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FinCEN Finalizes New SAR
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 […]
Combating Elder Financial Exploitation
On August 30, 2017, FinCEN issued a memorandum titled “Memorandum on Financial Institution and Law Enforcement Efforts to Combat Elder Financial Exploitation.” Elder Financial Exploitation is the improper use of an older person’s funds or assets. Assets can also include the older person’s property or belongings. When an older person is being exploited, it often […]
CFPB Releases HMDA‐LAR Reporting Tool
On Thursday, February 1, 2018, the Consumer Financial Protection Bureau (CFPB) released a statement indicating that the 2018 HMDA LAR Formatting Tool is now available. The tool, which is available here, is for use by those institutions not currently using an automated system for processing their HMDA LAR. Under the new HMDA reporting rules, an […]
What is the Cloud?
It’s not atmospheric, but the term is banner‐like: sky-borne and all powerful. Before we can discuss the hot topic of shared multi-tenant environment risk in our next article, we need to take a step back and address, “What is Cloud Computing?” Sure, the cloud is out there, somewhere in the unknown, or most likely hidden […]
Government Shutdown—National Flood Insurance Program Affected
Washington pulled through with a temporary compromise on extending government funding on Monday, thereby continuing to fund many “non‐essential” services and programs – one of which is the National Flood Insurance Program (NFIP). However, this provides us with a three week window and if additional compromises or an agreement is not made we may find […]
Last‐minute 2018 HMDA Clarifications
The long-awaited deadline to begin collecting 2018 HMDA data is here! Banking agencies have issued HMDA guidelines on data testing and additional information on HMDA data collection. Also, the Consumer Financial Protection Bureau (CFPB) has clarified some interpretations as it has worked through numerous questions via phone calls and emails from filers. One of the […]
Stunning Reversal by DOJ on Marijuana Enforcement
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 […]
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 […]
Fraudsters Expose Identification Weaknesses
An old scam targeting financing institutions is gaining new traction as data breaches become increasingly common and more information is freely available via social media. Banks are reporting increased occurrences of fraud targeting home equity lines of credit (HELOCs). Using a spoofed caller ID, a hacked email account or a faxed request, the fraudster requests […]
Video Gambling: A Good Bet for Your BSA Program?
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 […]
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