Regulatory Compliance
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Making Headlines – Credit Trends and Risk Management Take Center Stage
As credit stresses grow and borrowers face cash flow stress, lower income, and higher costs, financial institutions should consider adjusting their strategies for underwriting, managing, and monitoring credit risk.
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What do you call your BSA Program? Moving from BSA to AML/CFT
Many examiners now use the term Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) instead of “BSA/AML” to reference this collection of laws and regulations, to align with the AML Act.
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ICYMI- Fannie Mae Implements Changes to Prefunding and Post-Funding QC Requirements
In March 2023, Fannie Mae released a Seller Guide Announcement introducing upcoming policy enhancements to the prefunding and post-closing quality control review process. These changes include accelerating the post-closing QC review cycle timeline and establishing minimum prefunding volume requirements. Though lenders were encouraged to adopt the new guidelines immediately, the changes became mandatory on September […]
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Regulation E: What Everyone is Talking About
Reg E is a very customer-centric regulation, and that concept does not appear to be changing anytime soon.
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A Trust Company & the Bank Secrecy Act: Is your BSA program good, or good enough?
While all aspects of the Bank Secrecy Act (BSA) rules may not be required for a trust company that are required for depository financial institutions, the oversight obligation and importance is not diminished. Trusts intrinsically have elevated risk based on the transparency of structure, ownership, and purpose. Section 352 of the USA PATRIOT Act requires […]
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Mail Theft and Fraud and SARs…“Oh My!” FinCEN Alert on Mail Theft and SAR Requirements
Have you heard that checks are a dying breed? The industry has been saying that longer than I have been in banking, and that more than half the time I have been alive, yet checks are still being negotiated! According to an article by the Federal Reserve Bank of Atlanta, while checks as a preferred […]
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FinCEN Alert on Sanctioned Russian Elites
In January 2023, the Financial Crimes Enforcement Network (FinCEN) published an alert, FIN-2023-Alert002, regarding potential investments in the United States commercial real estate (CRE) market by “sanctioned Russian elites and their proxies”. This Alert follows a similar Alert issued in March 2022, FIN-2022-Alert001. CRE, as mentioned in the Alert, can have highly complex ownership and […]
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BSA / OFAC Matters: New Sanctions Against Russia and Belarus
On May 8, 2022, by the United States, through the Office of Foreign Assets Control (OFAC), introduced new sanctions against Russia and Belarus . The new sanctions will take effect on June 7, 2022. Read on to learn more.
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Computer-Security Incident Notification Requirements
In fall 2021, the banking agencies issued a final ruled regarding computer-security incident notifications. See how this new rule impacts your bank.
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Is your Financial Institution impacted by the BSA/AML Examination Updates?
Karen Leiter, Regulatory Compliance Director at CLA, summarizes the updates to BSA / AML for the first half of 2021. Read on to learn more and how CLA can help your financial institution.