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FinCEN Issues Statement to Cultivate BSA/AML Innovation

Adam Witmer
BSA, Regulatory Update

On December 3, 2018 FinCEN and the joint agencies released an advisory to encourage and support the implementation of responsible innovation and new technology in the financial system.  The advisory encourages banks and credit unions to take innovative approaches to their Bank Secrecy Act (BSA) programs for combating money laundering, terrorist financing, and other illicit financial threats.  

Conducting BSA Board Training

Conducting BSA Board Training

Adam Witmer
BSA

This Compliance Clip (video) provides a number of practical tips on how to execute a good BSA training session for your Board of Directors. Adam provides three main things that could be included in Board training and explains several best practices for ensuring an effective training session. The video concludes by discussing a valuable resource that may assist some BSA Officers in training their Board.

FDIC Proposes to Rescind Annual Disclosure Statement Requirements

Adam Witmer
Regulatory Update

On October 25, 2018, the Federal Deposit Insurance Corporation (FDIC) issued a proposed rule to rescind and remove its regulations relating to the disclosure of financial and other information by FDIC-insured state nonmember banks. Upon the removal of the regulations, applicable FDIC-regulated banks would no longer be subject to the annual disclosure statement requirement found in those regulations. The financial and other information that has been subject to disclosure by individual banks pursuant to these regulations is publicly available through the FDIC's website.

5 Tips for CRCM Test Prep

Adam Witmer
Compliance Management

The CRCM certification (Certified Regulatory Compliance Manager) is arguably the most well respected and highest certification a compliance profession can achieve.  And for good reason. In order for you to just qualify to take the CRCM, you must be a banking professional with at least six years as a compliance professional within the last ten years (three of which need to be within the last five years).  Alternatively, you can qualify with only three years of experience if you also have met two of several different requirement options. Furthermore, you must be a compliance professionals with “management” experience overseeing the “full range of compliance risk functions.”  

HMDA Partial Exemption Resources

HMDA Partial Exemption Resources

Adam Witmer
HMDA

In this atypical Compliance Clip (video), Adam explains why those who qualify for the HMDA partial exemption will probably want to use it as quickly as possible. He also manages to relate one of his most embarrassing stories to HMDA.

CFPB Finalizes Amendments to Regulation P

Adam Witmer
Privacy

Over two and a half years after the privacy laws were amended by Congress, the CFPB has finalized the revisions to Regulation P.  This final rule affects financial institutions that do not share nonpublic information to third parties, though financial institutions who do share information will see little changes to their existing practices.  The final rule was released on August 10, 2018 and will become effective 30 days after publication in the Federal Register.​​​​​​​

This executive summary provides an overview of the changes which can be shared with management.

OCC Updates and Rescinds Booklets

Adam Witmer
Regulatory Update

On June 28, 2018, the OCC revised several booklets from their Comptroller’s Handbook. The revised booklets include “Bank Supervision Process,” “Community Bank Supervision,” “Compliance Management Systems,” and “Large Bank Supervision.”  In addition to these booklet revisions, the OCC has rescinded several booklets for various reasons.

BSA Statement of Loan Purpose

BSA Statement of Loan Purpose

Adam Witmer
BSA

In this video, Adam discusses the BSA record retention requirements for obtaining a clear statement of purpose on certain loans. Adam explains the requirement in detail including which loans the rule applies to, common errors, and best practices to ensure compliance.

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