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 →

New York’s 504: BSA/AML Requirements You May Want to Start Wearing

If you’re a fashion fanatic and you want to get a jump on what will be hot next season, you’d probably want to look to the current fashion trends in New York. After all, New York, New York is known as one of the fashion capitals of the world. Now, if you’re in charge of BSA/AML compliance at your financial institution, your regulators will not be amused if you’re behind on anti-money laundering efforts, even if your compliance team looks ready to walk the runway. They’ll Continue reading →

The Fair Lending Self-Assessment “Miracle”

Originally published in CU Insight

I’ll admit it: I’m a sucker for a good sports movie. One of my favorites is “Miracle,” the 2004 movie starring Kurt Russell, who plays Herb Brooks, coach of the 1980 U.S. Olympic hockey squad, which (and I’ll try to avoid any spoilers here, but the movie’s title might have given it away already) had a very good run that year.

As I consider where we are today in terms of Fair Lending, there are two scenes from the movie Continue reading →

ACH Fitness: 5 Trouble Spots

Marketers of diet and exercise programs like to point out that their programs target the “trouble spots” of the body. “Trouble spots” generally refer to parts of the body that people typically have a hard time keeping in shape, like the tummy or upper thighs for example. There are targeted workout programs that claim, “just 15 minutes a day of our revolutionary system will give you that flat, toned stomach you’ve always wanted.” And then there are the programs that promise to target all the problem Continue reading →

Are You Getting a Complete Fair Lending Picture?

The human brain is quite amazing. It can take an incomplete image and fill in the gaps to create a complete picture. Research suggests that your brain processes the insertions it makes as if it had actually seen the complete picture. Look at the image on the right, for example.

It may take a moment, but you should begin to see a dalmatian dog sniffing the ground. Although all that’s really there are some black blobs and splatters, your mind fills in the gaps and Continue reading →

Is Your Institution Guilty of These 7 Deadly CTR Sins?

Wrath. Greed. Sloth. Pride. Lust. Envy. Gluttony. They’re often referred to as “capital vices” due to their tendency to lead to other sins.

While financial institutions deal more with money than with morals, there are several mistakes with currency transaction reports that can reflect unfavorably on your entire BSA program. Though CTRs may sound easy in theory, in the real world they can quickly become confusing, and it is important to correct these mistakes before they lead to larger issues.

Take a look at this Continue reading →

Fair Lending Policies Under the Microscope

You don’t have to be a hypochondriac to be a little nervous about waiting for the results of a blood test, especially if you had cause to believe you might have some serious illness. The financial world’s equivalent of a blood test is the Fair Lending examination. Your examiner essentially puts your institution under the microscope to reveal any Fair Lending problems. This can be a nerve-racking experience if you aren’t confident in your institution’s Fair Lending Policy and practices.

Regulatory examiners expect financial institutions Continue reading →

Be Prepared: The Fundamentals of a Solid Disaster Recovery Plan

Besides being trustworthy, loyal, thrifty, and brave, a Boy Scout is always prepared. After all, that’s their motto. Be prepared. It’s a good motto. You may laugh at your former Boy Scout friend who packs an extra heavy sleeping bag and winter clothes to the weekend summer camping trip, but as soon as the dark clouds roll in and the temperature drops 30 degrees, you’ll be wishing you had been a little more prepared. Preparedness doesn’t only apply while camping. Financial institutions face constant risks, and Continue reading →

Have Your Social Media and Eat it Too: Managing Social Media Risk

There are things in life that are really good, until you stop paying attention to their effects. Take donuts for example. Donuts may be one of the best foods ever invented, but if all you focus on is how good they are, the waistband of your jeans will soon be uncomfortably tight. The donut of the financial world is social media. It can be a really good tool to reach out to customers and promote your products and services. However, if you don’t pay enough Continue reading →

The Not-So-Secret Formula For Handling MSB Customers

A good superhero movie isn’t complete without the supervillain. In several superhero films, problems arise when the villain discovers, or stumbles upon, some sort of secret formula that gives superhuman strength, causes a transformation into an aggressively evil creature, or creates some sort of weaponized chemical. Sometimes, like in The Amazing Spider-Man, the villain starts off with good intentions, but his formula for a chemical that will regrow his missing limb goes very wrong. This sounds a lot like regulatory compliance—financial institutions have all the rules laid out in front of Continue reading →