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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...

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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...

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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,...

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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. ...

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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...

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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...

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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...

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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...

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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....

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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...

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