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New Year, New Exam
Interpreting the BSA/AML exam procedures
by Bill Koch, Editor, The Compliance Advisor
How
supportive are you when someone makes a New Year’s resolution? Do you give that
person your full support, hoping that he or she will make the change as
promised? Or do you respond with a cynical snicker, knowing that health clubs
empty out in mid-February and that cigarette sales spike in March?
If
you are a compliance officer at a community bank, you probably have your
fingers crossed that federal regulators will keep their promise to make their examination
procedures and requirements clear and consistent. That’s what they promised in
2005.
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A wish come true for 2006
Trey Sullivan |
At
the urging of harried compliance officers across the country, the federal
government has made a big resolution for 2006. They intend to make examination
procedures for compliance much more clear and consistent. To that end, new
guidelines have been released for the BSA/AML exams. How should your bank
adapt? Or is what you are doing now just fine? This month’s
feature article
shares some expert advice to ensure your bank stays compliant.
Last
month, we asked how you are changing your RegCC processes to meet the recently
released new requirements.
Your responses show that most banks will
have to change their processes in order to keep up. This month, we want to know
about your GLBA training program. Are you doing additional training or is your
current program enough?
Write us with your best advice or request help
from your peers about a particular challenge you face.
To
keep this material relevant to you, we invite you to become actively involved
with this newsletter. Please send ideas for articles you’d like to see and let
us know if the topics being covered are relevant to the issues your institution
faces. Take our brief
survey, and you’ll be registered to win 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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Complete our 1-minute reader survey and you could win
an Apple iPod. |
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GLBA,
FDIC & FFIEC:
Preparing for Your
Security Review & Risk Assessment
Learn the guidelines that establish administrative,
technical and physical safeguards to protect the privacy of customers’
nonpublic personal information. This Webinar focuses on FFIEC’s final
guidelines and will help your organization:
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Understand
the specific compliance requirements
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Access
your current state of readiness
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Gain
insights on comprehensive security risk assessments
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Build
a compliance blueprint
Wednesday,
January 25, 2006 2:00 p.m. to 3 p.m. EST
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for this complimentary Webinar today. |
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Last Issue's Dilemma:
Do new regulations always mean new processes?
In mid-November, the Federal Reserve Board amended RegCC to shift liability for unauthorized remotely created checks to the institution where it was first deposited. To reduce fraud, the amendments create transfer and presentment warranties by the presenting bank that warrants the check authorized by the person whose account from which the check is drawn.
This is a long overdue step for consumers, and I am glad that the board stepped up to make the changes. How do we need to change our processes to protect ourselves under these new amendments?
How are other banks changing their processes? This seems like a straightforward change, but is there anything that could come back to bite us?
Thanks for any help you can offer.
— Maria F., Compliance Officer
Read the best advice from
readers
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This Issue's Dilemma:
How much is enough GLBA training?
Since Gramm-Leach-Bliley went into effect, we have been conducting privacy training annually for our employees. This is in addition to all the other compliance training that we do in a regular basis.
I've heard that examiners may look for more frequent training on this act. I’d like to know what other banks are doing. Are you keeping the amount of GLBA training the same? Or are you doing additional GLBA training? If you’re doing additional training, what is the focus of that training?
Thanks!
— Jennifer C., Compliance Officer
Can You Help?
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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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