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...
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...
by georgeoself | BSA Compliance, Compliance, Cost of Non Compliance, Deceptive Advertising, Uncategorized, Unfair and Deceptive Bank Practice
Here’s a blinding glimpse of the obvious: there are a slew of marketing concepts that would be very attractive to bank customers. However, before a bank can kick off a new program, it needs to know if the new concept will comply with the State and Federal consumer...
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...
by georgeoself | Bank Customer Complaints, Bank Security, BSA Compliance, Compliance, Cost of Non Compliance, Deceptive Advertising, Deceptive Disclosures, Unfair and Deceptive Bank Practice
The next big thing in bank compliance. You heard it here first: banks will be going on the offensive to solve their customer’s security problems by launching “Customer Security Portals” and “Customer Feedback Portals.” Banks are making...
by georgeoself | BSA Compliance, Cost of Non Compliance, Deceptive Advertising, Deceptive Disclosures, Unfair and Deceptive Bank Practice
Protect your bank from adverse UDAAP exams with these 4 steps. The regulatory, reputational and financial risks posed by an adverse result from an Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) examination are significant – no, make that VERY significant....
