Let’s talk about a better way for small financial institutions to do the BSA/OFAC Risk Assessment.

by georgeoself | Bank Compliance, BSA Anti-Money Laundering, BSA Compliance, Compliance

Back in the day, most of us in small financial institutions were taught some variation of the “Appendix J” risk assessment. That was OK until recently. Now, it’s not really good enough and we think FIs are going to have to do better. We think there are major...

BSA people deserve more time in front of the board

by georgeoself | Bank Compliance, Bank Secrecy New Rules Beneficial Ownership, BSA Anti-Money Laundering, BSA Civil Money Penalty, BSA Compliance, Compliance, Report on Beneficial Ownership

I just finished soul-crushing assignment: develop a BSA training slide deck for the Board.  My instructions: “You only have 10 minutes.  Keep it high level.  It’s all the Board can stand.”  I got it done, but I don’t feel good about it.  I think all I did was...

Undone by a blue Schwinn

by georgeoself | Bank Compliance, Bank Security, BSA Compliance, Compliance, Uncategorized

In 1955, when I was 9 years old, my father moved the family to Detroit, MI from Asheville, NC.  It was a sudden decision.  I came home from West Asheville’s Vance Elementary School one Friday afternoon and the following Monday, I was attending class at Burns...

Community banks and consumer compliance: a new-world co-dependency

by georgeoself | Bank Compliance, Compliance

In the new world spawned by Dodd-Frank and the CFPB, community banks need to exploit every possible revenue possibility.  Not all, by any means, are viable. Of those that are, bank management needs the help of compliance people who have more to offer than knee-jerk...

The Fed has firmly put Compliance Officers in the management loop.

by georgeoself | Bank Compliance, Unfair and Deceptive Bank Practice

Community Bank CEOs now joined at the hip with their Compliance Officers? Yep, and it happened on November 16, 2013. That’s the day the Fed published its new consumer compliance “Risk-Focused Examination Program.” That would be RFEP to you. The ties...

Community banks should start building a risk-focused compliance program yesterday.

by georgeoself | Bank Compliance, Bank Customer Complaints, Compliance, Cost of Non Compliance, Deceptive Advertising, Deceptive Disclosures

Getting ready for your bank’s next consumer compliance exam will require a new, different mindset. Your bank can easily trip and fall over a practice you never noticed — much less thought of as “harmful.” To bankers who have recently been through this new...