Do Successor in Interest Rules Apply to My Bank? Successor in interest rules take effect on April 19, 2018 and many are still wondering if and how they apply to them if they are not a “large servicer.” A “small …
If it’s Tax Season it also means PA Escheat Season! With the April 18th reporting deadlines just on the horizon, many institutions are in process of scrubbing their dormant accounts for potential escheat processing. If you fail to report timely, …
Evelyn I. Dehmey If it’s Tax Season it also means PA Escheat Season
Are You Effectively Identifying Marijuana-Related Business Customers? The Financial Crimes Enforcement Network (FinCEN) has identified thorough customer due diligence (CDD) as a critical component in assessing the risk posed to financial institutions when providing a service or product to a …
Are You Effectively Identifying Marijuana-Related Business Customers? Yesica Quintero
ACH: Time is Running Out to Provide NACHA with Feedback on Same Day ACH Since the 1970s the principal electronic transfer system, ACH (Automated Clearing House) has been transferring payments from one institution to another. Based on stability not speed, …
Automated clearing house Cindy Tice Time is Running Out to Provide NACHA with Feedback on Same Day ACH
How Well Do You Know Your Third-Party Vendor? The risks of involvement with third-party vendors are increasing with news of data breaches from Equifax, Verifone, FAFSA, Docusign, and many more in 2017 alone. No matter the size of your bank, …
Risk ID Framework Practices The Banking industry develops and executes strategic plans in an uncertain and risky environment. The purpose of an enterprise risk management framework is to ensure that those risks and areas of uncertainty are identified, analyzed, and …
BSA – Critical vs Non-Critical Fields: What is the difference and how should they be handled? The FinCEN Suspicious Activity Report (SAR) and Currency Transaction Report (CTR) forms contain both critical fields and non-critical fields. Each field is just as …
CTR Currency Transaction Report FinCEN Michael McLaughlin SAR
ACH- Third Party Sender Registration On September 29, 2017 NACHA’s Third-Party Sender Registration Rule became effective. Financial Institutions must register with NACHA either to register their Third-Party Sender customers or to indicate that the institution does not have any Third-Party …
WHAT’S ALL THE CHATTER – REMA VS ASSESSMENT AREA? There was a time when all we needed to worry about for CRA (Community Reinvestment Act) compliance was defining the Bank’s Assessment Area – the geographic area by which the bank …
WHEN DO I HAVE AN APPLICATION? This is a frequently asked question in compliance circles and the answer is the elusive “It depends!” There are different definitions of “application” in various regulations depending on the context of the regulation. For …
ECOA Equal Credit Opportunity Act Evelyn I. Dehmey HMDA Regulation B