Blog
OFAC - What Went Wrong?

Cherilyn Genovese, CAMS

Nov 21, 2017

We all know what we're supposed to do, identify all areas where OFAC inquiries are necessary, then formulate risk-based compliance procedures for our institution to follow. What could possibly go wrong? Dissecting the reasons things go wrong - and identifying which controls may have been missing, broken, or become ineffective - can help you design a more effective controls environment in your own institution. We'll go through some high profile OFAC enforcement actions over the past few years to help you understand how to avoid incidents like these: 

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Cordray Departure Draws Mixed Reactions

Pam Perdue, EVP, Chief Regulatory Officer

Nov 21, 2017

Director Richard Cordray revealed on November 15 that he will step down as head of the Consumer Financial Protection Bureau. The news was met with cheers or tears, depending upon one’s vantage point. For the legislators and industry leaders who sought his departure along with reforms at the agency, smiles were bright. But for those who appreciated his strident and vigorous consumer advocacy, the announcement drew worry about what (or who) might come next.

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SAR Noncritical Fields: Still Important

Cherilyn Genovese, CAMS

Nov 15, 2017

Most people define critical as important: CRITICAL (krɪtɪkəl). adjective A critical time, factor, or situation is extremely important.
So doesn't noncritical mean not important? 
Not always! The assumption that a noncritical field is unimportant or can be skipped is a common misconception even among seasoned veterans in the industry.

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What Board Oversight of CMS Really Means

Lori Peterson, Director, Regulatory Infrastructure, CRCM

Nov 07, 2017

Since its introduction in March as one of the four factors evaluated in new rating guidelines, Boards of Directors have been curious about how they should prove they are engaged and involved in effective oversight of the institution’s Compliance Management System (CMS).  

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MLA or SCRA - What’s the Difference?

Donna Cameron, Director of Regulatory I/O, CRCM, CCBCO

Nov 07, 2017

With the recent changes to the Military Lending Act (MLA), financial institutions are taking a closer look at the rules that govern transactions with servicemembers, and sometimes finding themselves confused between the requirements of the MLA and the Servicemembers’ Civil Relief Act (SCRA). Are they parts of the same rule? When does each apply? Do they apply to all servicemembers?

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Determining Training Frequency: Four Steps to Success

Lori Peterson, Director, Regulatory Infrastructure, CRCM

Nov 07, 2017

Deciding how often to provide training can be a challenge for even the most seasoned risk and compliance veteran. As with many compliance-related questions, the answer is “it depends”. But depending on what? Given there are hundreds of compliance requirements with thousands of discrete task-level knowledge points, how can you begin to establish an appropriate training regimen? A simple four-step process can help you take a more logical approach to planning your training calendar.

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Agile Regulatory Change Management is a Necessity

Lori Peterson, Director, Regulatory Infrastructure, CRCM

Oct 31, 2017

“Agile” in the software development industry refers to a software building process that relies on a series of short development cycles called “sprints” to prototype, test and release new software in faster, more efficient ways. Although “agile” is not a word heard often when referring to financial institution operations, being quick and flexible is essential to success in today’s business environment, particularly when implementing regulatory changes.

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Catch Me if you Can Part 2: Home Improvement

Sarah Boisvert, Lead HMDA Auditor

Oct 31, 2017

Earlier this year, I wrote about how to pin down one of the more difficult-to-define HMDA categories: refinancing. Read more about the common pitfalls in ensuring all refinancings are reported in the first part of this series. Today, I want to look at another category where reportable loans can slip through the cracks: home improvement.

Note: This discussion applies to institutions compiling their 2017 LAR under the current HMDA rule. The Home Improvement definition is changing on January 1st, 2018, along with many other aspects of Reg C. The implications of these changes will be the topic of a future post.

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Does “Guidance” mean “Required”?

Donna Cameron, Director of Regulatory I/O, CRCM, CCBCO

Sep 12, 2017

With the increase in volume and complexity of new and revised regulations, we have seen a corresponding uptick in the number of “guidance” documents issued by the regulatory agencies.

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Should credit unions be free from the CFPB’s oversight and regulation?

Tiffany L. Brown, Esq., Regulatory Attorney

Sep 12, 2017

Before the inception of the CFPB in 2011, credit unions were regulated by the NCUA; however, Dodd-Frank granted the CFPB examination and enforcement authority over credit unions with assets over $10 billion, leaving the NCUA with oversight only over safety and soundness issues at institutions above that mark. In addition to examination and enforcement of large credit unions, credit unions are subject to a majority of the CFPB’s regulations. Should the CFPB end or in some way change the relationship it has with credit unions? Here is what the NCUA, CUNA, and the CFPB have to say on the matter. I’ve added my opinion as well - hopefully the perspectives of an attorney who has worked in both banks and credit unions, and now for a RegTech firm, may be of some value to the reader.

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