Next Level Risk-Based Pricing is Coming: Beyond Decisioning and Pricing is Outcome Analysis

When economic times are good and funds are relatively easy to lend without meaningful short-term risk, most financial institutions find themselves in strong positions from a credit risk and earnings perspective. Yet, the tough lessons of lending and risk over the past 30 years have taught us many times over that economic cycles repeat. It’s an all-too-often forgotten pattern that reminds us that good times, which always seem to feel like they are here to stay, only last so long.

Each of the major economic Continue reading →

Compliance Abhors a Vacuum – If the Void Is Filled with Heightened BSA Scrutiny, Would You Be Ready?

Originally appeared in CBIZ Insights

While a climate of regulatory relief sweeps across the industry, it is a prudent compliance officer who keeps both feet on the ground and considers what risks such a climate could possibly present. Beyond awareness that regulatory enforcement is cyclical and subject to potentially rapid changes based on external or internal events, there’s another potentially more-immediate threat to consider.

Although some areas have been removed from the regulatory playing field by new thresholds, that doesn’t mean regulators go away until Continue reading →

How Would You Describe the Complaint Management Process at Your Institution?

Find out how you could have free ongoing access to AffirmX’s complaint management solution.

Would you describe the complaint management solution at your financial institution as (a) hopelessly complicated, or (b) something you make up as you go? We hear from more and more financial institutions that examiners are looking at how they’re set up to handle and document consumer complaints.

AffirmX has a solution that will help you not only handle the complaint from receipt to resolution, but provide you with documentation of Continue reading →

To Keep or To Shred: Introducing the 2018 Record Retention Schedule

See below for information about how to get a free copy of the newly updated 2018 Record Retention Schedule

To shred, or not to shred – now that is the real question. Whether ’tis nobler in the mind to suffer the slings and arrows of an examiner who finds you shred too soon, or to take arms against a sea of records that threaten to swallow you.

Relatively speaking, when it comes tough decisions, Hamlet had it easy compared to today’s compliance officer, who has Continue reading →

In Search Of Compliance Independence From Your ISO? (Good Luck With That)

In banking, disclosures matter, especially when it comes to credit cards. The rules, and they are not a few, are specifically spelled out in great detail. Where it can get a little fuzzy is when third parties enter the equation. This is especially true with third parties known as independent service organizations, or ISOs, as Mid America Bank & Trust Company, located in Missouri, found out late last year.

ISOs may purchase charged-off or past-due consumer debt from financial institutions, then issue the consumer a Continue reading →

What Did Rabobank Do to Deserve a $50 Million Penalty?

Everyone knows that complying with Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations is a must. However, for this California bank, their deficiencies cost them a $50 million penalty by the Office of the Comptroller of the Currency (OCC). Let’s see where they went wrong.

Rabobank, N.A., of Roseville, California was subject to a cease and desist order on December 5, 2013 for deficiencies in their BSA and AML compliance program. The consent order and recent penalty assigned on February 7, 2018 were Continue reading →

Fighting the Continuing SAR Battle

Our most popular blog posts are about writing a knockout SAR narrative (you can find part one here and part two here). But when reviewing suspicious activity reports, we’ve noticed a large number of issues associated with fighting battles known as continuing SARs. As such, it seems that a guide to winning a continuing SAR battle is judicious.

What Is a Continuing SAR?

When a financial institution identifies a suspicious activity, it must file a suspicious activity report—or SAR. But if it later finds additional suspicious activity related to Continue reading →

Figuring Out What to Say and How to Say It to the Board of Directors is Like Balancing on a Bicycle

“Life is like riding a bicycle. To keep your balance, you must keep moving.”

-Albert Einstein

Successfully riding a bike to get where you want to go requires patience, knowledge, and experience. Determining what to say to your board of directors is like learning how to balance on a bicycle. The “what to say” is like leaning and pedaling on a bike. If you lean too far to one side or the other, you’ll fall off. If you pedal too Continue reading →

Three BSA/AML Errors to Avoid

Bank Secrecy Act and Anti-money Laundering (BSA/AML) enforcement is shaping up to be a hot compliance topic this year. We’ve heard from the NCUA that one of its supervisory priorities for 2018 will be BSA compliance. There are also some big changes coming in just a few months with FinCEN’s new customer due diligence and beneficial ownership requirements. What all this means is that you’ll want to pay particularly close attention to your BSA/AML program and procedures throughout 2018. To ensure your AML program is Continue reading →

The Wheels on the BSA Go Round and Round: In Pursuit of the Well-Written SAR Narrative (Part 2)

Consider your BSA program as one of the wheels that supports the vehicle that is your compliance program. Within this wheel, there are several smaller components—the rim, axle, and spokes could perhaps be considered due diligence, training, and suspicious activity monitoring. For BSA, one of these crucial pieces is the suspicious activity report (SAR) narrative.

SAR narratives can be one of the more problematic areas of BSA compliance, but they are also an important tool for helping government authorities fight criminal financial activity. Missing, faulty, Continue reading →