Some people might think that regulatory attention to the BSA has let up over the past couple of years, given other difficulties and areas of concern, such as fair lending, TRID, HMDA, and UDAP. Think again. With the safety and soundness of the entire industry the focus of news stories every day and many well-publicized enforcement actions, the regulators obviously haven't eased up. These rules are still very close to being the #1 issue facing compliance officers.
In Part 2, we’ll discuss the Customer Identification Program (CIP) rules, other BSA reporting, including funds transfer recordkeeping, PEPs, pouch rules, and the Office of Foreign Asset Control (OFAC) regulations.
We'll also talk about where the risk areas are and where examiners are criticizing institutions. Your comprehensive program must be continually updated, and we'll make sure you have the information you need to meet expectations.
- Funds transfer recordkeeping - more information collection
- OFAC rules – who and what to screen?
- Blocked & rejected transactions - what's the difference and how do I know which to do?
- Additional USA Patriot Act requirements, such as 314(a), PEPs, and Pouch activities
- Identifying customers and maintaining proper evidence under CIP rules
- Regulatory reorganization of BSA rules
- FinCEN hotspots and areas for review
- And more
Who Should Attend:
These rules impact most anyone in your institution who has direct dealings with customers, such as Customer Service Representatives and tellers. But others are impacted as well, like loan officers and others who make important customer-related decisions. Compliance officers, auditors, attorneys, and management too will benefit from this information, as well, as they often are the ones who must draft these complex programs, administer them, and audit them.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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