The Policy Doctor: Get Your Policies in Shape

Doctors and stethoscopes go together like french fries and ketchup. You won’t often see one without the other, especially in your annual physical exam. An integral part of every annual physical is the heart exam. Why? Because a healthy heart is a pretty strong indicator of a healthy person. The heart of a financial institution’s compliance program is its policies. Healthy policies usually indicate a healthy compliance program. That’s why, during any given examination, one of the first places a regulator will start is by Continue reading →

4 Issues to Watch for in Your E-SIGN Preflight Check

Imagine you’ve found your seat on the airplane ready to leave on vacation. Everyone gets settled and is awaiting takeoff, when suddenly the pilot announces that the flight crew found some issue with the plane and your flight is now delayed. Your initial reaction would probably be annoyance. However, if you think about what could have happened had the flight crew been lax in their preflight preparations, the delay wouldn’t seem like such a big deal. A small delay is much better than engine failure Continue reading →

Four Debt Collection Deficiencies and How to Avoid Them

“If you build it, they will come,” says the disembodied voice to Kevin Costner in Field of Dreams. Had the voice been talking to financial institutions, it would have said, “if they complain it, examiners will come.” You probably know by now that what consumers complain about, examiners pay extra attention to. Debt collection, for much of the six-year lifespan of the CFPB complaint portal, has been one of the most complained about topics from consumers. And in recent months, debt collection complaints have continued Continue reading →

Lessons from Troubled Restaurants for Financial Institutions

I’ve become a huge fan of a reality show called Restaurant Impossible. It features a host, Chef Robert Irvine, who visits a restaurant in some level of disarray and attempts to completely overhaul it in 48 hours. This overhaul is usually filled with tears and trauma. After all, some of these restaurant owners have worked their entire lives to build their establishment. Some even once experienced tremendous success, but something has gone terribly wrong. Most are months, weeks, or even days from closing. I’ve observed that these Continue reading →

Risk Watch’s 6-Part Take on Consumer Complaints

One of our most-covered topics (especially lately) in our 130+ episodes of Risk Watch is consumer complaints and complaint management. We’ve brought these six consumer complaint episodes out of the Risk Watch Central vault (available through My Risk Inbox) to help you brush up on your complaint management at no charge for the month of October. Watch them here.

Risk Watch 135: State of Complaints

What does your state complain about and how much does it complain? A recent CFPB complaint report covers just that. Ken Agle of AdvisX Continue reading →

BSA/AML Systems Survivor

Imagine two scenarios. In the first, you fly to a beautiful, remote island for a carefree week at an exclusive and all-inclusive resort. You spend the week soaking up sun on the beach, enjoying fine dining, and snorkeling in the crystal clear water.

Now for scenario two. Same beautiful island, but this time, there’s no resort, no gourmet chefs, and no king size bed. In fact, there’s nobody but you. This time you’re stranded. Despite your circumstances, you’re still able to appreciate the beauty of Continue reading →

How to Optimize Your AML System (Without Hiring Sherlock)

One of the defining characteristics of Sherlock Holmes (besides the deerstalker hat and overcoat) is his almost superhuman powers of deduction. In the first Sherlock novel, A Study in Scarlet, Holmes says, “From a drop of water, a logician could infer the possibility of an Atlantic or a Niagara without having seen or heard of one or the other.” In every Sherlock story since, Sherlock does indeed turn tiny, seemingly insignificant details into solved crimes. Now, if you’re tasked with evaluating a Bank Secrecy Act Anti-Money Laundering (BSA/AML) system, you might Continue reading →

Your Top 6 BSA Questions Answered

Bank Secrecy Act (BSA) compliance can be one of the more difficult areas of compliance. Even if you feel like you’ve got a pretty good handle on all the requirements, it’s likely you’re still going to have a few questions, especially when the scenarios get a little more complex (just like in real life). That’s where we come in. Without further ado, here are the answers to your top six BSA questions.

Question 1

Facts: 

In Pursuit of the Well-Written SAR Narrative

Suspicious Activity Report (SAR) narratives can be one of the more problematic areas of BSA compliance. However, not only are SARs an important tool for government authorities to help fight criminal financial activity, they frequently trip up financial institutions in examinations, leading to potentially costly fines and an adverse impact on their reputations, which is why it is crucial to make your SAR narrative as thorough as possible.

Furthermore, if you can get the SAR narrative down, you’ve gone a long way to demonstrating the Continue reading →

What Happens to Your SARs?

Imagine you spent hours and hours in the kitchen carefully preparing meals for someone, only to learn later that, instead of eating those meals, they had ordered pizza, letting your hard work spoil in the refrigerator. You’d probably be steamed. Similarly, you’d probably be a bit peeved if you learned that instead of using your carefully prepared SARs, law enforcement and government agencies simply tossed them in the trash bin out back. After all, financial institutions file a lot of SARs. Nearly a million last year Continue reading →