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 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...
by georgeoself | Compliance
BDOs pretty universally refer to compliance officers as “Compliance Nazis.” They whine that the “compliance people won’t let us do anything.” I think I know why this happens, at least most of the time: Bank sales people, including BDOs...
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...
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...
by georgeoself | Compliance
Who knew? The CFPB is a favorite whipping boy for banks of all stripes. As a child of Dodd-Frank, the CFPB is not exactly on the Christmas card list of most bankers. But, the new mortgage disclosure forms look like genuine progress to me. And, the bonus is the clear...
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...
