How BSA Rules Apply to School Corporations: CIP, CTRs, & CDD

Adam Witmer
BSA

Years ago as a new BSA Officer, I received a call from one of our branch managers who had a customer at their desk and was needing my immediate input.  The branch manager told me that the person trying to open a new deposit account with us was refusing to provider her social security number and driver’s licence information (the info our CIP policy required) as she was told that the account was exempt and she didn’t need to provide it.  I asked her what type of company was opening the account and she responded by saying that it was a school.

Exam Procedures for Ultimate Beneficial Ownership Rules

Adam Witmer
BSA, Regulatory Update

On May 11, 2018, the FFIEC released new examination procedures for the recent “Customer Due Diligence Requirements for Financial Institutions.”  These procedures are intended to be utilized by each regulatory agency - meaning they apply to all banks, savings and loans, savings associations, and credit unions - and will be a part of a financial institution’s BSA examination.  These new procedures replace the prior procedures and financial institutions should expect examiners to utilize them in the near future.

Reporting a SAR on a Director

Reporting a SAR on a Director

Adam Witmer
BSA

This BSA video discusses what a BSA Officer should do when they have filed a SAR on a Director and then are supposed to report the SAR to the Board - but the Board requires the names of SARs to be included in the Board report.  Plus, Adam gives a real life example of when this became an issue.

Closing a Loan with Force Placed Flood Insurance

Adam Witmer
Flood

Flood insurance is a challenge for both consumers as well as financial institutions.  The rules are complex, cumbersome, and flood insurance can be extremely expensive - so expensive, in fact, that some consumers have found it more affordable to pay for forced placed flood insurance than to get a separate flood insurance policy.  While this this current trend can help to save the customer some money in the short run, it could cause some compliance challenges down the road.

TRID Resetting Tolerances With a Closing Disclosure

Adam Witmer
Regulatory Update, Regulation Z, TRID

On April 26, 2018, the CFPB released a second set of TRID amendments which address when mortgage lenders with a valid reason may pass on increased closing costs to consumers and disclose them on a Closing Disclosure instead of a Loan Estimate. “Specifically, a timing restriction on when the creditor may use a Closing Disclosure to communicate closing cost increases to the consumer could prevent a creditor from charging the consumer for those cost increases despite a valid reason for doing so, such as a changed circumstance or borrower request. This article takes an in-depth look at the new rules and how they apply to community banks and credit unions.

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