Bankers Blog
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BSA Risk Assessments
The idea behind having a BSA Risk Assessment is to break down your bank’s BSA/AML risks into smaller, more manageable parts. There is no specific methodology which means that each bank’s risk assessment can, and likely will, look different. No two banks are the...
HMDA: What’s a Purchase?
HMDA banks are required to collect and report data regarding applications for dwelling-secured loans or lines where the purpose is to: Purchase a Dwelling;Refinance a Dwelling;Improve a Dwelling; orHome Equity (consumer purpose). So, what is a “purchase” for...
Regulation CC: What’s Covered?
When it comes to Regulation CC, you must know what’s covered. A common misconception is that Regulation CC is a consumer regulation. It’s not. Regulation CC applies to demand deposit accounts, which can be held by consumers and non-consumers (entities, clubs,...
BSA/AML & Crypto/Virtual Currency
Be sure to JOIN US for our webinar, “BSA/AML: Crypto/Virtual Currency.” Crypto/Virtual currency is growing by leaps and bounds and is becoming more prevalent and mainstream. If you haven’t seen it pop up yet at your institution, it’s probably only a matter of time. ...
BSA/AML & Customer Due Diligence
Be sure to JOIN US for our webinar, “Customer Due Diligence Programs & Beneficial Owners” In our December 2021 Monthly Connection, we discussed the FFIEC’s December 1, 2021, updates to the BSA/AML Examination Manual. While the updates weren’t major, they did...
Truth in Savings: CD Renewal Notices
When it comes to renewal notices for your certificates of deposit, there are actually a lot of “ifs” that can come into play. Those “ifs” dictate not only when a notice is required but also what information needs to be included on the notice. These notices...
TRID Guidelines: Shopping Disclosure
The TRID Guidelines are often a big player when it comes to the life cycle of a mortgage loan. There are timing requirements to meet, disclosures to complete, and so much more. One of the main purposes of TRID is to get accurate “shopping disclosures” into...
FinCEN Issues NPRM for SAR Pilot Program
On January 24, 2022, FinCEN issued a Notice of Proposed Rule Making (NPRM) regarding the establishment of a pilot program for financial institutions to share Suspicious Activity Reports (SARs) and related information with foreign branches, subsidiaries, and...
Initial Escrow Account Statement Timing
When you establish an escrow account to pay a borrower’s taxes, insurance, etc., you must provide them an Initial Escrow Account Statement. Generally, this is given at loan closing, but it can technically be provided after closing and still be compliant....
Compliance vs. Marketing
Be sure to JOIN US for our webinar on “Advertising”. Compliance officers are typically left-brained people. They are analytical, linear thinkers who like facts and logic. Marketing personnel is often the exact opposite. They are right-brained and are typically...