings and end up fired due to our previous manager and it is making our region very nervous. A lot of it is due to changes in leadership and different preferences for documentation. The previous manager that has now left was…. special to say the least. Should those of us with these meetings be worried and start job searching?

Did you know:

NYSE-listed companies must adopt and disclose a code of business conduct and ethics applicable to all directors, officers, and employees, per SEC-approved rules. These rules cover conflicts of interest, compliance with laws, insider trading, and reporting of illegal behavior, and must be posted on the company's website.

Interesting that Jones just rolled this out when this is a requirement for publicly traded companies listed on the NYSE. But we're not for sale, right? I'm sure the timing of the rollout is just a coincidence.

Patient Data Tracking: A class-action lawsuit claims Elevance used website trackers to intercept and share private patient health info with third parties without consent.

Medicare Advantage Fraud: A federal judge allowed a DOJ lawsuit to proceed, alleging the company submitted false data to boost Medicare Advantage reimbursements.

Behavioral Health Denials: A settlement was approved for a lawsuit accusing them (as Anthem) of improperly denying mental health/substance use treatment.

Provider Reimbursement: Subsidiaries faced numerous lawsuits for failing to pay healthcare providers for medically necessary services. Recent Allegations & Lawsuits

I was scheduled for mandatory Compliance Training a few weeks back. Earlier this week, it was cancelled from My Learning. Am i reading too much into it? With the upcoming, ongoing cuts, i cant help but wonder if I was put on the list. Thoughts?

UnitedHealth Group has released findings from multiple independent reviews of its business practices following a June pledge from CEO Stephen Hemsley to conduct a transparent and comprehensive examination of company processes.

The reviews, conducted by FTI Consulting and Analysis Group, examined Medicare Advantage risk adjustment operations, utilization management practices, and Optum Rx’s administration of manufacturer discounts. UnitedHealth has adopted 23 action plans in response, with 65% targeted for completion by year-end and full implementation by March 31, 2026.

Ten things to know:

1. Across all three areas, the auditors concluded that UnitedHealth maintains strong operational controls and documentation. However, a common theme emerged: policy organization, centralization and governance structures need improvement. The risk adjustment review found policies weren’t always codified or recently reviewed; the UM review found corrective actions that weren’t fully remediated; and the PBM review recommended consolidating and streamlining policy documentation.

2. In response to the findings, UnitedHealth said it will ensure all policies and procedures are reviewed and approved at least annually, maintain centralized policy repositories, and enhance enterprise-wide governance structures outlining roles and responsibilities for policy oversight, compliance monitoring and risk assessment activities.

3. FTI reviewed Optum’s risk adjustment diagnostic coding standards against ICD-10-CM guidelines and found the content consistent with official coding guidance. The HouseCalls in-home assessment program received strong scores, with “comprehensive and well-organized” policies and evidence that the majority had been reviewed within the past 12 months.

4. FTI recommended separating coding audit functions from operations. Currently, targeted coding audits directed by Optum compliance are performed by coding resources that report into coding operations rather than compliance. FTI recommended establishing dedicated coding audit resources within compliance itself. UnitedHealth’s action plan confirms it will “establish an independent coding audit team within the broader Optum compliance organization.”

5. UnitedHealthcare holds national NCQA utilization management accreditation with 100% scores. The insurer achieved the accreditation in 2023, which deems its Medicaid and commercial plans 100% compliant with NCQA utilization management standards. When benchmarked against Medicaid peers in external quality reviews, UnitedHealthcare met full compliance in all 12 states examined, scoring 100% on prior authorization and practice guideline standards.

6. Nine of 62 UM audits showed corrective actions that weren’t fully remediated. While 42% of the UM-related audits FTI reviewed had no negative findings, auditors flagged instances where corrective actions from previous audits remained unresolved. FTI found UnitedHealthcare lacks “an overarching control” to ensure full remediation of all audit findings and recommended formalizing a standardized tracking mechanism with dashboards and internal thresholds independent of regulator deadlines.

7. The UM review questioned how quality management is operationalized. FTI observed that while multiple teams have roles in quality improvement for utilization management, “there did not appear to be a documented, centralized process or cross-functional accountabilities” to oversee systemic improvement opportunities. The quality management team’s UM role focuses on maintaining NCQA accreditation rather than leading broader quality improvement activities, FTI found.

8. Analysis Group identified 25 distinct controls in Optum Rx’s manufacturer discount administration. The PBM review concluded that Optum Rx has “built a robust and well-structured governance framework” for collecting discounts from dr-g manufacturers and disbursing them to clients.

9. Optum Rx was advised to improve client reporting on why certain claims don’t generate rebates. While the PBM provides information on claims deemed ineligible for manufacturer discounts upon client request, Analysis Group recommended assessing opportunities to enhance this reporting proactively. The firm also suggested refining escalation processes for manufacturer disputes and non-payment, and evaluating automation opportunities for low-complexity, high-volume processes.

10. All three reviews had limitations. The auditors did not test the effectiveness of controls, did not perform legal analysis, and expressly disclaimed any opinion on legal compliance. FTI’s UM and risk adjustment reviews focused only on current-state policies, not historical practices. Analysis Group noted its PBM review “did not identify deficiencies” but rather “opportunities to further enhance Efficiency

https://www.dol.gov/newsroom/releases/osec/osec20250919

I obtained the language from an offer letter provided to a colleague who was transitioned to Infinite in July. I subsequently had this document reviewed by my employment attorney / father-in-law. His reaction was immediate and unequivocal. Despite the paper transfer, the same employees continue to perform the exact same work they performed at Fiserv, for the same clients, using the same systems and devices, and reporting into the same leadership. Day-to-day direction, supervision, and control remain firmly with Fiserv. A payroll change does not alter economic reality.

Based on these facts, he concluded that this structure exposes Fiserv to extraordinary legal and regulatory risk. Employees who were nominally transferred but remain substantively controlled by Fiserv have clear and actionable claims. This is not a gray area, nor a technical compliance issues, it is a textbook example of form being used to disguise substance.

He further stated that if this model is applied broadly, Fiserv’s potential exposure is staggering. The company could face hundreds of millions of dollars in liability to the IRS for unpaid or improperly allocated payroll taxes, penalties, and interest, in addition to serious exposure under Department of Labor enforcement. Using a third party as a payroll conduit does not insulate the controlling employer from federal tax or labor law obligations.

In his professional judgment, this structure is unsustainable. He believes it is only a matter of time before it draws regulatory scrutiny and becomes public, resulting in significant enforcement actions and reputational damage. No amount of contractual language can override the reality of who controls the work. I understand the initial contract was executed by Frank and Guy, but WTH, 🤦 Mike? Last nail in the coffin?

https://www.dol.gov/newsroom/releases/osec/osec20250919

Does any of y’all know f we can call osha over this situation? We work at a place where second amendment has made employees carry and where we don’t have an outlet to report things to tested leads. I have never seen it this bad and they have not fixed Montgomery from what a relative these tells me. What do y’all thing? Can I?

Have you or someone you know been disciplined for non compliance of RTO rules? Asking for a friend...

NYSDOL currently looking into if Verizon violated NYS WARN laws. Contact the state WARN coordinator with any questions or inquiries:

Statewide Rapid Response Coordinator
Regenna Darrah
New York State Department of Labor
518-457-1143

Want a quick $1.5 million? Just report fraud on Fiserv:

https://www.justice.gov/usao-edmo/pr/united-states-reaches-89-million-settlement-milwaukee-company-accused-improperly

The in office reporting is officially out. For those that work 3 days in office and 2 days remote. Although the expectation is a full 8 hour day, the requirement for in office hours for reporting purposes is 7 hours. Anything below that you’ll get flagged on the reports.

Did anyone catch the question during the AMA event where SM admitted they were seriously considering combining Ops Risk and Compliance? She said she thought it was a good idea and that our peer banks have already done it... Is Compliance done for??

Both NY and NJ have 90 requirements for WARN notices. How is Verizon justifying some NYers staying on until 12/19 while NJers stay on until 2/19?

A company is not always required to provide notice if it offers severance benefits, but it must comply with the WARN Act or state laws for mass layoffs and plant closings. If an employer fails to give the required 60 days' notice under the federal WARN Act, it can provide a severance package instead of notice. The severance package can serve as payment in lieu of notice and may be used to offset any damages the company owes. However, the severance package must be "voluntary," meaning it isn't already required by another law, contract, or company policy.

Key points about WARN Act and severance

WARN Act notice: For qualifying employers, the federal WARN Act requires 60 days' advance written notice for mass layoffs or plant closings.

Severance as pay in lieu of notice: An employer can offer a severance package as an alternative to the 60-day notice period. This package can include pay and benefits for the 60 days.

Offsetting damages: If an employer provides a voluntary severance package, it can be used to offset the back pay and benefits the company would otherwise owe for violating the WARN Act.

Voluntary payments: The severance package must be "voluntary," meaning it's not something the company is already legally required to pay under a separate law, contract, or established company policy. If it is a mandatory payment, it cannot be offset against WARN damages.

State-level laws: Some states have their own "WARN" acts that may require longer notice periods or have different requirements than the federal law.

If an individual is engaged in multiple full-time positions simultaneously during standard working hours (Monday through Friday, 9 a.m. to 5 p.m.), to whom or through what channel should such a situation be reported?

I noticed new items have been added in the expectations. Consider this an official warning that HR can use against you.

• In-office days are expected to be eight hours in the office (i.e., don't come in at all if you can't stay 8 hours, even if you're coming in an extra day more than required).
• Employees who need to leave early for medical appointments or childcare should come in extra hours in-office on other days or "talk with their managers." (like the 3 day requirement, your managers should be able to override it on a case-by-case basis if they document it beforehand).
• Half day PTO of all forms of time away count as in-office days still, even with the 8 hour requirement going forward.

https://www.hcamag.com/us/specialization/employment-law/bank-of-america-faces-lawsuit-over-alleged-unpaid-computer-boot-up-time/554302

This is very interesting read.
I can see Bridget Engle getting fired and Charlie tossed as well for tracking hours of exempt employees and treating them like hourly. I can't wait to see those reports:) Doubt she finds work again not having a college degree, passing herself off as a techie. Carrie and Stumpf had "eight is great", Bridget and Charlie have "8 hours office tracking."

as you can see the complainers and negative feed back people are the ones that are abusers.
MST home dispatch tech use and abuse company assets. They drive 100K-200K bucket trucks to their home and back to their home garage everyday. Big V8 6.3 L engines use a lot of gas and insurance on top. Also, with MST high pay and only have .5 job per tech a day per tech how is that saving company money and liability.
There are rules to follow when joining home dispatch program. Following the rules helps save gas and time and wear and tear on a vehicle used to drive to work and to home. But MSTs abuse this program from driving to the garage every day and dispatching at the garage. Making a stop at the grocery store to grocery shop in the company vehicle before driving home. Not closing your last job at the job site and instead, drive home and being still dispatched on your work ticket and then closing the job when you arrive home. I follow the rules, and I do not want the home dispatch program to go away because of MSTs taking advantage of the abuse. Also, MST managers are favoring many MSTs and letting the home dispatch MSTs do what ever they want. STOP ABUSING THE HOME DISPATCH PROGRAM YOU MSTs. You know who you are...

US Department of Labor has launched an initiative to prevent the abuse by corporations often H-1B Visa program spamming the over hiring of jobs that are displacing US Citizens. The initiative is focused on ensuring that US American Citizens are put at higher priority for skilled labor jobs in technology and healthcare.

Is there a major round of layoffs about to hit the compliance department? Dan Veale, the global head of surveillance was reassigned to a far less prestigious area of ICRM. Jennifer Taylor, the Chief Compliance Officer of a major unit, has not been seen in the office for weeks. She also no longer has anyone reporting to her as per the global directory, of where till recently had. The Jersey City location is filled primarily with compliance officers, of where Citigroup recently fired a WARN Act with the state of New Jersey, that the bank intends to layoff 70 staff in that location the first week of December. In summary, the combination of an official WARN notice for a location housing compliance staff and the apparent elimination or reassignment of two senior compliance executives makes it highly probable that a major reduction in force is targeting the compliance department. Anyone else observing possible pre positioning ahead of a major change?

Is anyone else experiencing massive data and reporting issues for their LOB? An example would be incorrect regulatory reporting sent externally. It feels like the shift higher up to push for automation and restructure is placing health plans at compliance risk. Are we just going all in here despite legal, regulatory, and future RFP risk? This seems obvious as I'm typing, but more curious if others are seeing this.

Has the CEO broken SEC rules on declaring Free Cash Flow on the Q3 Results, after he admits to the employees that it is only there because the company held payments for debts.

Never seen such a clear excuse to use to cut people who arent aware of not being in compliance

The MEG “improved offer” announcement should make a few folks inside CVE uncomfortable. The question investors should be asking isn’t whether the Vawn assets are material to Cenovus, it’s whether the side-deal Strathcona received treats all other MEG shareholders fairly. Because if a private buyer gets a sweetheart deal on sold assets, that’s a transfer of value - plain and simple - and it raises serious questions about compliance with securities-law principles of fair and equal treatment. It’s also striking how the MEG board hides behind its advisors (BMO, RBC) instead of defending its own judgment. “Our advisors told us it was fine” isn’t a fiduciary defense - it’s an abdication of duty. If this ever gets real regulatory attention from the ASC - or even the SEC - the paper trail around valuation assumptions, fairness opinions, and board communications will matter. Until then, rank-and-file CVE employees get to watch leadership pretend the assets were sold at fair value while staff job cuts hang in the balance.

MST home dispatch tech use and abuse company assets. They drive 100K-200K bucket trucks to their home and back to their home garage everyday. Big V8 6.3 L engines use a lot of gas and insurance on top. Also, with MST high pay and only have .5 job per tech a day per tech how is that saving company money and liability.
There are rules to follow when joining home dispatch program. Following the rules helps save gas and time and wear and tear on a vehicle used to drive to work and to home. But MSTs abuse this program from driving to the garage every day and dispatching at the garage. Making a stop at the grocery store to grocery shop in the company vehicle before driving home. Not closing your last job at the job site and instead, drive home and being still dispatched on your work ticket and then closing the job when you arrive home. I follow the rules, and I do not want the home dispatch program to go away because of MSTs taking advantage of the abuse. Also, MST managers are favoring many MSTs and letting the home dispatch MSTs do what ever they want. STOP ABUSING THE HOME DISPATCH PROGRAM YOU MSTs. You know who you are...

So we got all our severance agreement emails. But a friend got a strange attachment sent along with theirs. It’s a list of job titles, ages, and two other columns saying “selected for layoff” and “not selected for layoff”. It has no names or location. So for example it says “Med Asst Lead” and then an age next to it (ex: 25) and then an x under the “selected” or “not selected” for layoff column… It looks like it was an accident and shouldn’t have been sent to them. But I find it very strange that they included the age but no name or location

If you were one of the people that did download the list, I received an email from Cybersecurity letting me know I broke policy by accessing sensitive information. They only asked to respond back to confirm any copies have been deleted, and if you distributed the list, to let them know where you shared it. My director was CCd on the email, but they didn’t think it was a big deal and moved on. There will only be action taken if you don’t respond to the email.

Are we just not even going to pretend to be a compliant & sound bank? Has USAA just given up on quality leaders, innovation, member focus and truly caring about its employees. We’ve gotten so used to scraps around here, when id--ts with a title makes greed based decisions we all just nod and clap. This place will have a day of reckoning. When and how bad, who knows. My prediction is lights off and news cameras we wake up to randomly one morning.

I have worked closely with RCSA. I have a pretty broad view where we are from a quality standpoint.

It is mostly trash and too high level. Where is audit? Better question, where is Wells Fargo Compliance?

This bank will be back in the news within 4 years. This isn’t risk management. I don’t know what to call it. Investment in a process that results in deterrence?

I've heard through the vine that folks with longstanding and easily proven medical accommodations - the accommodations are being reviewed or terminated. The federal ADA states that the employer can periodically review an existing, but not terminate. Has anyone experienced this?

AT&T’s latest masterclass in self-sabotage: spend millions attacking T-Mobile, violate NAD rules, and get slapped with a cease-and-desist.
You’d think someone in legal or marketing would’ve caught that — maybe the one competent person who actually reads compliance documents.

But that person got RTO’d to Dallas or Atlanta five days a week, fighting for a seat, dodging “collaboration days,” and wondering why their life turned into a bad sitcom.
Meanwhile, the yes-men who approved this ad are sipping coffee in their corner offices, calling this fiasco “brand momentum.”

Let’s be honest — we’re not #1 in customer service or innovation.
We’re #1 in wasting money. We should be a Harvard Business School case study on how to find new ways to burn cash and call it a strength.
Only AT&T could turn a marketing campaign into a compliance violation and call it “forward-thinking.”

Now the ad’s gone, the money’s gone, and morale’s in free fall — but hey, at least leadership gets another “All-Hands” meeting to tell us how proud they are of the team.