FinCEN continues to make communication updates. This is a reminder to check your AML/CFT policies and procedures to make sure they contain the following recently updated contact information: TCA – A Better Way!
AML/CFT Policy and Procedure Checkup Read More »
Answer: When the financial institution is notified of the death of a recipient, it must return all subsequent post-death benefit payments with a Return Reason Code R15 or R14. These codes notify the Federal agency of the recipient’s death. The financial institution may return any post-death benefits that have already posted by ACH without waiting
When you deny a credit application or a deposit account request, you simply fill out a form and move on to the next customer, right? If only it were that simple! This article will clarify the who, what and why of the different requirements for denying loan applications and deposit requests for consumers and businesses
Adverse Action Notice Requirements For Loans and Deposits Read More »
TCA has received questions from several clients recently regarding privacy notices and opt-out requirements, so we felt it was time to provide a refresher. Questions on whether written agreements meet the requirements for joint marketing arrangements should be referred to legal counsel. What information is covered? The GLB Privacy Rule protects a consumer’s “nonpublic personal
Privacy Notice Opt-Out Requirements Read More »
Even though a topic may not fall under TCA’s typical umbrella of compliance, we often have broader compliance discussions with our clients that we feel are important to share for informational purposes; this is one of those instances. We were told by a banker that an examiner had cited a deficiency in the institution’s vendor
Vendor Management – Monitoring Consumer Complaints Read More »
The Bank Secrecy Act requires banks to manage risks associated with automated clearinghouse (ACH) and international ACH transactions (IAT), which results in a need for effective risk mitigation strategies and monitoring processes. The sheer volume of ACH activity makes the task seem impossible. TCA’s BSA Action Team (BAT) can help evaluate the effectiveness of a
ACH Activity: Are You Managing Your BSA Risk? Read More »
FinCEN announced updates to the Suspicious Activity Report (SAR) filing format in a notice to e‐filers. The announcement says that the revisions adhere to the changes listed in FinCEN’s February 2, 2017 Federal Register notice and will be live in June 2018. In these new filings, batch submissions will have to be made in an
FinCEN Finalizes New SAR Read More »
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