Tracy Wilson

BAT CHAT

What do CDD and EDD Mean? Part II: Enhanced Due Diligence

The expectation for enhanced due diligence did not change with the passing of the 5th BSA pillar. However, examiner expectations for enhanced due diligence (EDD) continue to evolve because it is a critical component of your bank’s BSA Program. TCA® first addressed the EDD topic in a 2015 In Depth article. The November 2018 BAT …

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geo targeting

Here We “GTO” Again Real Estate Geographic Target Orders Expande

On November 15, 2018, FinCEN announced the expansion of the existing real estate geographic target orders (GTO) to include 12 more metropolitan areas. As covered in previous TCA Special Delivery articles, a series of GTOs measures became effective March 1, 2016 which temporarily required certain U.S. title insurance companies in the Borough of Manhattan, New …

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wall street

Avoid Regulation DD Pitfalls When Disclosing Introductory Rates

Retail bankers have to confront a robust stock market, aggressive deposit acquisition strategies from growing firms, and maybe more than three Fed rate increases coming in 2018. Increasingly more creative methods are being used to attract deposit dollars. One such method is offering higher introductory rate products to catch attention while still holding down the …

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aml

Never Too Much BSA Training

With new leadership at the CFPB, OCC and FDIC, one may put training expenditures on the back burner thinking regulatory relief may make training not an every‐year mandate. Until you see relief in a regulation or rule change, don’t make any assumptions because training exceptions are BSA Pillar violations. Remember, a pillar violation can trigger …

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