COVD-19 Vaccine Fraud

In case you missed it, FinCEN issued a Notice alerting institutions about potential fraud related to COVID-19 vaccines on December 28th.  Such fraud might include trying to sell unapproved/illegally marketed/counterfeit vaccines and/or the illegal diversion of legitimate vaccines.  There have already been offers to expedite vaccine delivery in exchange for a fee and ransomware targeting vaccine research.  Institutions should be on the lookout for fraud related to developing, distributing and/or administering COVID-19 vaccines.

Institutions that file SARs related to vaccine-related scams and cyberattacks should:

  • Note “FIN-2020-NTC4” in Field 2 (i.e., Filing Institution Note to FinCEN) and the narrative;
  • Select Field 34(z) (i.e., Fraud – Other); and,
  • Indicate vaccine scam or vaccine ransomware, as applicable, in SAR Field 34(z)

Further details should be provided in the narrative such as, how the victim was contacted and/or how the victim provided/tried to provide payment information, if known.  In addition, you should provide any information on IP addresses and/or phone numbers.  Institutions should also refer to the “Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments” and the “Notice Related to the Coronavirus Disease 2019 (COVID-19)”, as applicable.

Find more BSA Information here –


2021 Thresholds

With 2021 still feeling pretty new, do you ever start to think, “what did I forget”?  Something that can slip through the cracks are the regulatory threshold changes that generally take effect on January 1st each year.  These thresholds are used to determine whether certain compliance requirements apply to your financial institution.

Here’s a quick list (not all-inclusive) of some common ones:

Regulation Z

Loan Amount Exemption to determine if a loan is subject to Regulation Z

High-Cost Mortgage (Points & Fees)

Loan Amount Exemption for special appraisal requirements on Higher-Priced Mortgage Loans

Qualified Mortgage (Points & Fees)

Qualified Mortgage (Small Creditor Asset Size)


The asset-size threshold is one piece to determining if your financial institution is subject to HMDA.


Asset-size thresholds for small, intermediate small and large banks/savings institutions.

For more information on these threshold changes, refer to the January edition of our Banking on BCC Magazine.


FREE Lending Q & A

Do you have burning questions related to lending compliance?  Struggling with TRID, HMDA, Fair Lending, etc.?  If so, we’d love to have you join us on January 26, 2021, for our FREE Lending Q & A Forum where we’ll answer questions such as:

Question:  Are we required to document all the different ways an applicant can provide intent to proceed?

Answer:  We do believe it’s a good idea to formalize how you will accept the intent to proceed to help ensure consistency among your lenders.  The regulation allows applicants to give you the intent to proceed in any way they choose, unless you require a certain method.  If you don’t limit the ways someone can give you the intent to proceed, we would recommend your procedures simply reflect that applicants can provide intent to proceed in any way they choose.

Question:  When we match a rate from a competing institution, what kind of documentation are we required to keep?

Answer: There really aren’t any guidelines that address this specifically.  At a minimum, we believe a loan officer should simply document the reason(s) for any exceptions and/or pricing decisions that were made/given.  More specifically, spell out very clearly “why” the rate given doesn’t match the rate sheet or loan policy.  Lenders should be sure to check with their compliance officer/management to ensure any institution-specific requirements.

Register for the Forum on our website and then start pre-submitting your lending questions to (please put “January Forum” in the subject line).  We will answer as many of your questions as we can during the allotted hour.

See you there!!


Get Answers to Your Compliance Questions

Do you ever have trouble finding answers to your compliance questions? 

Do you get stuck and can’t figure out what box to check or what disclosure to give?  

Do you just want to run an idea by someone or need advice on how to handle an issue?

If so, where or who do you turn to for help?

We all need a “lifeline” sometimes and Banker’s Compliance Consulting can be that for you.  We offer phone/email/live chat support for your burning compliance questions and provide consultation on best practices and the latest regulatory issues.  Reaching out to an expert not only helps you save valuable time but it also gives you peace of mind! 

Let us make it simple, getting set up is easy! 

Just contact our office and let us know you’d like to be a phone/email client.  All we need is your contact information and billing address.  Once you’re set up, ask away! 

Our goal is to get you an answer within four hours (during normal business hours).  Your time is valuable!

We also offer phone/email/chat retainer packages. Get it into your 2021 budget now!

Are you ready to have a partner in your compliance journey?

Find out more here –


BSA Charity

On November 19, 2020, the Agencies issued a Joint Fact Sheet on Bank Secrecy Act Due Diligence Requirements for Charities and Non-Profit Organizations (Joint Statement).  The intent of the Joint Statement was to provide clarity to financial institutions in determining how to handle charities and other non-profit organizations (NPOs) from a customer due diligence (CDD) perspective.  As a result of the 2016 CDD Final Rule, some charities reported difficulty obtaining and maintaining banking services, so this Joint Statement provides a little more clarity on what exactly the expectations are. 

It is important to note that the new guidance does not change any requirements under the Bank Secrecy Act. 

The Joint Statement does emphasize –

the U.S. government does not view the charitable sector as a whole as presenting a uniform or unacceptably high risk of being used or exploited for money laundering, terrorist financing (ML/TF), or sanctions violations.” 

There are of course risks that need to be evaluated, but they vary depending upon the circumstances surrounding the individual NPO.  This statement is also consistent with the general theme that banks should mitigate and manage their relationships as opposed to closing accounts to avoid risk in general.

In general, financial institutions are required to apply a risk-based approach to CDD and develop risk profiles for all their customers, including NPOs.  Depending upon the facts and circumstances for each individual relationship, NPOs should be evaluated for their particular ML/TF risk and the CDD should be modified as appropriate.  Numerous factors can impact the risk associated with an NPO and the guidance provides a list of things to take into account when assessing the risk.  The Joint Statement includes a listing of customer information that could be useful in establishing the customer risk profile as well as resources for evaluating specific organizations.

If you need training on BSA-related topics, we have several webinars coming up in the coming months as well as, a wide variety available OnDemand.

Find more Free BSA Tools here –