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 »
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