Can your program handle the next data breach? TCA will review the minimum requirements for an ID Theft Prevention Program and consider best practices for staff working with customers who have been victimized. Topics include: Red Flags Risk Assessment ID Theft Prevention Procedures Board Reporting and Governance Vendor Management
Identity Theft and FACT Act Read More »
Overdrafts have received a lot of attention from examiners and is a hot button topic. We will consider the requirements for formal and ad hoc payment of overdrafts across multiple regulations. Reg DD Reg E Reg Z Reg B Fair Credit Reporting Act Fair Debt Collection Practices Act Unfair Deceptive Abusive Act and Practices Current
Overdraft Rules: Have Your Considered All the Options Read More »
April showers brought May flowers, or in the BSA world, beneficial ownership is finally here. The BAT has been fielding questions left and right about some of the nuances of the new CDD requirements. The BAT has speculated on the implications of CDD as the fifth pillar for years now and one thing is clear:
Beneficial Ownership and Lending: Have we considered all possibilities? Read More »
Many TCA clients have expressed concerns regarding FinCEN’s position that automatic renewals of certificates of deposits and loans are considered new accounts which require that a financial institution obtain a Certification of Beneficial Ownership for legal entity customers. Since FinCEN published the Frequently Asked Questions just one month prior to the mandatory compliance date, our
FinCEN issues Exceptive Relief for Certificate of Deposit and Loan Renewals Read More »
In eight days, the new 5th pillar – that includes Beneficial Ownership – takes effect. Starting May 11, 2018, Customer Due Diligence (CDD) will be added to the other four Bank Secrecy Act pillars. Right now, one of the most frequently discussed questions continues to be CD and loan renewals. TCA’s BSA Action Team (BAT)
CDD and Auto-Renewing Products: Are you BSA Compliant Read More »
On January 4, 2018, Attorney General Jeff Sessions issued a Memorandum which reverses the Department of Justice’s (DOJ’s) stance on enforcement of the Controlled Substances Act as it relates to medical and recreational marijuana that is legal at the state level. How this will impact federal prosecution of the marijuana industry is uncertain, but the
Stunning Reversal by DOJ on Marijuana Enforcement Read More »
TCA’s 90 minute webinar will help you understand the regulatory requirements for advertising and the focus on consumer harm.Topics include: Advertising Basics – Has the “trigger” been pulled? Overview of what is required Trigger terms that require additional disclosure Differences in media Disclosure Format – Time to Read the Fine Print Best practices for formatting
Advertising and Marketing Pitfalls: Avoiding Consumer Harm Read More »
All of the regulatory agencies have followed the lead of the CFPB and significantly shifted the focus of examinations to the potentialfor consumer harm. In order to effectively prepare for this new regulatory approach, Banks must be able to understand its consumerharm risk profile. This critically important and timely webinar includes: The evolving approach of
What You Need to Know for Your Next Compliance Exam Read More »
Following the recession of the last decade, many states explored creative options to generate additional revenue without increasing income or sales taxes. Given the popularity of lotteries, some states – including Illinois, South Dakota, West Virginia, and Oregon – legalized video gambling machines. State governments, local municipalities, machine operators and business owners all share in
Video Gambling: A Good Bet for Your BSA Program? Read More »
We’re here to review your current compliance strategy and help you find A Better Way to manage risk.
