2016 is just about gone, but there’s still just enough time to look back and see where you’ve been. Here’s a look back at the top 5 most popular blog posts of 2016.
Although it’s now been a few months since we first heard about all the troubles at Wells Fargo, the fallout is still continuing. This should be a reminder to all institutions that reputation risk is a serious business. Failure to manage this risk can have heavy, long-lasting consequences. So Wells Fargo’s mistakes can teach us some valuable lessons… Continue reading.
2. The ADA Hurdle Your Institution Might Still Need to Clear
In 1990, before we used computers for nearly everything, Congress passed the Americans with Disabilities Act, or ADA. The act ensured that people with disabilities would have the same opportunities as everyone else. In the past few weeks, banks and credit unions have begun receiving demand letters from a law firm in Pittsburgh that has filed dozens of website lawsuits in federal district court contending that defendant’s websites are not accessible to blind and visually impaired consumers. As this is an increasing concern in courts and with the DOJ, financial institutions need to make sure their accessibility accommodations don’t fall behind… Continue reading.
3. Ignorance is Not Bliss: TCPA Risk Assessment
Despite the recent buzz about the TCPA and the FCC’s Ruling back in July 2015, some financial institutions have been ignoring their TCPA risk assessment and compliance measures, perhaps based on some faulty assumptions. Financial institutions may have a variety of excuses for why they think they don’t need to worry about their phone call compliance. And while it’s true that maintaining perfect compliance can be very tricky given all the different types of communication technology we use, institutions should not make the mistake of thinking TCPA rules don’t apply to them. Here are six things you need to know about the rule so you can keep your compliance up to date… Read more.
At present, banks and credit unions are not required to know the identity of the individuals who own and/or control their legal entity customers or members. FinCEN and the federal law enforcement agencies have long seen this as a weakness in the BSA/AML programs that financial institutions are required to administer. So, FinCEN came up with a new rule to combat that vulnerability. Effective July 11, 2016, FinCEN’s new rule is designed to address this concern by requiring financial institutions to look beyond the legal entity itself and to identify the individuals who own and/or control these legal entities. The rule requires that financial institutions establish and maintain written procedures that are designed to identify and verify the beneficial owners of their legal entity customers/members. In order to meet this requirement, you must know what FinCEN means when it talks about beneficial owners and legal entities… Read more.
An effective complaint management program is a key part of a strong compliance management program. Complaints can uncover a variety of consumer compliance violations as well as policy, procedure and training weaknesses. It is common to look at complaints as a negative, but a financial institution can use complaint trends to detect problems, determine risk levels, and develop strategies. Having a proactive approach to the issues uncovered during the complaint resolution process can improve overall compliance management as well as the examination experience… Read more.