CTRs with Multiple Transactions

In this Compliance Clip (video), Adam discusses some recent changes to CTR reporting. Specifically, FinCEN has updated its user guide in regards to reporting CTRs with multiple transactions. The guidance has flip-flopped a bit over the last few months, so you won’t want to miss this video.

Earlier this month, we ran a contest to give away one of our new Premium Gold memberships for free. Our Premium Gold membership includes our four Quarterly Compliance Updates as well as three additional Compliance Classes. Congratulations goes to Becky G who won this contest and has been enrolled in our Premium Gold membership for 2020. Be sure to watch for more contests throughout the year and you can learn more about our premium membership options at www.compliancecohort.com/premium-membership

Next week is your last week to enroll in one of our two new premium memberships: Premium Silver or Premium Gold. Both memberships include our Quarterly Compliance Update program as well as additional Compliance Class(es) at a bundled/discounted price. This means that our programs are designed to keep you up-to-date on all regulatory changes that occur during the year as well as provide you with additional compliance training (depending on the membership level you choose). You can learn more about our two new Premium Membership options at www.compliancecohort.com/premium-membership.

Overview of CRA Proposal

In this Compliance Clip (video), Adam briefly discusses the recent CRA proposal by providing an overview of the goals of the proposal. Adam also discusses how, if passed as proposed, this new rule would have some major changes to Assessment Areas that may have negative effects on banks. Comments are due soon on this proposal, so watch this video to learn how the changes might affect your bank.

This is a guest post by one of our Compliance Cohort members, Jennifer Johnson.  Jennifer is a Vice President and Chief Risk Officer at a $225 million community bank, and shares her years of experience in multiple banks with us in this article.

In a previous article, we discussed those frustrating customers who come to us with bits and pieces of the information we need to make a loan decision, providing us with an incomplete application. If you’re OCD like me, those situations drive you more than a little crazy, especially when you know that you have obligations to notify the customer of your decision within 30 days of receipt of the request. So how do you handle these scenarios without pulling out your hair? I have a simple solution…

On January 7, 2020, the NCUA announced that it had issued its annual letter to credit unions listing its 2020 supervisory priorities as well as updates on regulations and the agency’s modernization programs.

The letter includes a summary of recent statutory and regulatory updates, including additional guidance on serving legal hemp businesses; changes in the appraisal threshold for commercial real estate transactions; the amended supervisory committee audits rule, which took effect Jan. 6; and the amended public unit and nonmember shares rule, which takes effect Jan. 29. For 2020, the NCUA has listed the following as supervisory priorities:

Have you ever thought about writing an article on compliance or BSA to share your knowledge or expand your resume? Well, we should chat as we are again accepting article proposals for possible publication on the Compliance Cohort. If this is something you are interested in, we would love to collaborate with you as our members benefit from guest articles on any banking compliance topic. Contact us at members@compliancecohort.com or just reply to this email for more information.

Reg E Disputes on Older Transactions

In this Compliance Clip (video), Adam discusses how Reg E liability and the dispute process works for older transactions. You know, when a customer comes to you two years after-the-fact and says they now want to dispute a purchase they don’t remember doing. This video explains the responsibilities under Regulation E as far as what needs done for this type of dispute.