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The Rules of Risk
Understanding the risk assessment process for
building
strong BSA/AML/OFAC programs
by Bill Koch, Editor, The Compliance Advisor
There is always
that one person you know you can count on when it comes time to install that new
computer or plasma TV. That is the person who actually reads the directions and
can make that new piece of equipment work properly.
Community
banks and credit unions have also been given directions — to assess risk and
build compliance programs based upon that risk. But these guidelines have been
written with national banks in mind. They use examples that pertain mostly to
the big, more experienced guys.
[ Read More ... ]
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Risky business
Trey Sullivan |
There
is no activity more disruptive for members of the financial services industry
than preparing for an audit. Most federal guidelines for assessing business risk
focus on "big bank" scenarios, but smaller institutions and community banks must
also perform detailed risk assessments. This month’s
feature article provides some practical
tips to follow in assessing risk in accordance with federal guidelines.
Last
month, we asked how you would deal with a branch manager who consistently
accepts documentation outside of your procedures.
Your responses showed the manager needs to be confronted, but you differed
greatly on how to do it. This month, we ask how you are dealing with recent
changes in the CRA. Are you revamping your program or sticking with the way
you’ve always done things? We need
your best advice.
To keep
this material relevant to you, I invite you to become actively involved with
this newsletter. Please send ideas for articles you’d like to see and let me know
if the topics being covered are relevant to the issues your institution faces. Take
our brief survey
and you’ll be registered for an Apple iPod™.
If you would like to unsubscribe from this newsletter, please click on link at
the bottom of the page.
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New
Information Technology Examination Procedures
The
FDIC has updated its risk-focused information technology (IT) examination
procedures for FDIC-supervised financial institutions.
Read more
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Complete our 1-minute reader survey and you could win
an Apple iPod. |
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Suspicious Activity?
What do you do when if a match is found on the Financial Crimes
Enforcement Network (FinCEN) list? Learn the proper procedures to follow
when submitting a Suspicious Activity Report (SAR) and the infractions most
commonly cited by regulators.
September 29, 2005
2:00 to 3:00 PM EST
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for this complimentary Webinar today. |
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Last Issue's Dilemma:
The buck stops nowhere
In our CIP
Risk Assessment, we have specified what types of ID are allowed for primary
documentation, secondary documentation and non-documentation verification
methods. These processes were created after input from everyone in our bank.
However, I
have one branch manager who consistently overrides the policy and accepts
documentation that is outside of our policy. We haven’t had any problems yet
from this lack of following our agreed-upon process, but I’m worried it’s only
a matter of time.
Should I confront this manager directly? He’s
my superior, so that could be a little uncomfortable. Or should I relax and
accept the fact that he knows what he’s doing?
— Pat Kramer, Compliance Officer
Read the best advice from readers
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This Issue's Dilemma:
New CRA, Old Systems
I’ve been reading a lot lately about the changes in the CRA. I’m glad to hear that much of the existing regulation would not be changed, especially for banks our size (under $500 million in assets).
However, I’m concerned that one of the ways it will change is that we’ll need to spend more time on data reporting and analysis. I’ve had consultants in here telling me that I need to hire them to help me re-evaluate my program, or risk increased scrutiny.
Do I need to take a renewed approach to my CRA program, or can I safely continue on the course we are on? What are other banks our size doing?
— Jeanette Rodrigues, President
Can You Help?
Congratulations to Randy Herndon, COO of Citizens Bank of Perry, for being
this issue's winner.
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Fraud and AML
Monitoring: Stay ahead of the bad guys |
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Change Management:
Survive and thrive |
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Government
Regulations: Keep up with your changing environment |
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