Risk Watch Extra
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Risk Watch Plus Webinar 4: Disaster Recovery & Business Resumption Concepts & Approaches
In this short-form webinar, Ken Agle walks through the basic elements of a sound disaster recovery and business resumption strategy for financial institutions, concepts that are particularly timely in light of current events. Certificate of completion available. (See in-webinar instructions.) Before that, we cover what’s hot in compliance, as seen by the editors of http://riskinbox.com. This week’s hot items: 1) 2019 HMDA data have been released. Here’s an early look at some potential hot areas. 2) What is the most common consumer complaint the CFPB is receiving in this pandemic era?
Risk Watch Plus Webinar 3: BSA/AML System Validation
In this short-form webinar, Ken Agle walks through the basic steps of validating a monitoring system for compliance with Bank Secrecy Act/Anti-Money Laundering rules. Before that, we cover what’s hot in compliance, as seen by the editors of Risk InboX. This week’s hot items: 1) What is the most common violation examiners are finding in the field? 2) If there were Oscars for SARs, this would be it. See how FinCEN calls attention to how SARs help in law enforcement. Certificate of completion available. (See in-webinar instructions.)
Risk Watch Plus Webinar 2: Fair Lending Spotlight on Minneapolis
What’s hot in compliance, as seen by our editors. This week’s hot items: 1) What has House Democrats upset with the OCC? 2) Redlining’s adverse impacts continue to be felt four decades later. 3) Ken Agle walks through a basic look at Fair Lending analytics that can be performed using the expanded data points available through HMDA. The focus this episode: Minneapolis MSA. (Complimentary certificate of completion available. Email riskwatchplus (at) advisx.com with the subject line: “Minneapolis”).
Risk Watch Plus Webinar 1: Spotlight on CRA
What’s hot in compliance, as seen by our editors. This week’s hot items: 1) What got International Bank of Chicago in hot water for its Bank Secrecy Act program; 2) Which 7 cities should be praying they don’t get a 100-year storm anytime soon; and 3) the compliance spotlight shines on the Community Reinvestment Act, which is in the crossfire of politics, protests, and a pandemic. (Complimentary certificate of completion available. Email riskwatchplus (at) advisx.com with the subject line: “CRA”).
Risk Watch 153: What You Need to Know About Elder Financial Exploitation
Losses to senior citizens from financial abuse are estimated to be $3 billion last year alone. Banks and credit unions are on the front lines when it comes to detecting and reporting suspected instances of abuse. At the same time, they have an obligation to protect the privacy of their customers and respect their wishes to conduct lawful transactions. Amy Wargo of CU Solutions Group presents how financial institutions can navigate this delicate balance through effective employee training.
- Elder Abuse Prevention Training by Strategic Advisory Solutions
- Memorandum on financial institution and law enforcement efforts to combat elder financial exploitation
- Interagency guidance on privacy laws and reporting financial abuse of older adults
- Advisory and report for financial institutions on preventing and responding to elder financial exploitation
- Suspicious Activity Reports on Elder Financial Exploitation
- Reporting of Suspected Elder Financial Exploitation by Financial Institutions (this includes a state-by-state breakdown of mandatory reporting requirements)
- FinCEN Analysis on How the Use of SARs Protects Against Elder Financial Abuse
Risk Watch 152: Member Business Loans – What You Need to Know
A look at a brief history of the political hot potato that is member business lending at credit unions as well as recent changes that may impact those who manage credit unions and their members.
Risk Watch 151: Suspicious Activity Reporting and Business Email Compromise
Business email compromise (BEC) schemes are on the rise. In fact, with the number of Suspicious Activity Reports for BEC more than doubling since 2016, the Financial Crimes Enforcement Network recently issued three alerts on the subject. Here’s a quick overview of what BEC is, how you can identify it, and how it impacts your SAR filings.
Risk Watch 150: True Beneficiaries and Bank Secrecy Act
Why is knowing the true beneficiary a vital aspect of a financial institution’s Bank Secrecy Act efforts? Here is the third of three episodes of Risk Watch highlighting notable examples of BSA reporting as recognized by FinCEN.
Risk Watch 149: What is Trade-Based Money Laundering?
What is trade-based money laundering and how can your Bank Secrecy Act and front-line personnel recognize it? Here is part 2 of our 3-part series in Risk Watch on Bank Secrecy Act reporting. Due to the sensitive nature of BSA reporting by financial institutions, usually little is heard about it. But if front line and BSA personnel never hear what can become of their efforts, it is easy for this important work to seem like a pointless exercise, which can lead to lapses in vigilance. Dayne Bloxham of AdvisX presents this three-minute look at the emerging issue of trade-based money laundering.
Risk Watch 148: BSA Reporting Takes a Rare Bow
Due to the sensitive nature of Bank Secrecy Act reporting by financial institutions, usually little is heard about it. But if front line and BSA personnel never hear what can become of their work, it is easy for this important work to seem like a pointless exercise, which can lead to lapses in vigilance. Hence, FinCEN annually shares how BSA reporting by financial institutions has made an impact in the successful prosecution of criminals, terrorists, and other bad actors. Presented by Ken Agle of AdvisX, this is the first of three episodes of Risk Watch highlighting specific examples recognized by FinCEN.
Risk Watch 147: What Financial Institutions Can Learn from Rabobank’s BSA/AML Mistakes
Rabobank in California was hit with a $50 million fine for its Bank Secrecy Act and Anti-Money Laundering deficiencies. Ken Agle of AdvisX shares where Rabobank went wrong and what financial institutions can learn from its mistakes.
Risk Watch 146: Everything You Need to Know About Fifth Pillar in Five Minutes or Less
With the effective date of May 11, 2018 just around the corner, here’s what you need to know about the 5th Pillar and Beneficial Ownership in five minutes or less. Presented by Makayla Denton of AdvisX.
Risk Watch 145: NCUA’s 2018 Supervisory Priorities
In a recent letter to credit unions, the NCUA highlighted several areas that examiners will be focusing on in 2018. Rachel Osborn shows you how you can prepare for those upcoming exams. (2/16)
Risk Watch 144: HMDA Compliance Under New CFPB Leadership
Under a new Acting Director, the CFPB issued a statement indicating that the bureau will take a gentler approach to enforcing the HMDA changes that went into effect on January 1. But does this mean you can now sit back and relax when it comes to HMDA? Ken Agle of AdvisX takes a closer look at the CFPB’s statement. (2/9)
Risk Watch 143: Top 5 Episodes of 2017
This year we’ve added more than 30 new episodes to our library and covered nearly as many compliance topics. To round out the year, we’ve put together a review of the top five episodes of 2017. (2/2)
- #1: https://youtu.be/ApAtG-S8L8Y
- #2: https://youtu.be/KommSpc_PUE
- #3: https://youtu.be/iOz-NZi3D58
- #4: https://youtu.be/1H9CWLAYvRA
- #5: https://youtu.be/JsSNuU2OP6I
Risk Watch 142: Digging into ADA Website Accessibility
The best way to find and address website accessibility issues and prevent ADA lawsuits and other compliance troubles is to dig deep into every aspect of your website. Eric Meadows of AffirmX shows you several key trouble spots to look for when evaluating your website for ADA accessibility. (1/26)
Full Archive of Past Episodes Available Now on Risk Watch Central
Risk Watch 141: Longer-Term Auto Loans on the CFPB Radar
A recent CFPB report highlights some of the bureau’s concerns with the rising popularity of longer-term auto loans. This is a strong hint that supervisory scrutiny for these types of loans is on the horizon. Carolyn Orner of AffirmX has the details. (1/19)
Mid America Bank & Trust Company, located in Missouri, found out the hard way that disclosures are very important, especially when it comes to credit cards and third parties. Abigail Rackliffe of AdvisX shows you what the bank did wrong, and how you can avoid similar missteps. (1/5)
Are you ready for the new HMDA reporting requirements coming in 2018? If you’re like many institutions, you’re probably feeling unprepared. Makayla Hatch of AdvisX has some suggestions to help you get ready. (12/15)
There are currently no hard and fast rules requiring websites to comply with the Americans with Disabilities Act (ADA). This means that financial institutions are vulnerable to people trying to take advantage of the uncertain legal landscape. The best way to steer clear of frivolous lawsuits is to make your website ADA accessible. Eric Meadows of AffirmX shows you how. (12/8)
Complaints draw examiners’ attention like honey draws flies. As debt collection has been one of the most complained about topics lately, it’s no surprise that the CFPB made this an important area of focus in its recent issue of Supervisory Highlights. Ken Agle of AdvisX points out some key debt collection takeaways from the report. (11/17)
Maximizing your BSA/AML system and making it work for your institution can feel like trying to survive on a deserted island. Your best efforts may sometimes seem fruitless. Ken Agle of AdvisX shows you how to take your BSA/AML system from surviving to thriving. (11/10)
Risk Watch 135: State of Complaints
What does your state complain about and how much does it complain? A recent CFPB complaint report covers just that. Ken Agle of AdvisX breaks down the report and highlights important state-by-state complaint trends. (10/27)
The CFPB recently finalized some long-awaited amendments to its TILA/RESPA Integrated Disclosure rule. While many were hoping for more from the bureau with these amendments, there are some specific changes you’ll want to make sure you have noted. Kevin Twigger of AffirmX shows you what you’ll want to watch for. (10/18)
Some new BSA/AML requirements in New York State have all the makings of requirements that could be adopted by federal regulators in the near future. But even if they don’t end up as a federal regulation, there are some sound principles that will surely add BSA/AML program strength if implemented. Ken Agle of AdvisX gets you acquainted with the new requirements. (10/6)
If you aren’t confident in your institution’s fair lending program, you’ll naturally dread the thought of a fair lending examination. But there’s a better way. And that is to make sure your fair lending program is strong and effective. Jane Pannier of AffirmX shows you the five aspects of a fair lending program that will eliminate any fear of a fair lending exam. (9/8)
The CFPB recently released a consumer complaint snapshot featuring complaints received from older consumers. To help protect older consumers from the harmful and growing problem of elder financial exploitation, Mike Stottlemyer of AffirmX shows you what your older customers complain about, and how you can best address those concerns. (9/1)
The CFPB’s recently published 2016 Fair Lending Report is a great resource to look to when evaluating your institution’s fair lending program. The report reviews the bureau’s efforts to enforce fair lending, and outlines fair lending regulatory priorities in the months to come. Kevin Twigger of AffirmX highlights key insights from the report that will help you address any fair lending problem areas before your examiner does. (8/25)
In the world of BSA/AML, it all comes down to perspective. For many financial institutions, the perspective sometimes becomes stagnant, looking at the same things over and over. In a sense, it’s like they’re looking at one side of the moon, ignoring what’s on the other side. Ken Agle of AdvisX shows you how beneficial ownership can broaden AML perspective. (8/4)
Your institution likely filed at least a handful of the nearly one million SARs filed last year. Have you ever wondered what happens to all those SARs you painstakingly prepare and file? Rachel Osborn of AffirmX shows you some of the ways law enforcement has used your SARs to stop crime. (7/14)
While commonplace, remittance transfers can be confusing. The confusion generally comes from trying to determine what qualifies as a remittance and what doesn’t. Mike Stottlemyer of AffirmX clears things up with this handy remittance transfer crash course. (7/7)
When it comes to CRA, you’re most likely one of the 98 percent Satisfactory or Outstanding organizations. However, that doesn’t mean you can skip your preparations for your next CRA exam, because that is the formula for disaster. What it does mean is that you should look for the most efficient ways of preparing for your next examination. Ken Agle of AdvisX shows you some effective tools that can help cut the costs and make your CRA process more efficient and less painful. (6/16)
Merchants Bank of California was recently hit with a $7 million fine for BSA violations, which means that BSA/AML problems are still among the top concerns for regulators. Ken Agle of AdvisX explains Merchants’ mistakes, and shows you how you can avoid similar problems. (6/2)
The CFPB recently released a proposal to amend Regulation B, which implements the Equal Credit Opportunity Act. Sydney Caskey of AffirmX highlights the proposed changes to help you keep on top of your fair lending obligations. (5/12)
To retain, or not to retain? That’s the question that can be quite difficult to answer when it comes to figuring out how long to keep all the various records and documents you deal with on a daily basis. Taking the time to make sure you understand record retention requirements will go a long way to ensuring your customer and member data stay safe. Jane Pannier of AffirmX outlines the basics. (5/5)
Risk Watch 122: Key Takeaways from FinCEN’s 2016 SAR Report
FinCEN recently published its 2016 SAR Stats Technical Bulletin, which provides an in-depth recap of the all the year’s SAR filings. If you’re involved in your institution’s BSA program, a review of this data can be one of the most informative ways to keep your program current and effective. Dennis Agle of AdvisX highlights some of the key stats from the report. (4/28)
It’s been more than 35 years since the Uniform Interagency Consumer Compliance Rating System last saw any changes, so the FFIEC thought it was high time for some updates. But what are those changes, and how will they affect your institution? Mike Stottlemyer of AffirmX highlights the key revisions. (4/14)
Last episode we looked at some key issues highlighted by the kinds of complaints and the types of businesses represented in the CFPB’s consumer complaint database. But now the question is what type of complaints should receive the most attention? Ken Agle of AdvisX shows you how to determine which complaints carry the greatest weight, and how you can use that information to identify areas of your institution that need attention. (4/7)
Since its release in 2011, the CFPB’s Consumer Complaint Database has received over 1 million complaints. These complaints reveal some key issues that could impact your institution. Ken Agle of AdvisX shows you what you can learn from these complaints, and how you can be better prepared to respond. (3/31)
An essential part of making sure your BSA program is running smoothly is periodic validation of your anti-money laundering system. The problem is that many validations only validate halfway, and often don’t even know they’re missing the other half. Hailey Jensen of AdvisX shows you what to look for to make sure you’re getting a complete validation. (3/24)
In a recent letter to credit unions, the NCUA outlined several priority areas that examiners will focus on for 2017 exams. So what are those areas, and how can you make sure you’re ready? Jane Pannier of AffirmX shows you what you can do to prepare. (3/3)
With the new year comes a new HMDA. HMDA has changed a lot over the years, but nothing like what is heading our way. What are the changes ahead, and how can you be ready for them? Ken Agle of AdvisX explains the significant changes and shows you how to best manage them. (2/24)
For most, regulatory relief is actually quite relieving. But if you’re responsible for compliance at your institution, thinking about the changing regulatory environment may be causing you some stress. That’s because there might be a tendency for those around you to get lax in their compliance vigilance. So how can you keep your institution focused on compliance? Mike Stottlemyer of AffirmX gives some pointers to help you ensure that compliance remains a priority at your institution. (2/10)
Many institutions are using fair lending models tasked with evaluating an organization’s decisioning and pricing relative to the prohibited factors, such as race, gender, religion, age, etc. However, are these models working correctly and doing what they were designed to do? Assuming the answer is yes could be a costly mistake. Ken Agle of AdvisX shows you how a fair lending model validation is the most effective way to ensure your fair lending system is working properly. (1/20)
If your fair lending regression analysis highlights any areas of concern, it’s time to dig deeper. The way to do that is with a comparative file review. This takes matched loan pairs and examines them for fair lending disparities. AdvisX data analyst, Hailey Jensen, reveals just how helpful a comparative file review can be in determining your fair lending risks. (1/13)
The key to managing fair lending risk is knowing your data. But sometimes a basic fair lending data analysis won’t tell you the whole story. So what should you do? A regression analysis can tell you what you’re missing and can give you a more accurate picture of your fair lending risks. And since those of us that aren’t statisticians may find it somewhat daunting, AdvisX data analyst, Hailey Jensen, explains the what, why, and how of a fair lending regression analysis. (1/6)
The threat of cyber attack, even for smaller institutions, is growing. More and more banking is moving online, and as such, it is vital that your institution stays up to date with cybersecurity. The FFIEC recently published a information security booklet containing important cybersecurity information. AffirmX’s Dennis Agle highlights what your institution should know to stay secure and prevent attack. (12/9)
AML systems are often a source of frustration for financial institutions, because they produce too many unproductive alerts, or because they miss things that should be more closely scrutinized. AdvisX’s Ken Agle explains how adding a third dimension to your AML perspective can lead to greater precision in determining where your highest risks are, and can make your AML system much more effective. (12/2)
With regulatory scrutiny of fair lending heating up, it pays to know how to conduct a solid fair lending risk assessment. But what does that entail? Jane Pannier of AffirmX highlights six key areas your fair lending risk assessment should cover to keep you in the clear. (11/25)
If you think social media consists solely of meaningless posts about who ate what for breakfast, think again. Social media can be a valuable marketing tool for your institution. But like other forms of marketing, there is a right way, and a wrong way. AffirmX’s Rachel Osborn reveals what you need to know to make social media work for you. (11/18)
With the release of the Department of Defense’s final rule on changes to the Military Lending Act, chances are that the SCRA is also on your mind. These two acts are very similar, and can easily be confused. AffirmX’s Sydney Caskey points out the key differences between the two acts and highlights a couple of the new MLA changes you should be aware of. (11/4)
Wells Fargo was recently fined over $180 million because employees opened over two million fake accounts. AdvisX’s Ken Agle gives us the scoop on what happened, and four key lessons your financial institution can learn from Wells Fargo’s mistakes. (10/28)
The CFPB issued its final rule amending mortgage servicing rules under Reg. X and Reg. Z. The rule came in at a little over 900 pages. We asked AffirmX’s Mike Stottlemyer to give us a high-level view of what banks and credit unions should know about the changes in five minutes or less. (10/21)
The CFPB recently published the findings of a field scan that highlighted the many challenges immigrants face when it comes to financial education. Jane Pannier of AffirmX tells you what your institution can do to help immigrants with these challenges and improve customer reach and service. (10/14)
What can other financial institutions learn from BancorpSouth’s fair lending issues? AdvisX’s Ken Agle reviews what examiners found and shares three key takeaways for other banks and credit unions. (10/7)
The CFPB issued a proposal regarding changes they want to see in debt collection. You can read the 117-page proposal, or you can spend five minutes listening to AffirmX analyst Rachel Osborne highlight the proposed changes. (9/30)
The Telephone Consumer Protection Act might be more relevant than you think. AffirmX Analyst Eric Meadows explains five facts about the TCPA that your financial institution needs to know in order to keep your compliance measures up to date. (9/23)
Risk Watch 100: Three Things FinCEN Wants You to Understand About its CDD Requirements
In its published FAQ, FinCEN answered 26 questions regarding its new CDD rule. AdvisX Analyst Hailey Jensen highlights three terms that FinCEN wants financial institutions to understand in order to understand the rule. (9/16)
Risk Watch 99 | Deposit Discrepancies: Short-Term Benefits, Long-Term Consequences
Deposit discrepancies may initially benefit a financial institution, but they hurt consumers and expose institutions to the risk of agency action. AffirmX Analyst Sydney Caskey discusses the correct way to handle deposit discrepancies. (9/9)
More and more financial institutions are facing the prospect of undertaking a look-back project, which can be all-consuming. If you find yourself in such a position, however, don’t despair. It is possible to come out alive on the other side. Ken Agle, President of AdvisX, gives us some tips on how to survive a look-back project. (7/27)
The CFPB’s proposed Payday Lending Rule covers more than just non-bank, short-term lending entities. The rule also covers vehicle title, and high-cost installment loans. Zac Stucki, AdvisX Analyst, discusses four things you need to know about the rule. (7/12)
The Americans with Disabilities Act ensures individuals with disabilities have the same opportunities as everyone else. As opportunities expand with widespread use of the internet, financial institutions need to take a look at their websites and make sure they’ve cleared accessibility requirements. Mike Stottlemyer, Director of Operations at AffirmX, explains what that means for your website. (7/5)
The CFPB’s proposed Payday Lending Rule covers more than just non-bank, short-term lending entities. The rule also covers vehicle title, and high-cost installment loans. Zac Stucki, AdvisX Analyst, discusses four things you need to know about the rule.
Risk Watch 91: Four Top Fair Lending Violations
Are guarantors considered applicants under ECOA and Reg. B? The Supreme Court was supposed to clear this up, but instead we’re left in the midst of more confusion. Ken Agle, AdvisX president, explains why.
The CFPB has introduced a new interim final rule on Reg. Z impacting dealings with rural and underserved areas. What changes should you be on the lookout for? AffirmX Director of Operations Mike Stottlemyer explains what your institution needs to know about this interim rule.
In an effort to encourage financial institutions’ development of innovative products, the CFPB has introduced a No Action Letter Policy. But is this policy’s bark worse than its bite? Jane Pannier, AffirmX VP and in-house counsel, fills us in on just how helpful a No Action Letter may be to your institution.
When tackling vendor management for any size institution, a comprehensive and tailored approach can more than help. AffirmX analyst Rachel Osborn introduces the AffirmX Vendor Management Solution tool, which offers to do just that.
While receiving a consumer complaint is not a new phenomenon, the way financial institutions are expected to handle complaints is changing and is now becoming a focus for examiners and regulatory agencies. Julie Kappenman of Mountain West Credit Union Association describes the eight components of a sound complaint management process.
Looking to make the FFIEC’s Cybersecurity Risk Assessment tool more manageable and effective? Mike Stottlemyer, director of operations at AffirmX, introduces to us a new tool his firm has created to help institutions better manage data and monitor their progress while conducting their cybersecurity assessments.
How financial institutions deal with consumers who have Limited English Proficiency, or LEP, is receiving growing attention from regulatory agencies. In our first non-English episode of Risk Watch, Quinton Harrison, AffirmX Analyst, puts this problem into a poignant perspective as he explains the challenges faced when marketing to LEP consumers.
With the areas of scrutiny constantly evolving, how can a financial institution get a sense of what is coming down the road from examiners? Chris McCullock of AdvisX shares some of the drivers he sees as indicators of where regulatory attention is heading.jj
In its fall 2015 semi-annual report, the CFPB points out 5 areas of heightened fair lending risk it encounters. Using recent enforcement actions, AffirmX Regulatory Counsel Chris McCullock illustrates what poor fair lending patterns attract the CFPB’s eye.
The Federal Financial institutions Examination Council just released a statement warning financial institutions about the increasing frequency and severity of cyber attacks involving extortion. What can be done to prepare for such attacks? Dennis Agle, CIO of AffirmX, breaks down the report and brings us up to speed.
Thought the relative number of SARs associated with crowdfunding is still low, a 171% rate of increase can’t be ignored. Ken Agle, president of AdvisX, gives us the lowdown of what attracts money launderers and fraudsters to these crowdfunding campaigns, and clues us in on how to spot and report such unsavory practices.
The CFPB has releasedan 800-page overhaul of the Home Mortgage Disclosure Act, and the changes are rather significant. How should you prepare? Barrett Jones, head of data analytics for AdvisX, breaks down what changes financial institutions should know about and, more importantly, what they mean.
Ever wonder what becomes of your Suspicious Activity Report once it’s submitted? Ken Agle of AdvisX takes a look at the FinCEN’s 2015 SAR Stats, which breaks down how SARs are used by various federal, state, and local agencies. What’s more, it offers some helpful tools your financial institution can use to make sure its Bank Secrecy Act program is proactively meeting emerging threats.
With the NCUA expected to finalize its Risk-Based Capital Rule soon, Former NCUA Chair Dennis Dollar cuts through all the hullabaloo and breaks down what you really need to know about the proposal as well as what you can expect going forward. In plain English!
FinCEN’s Director pulled the public eye when she announced data that showed many small credit unions have not filed any Bank Secrecy Act-mandated Suspicious Activity Reports or Currency Transaction Reports in nearly two years. AdvisX regulatory affairs counsel, Chris McCullock, explains what this finding means, and discusses a plausible explanation for such a lack of SAR and CTR reports.
One of the most underutilized credit union tools, the Low-Income Designation can actually provide some strong exemptions and opportunities. NCUA former chair and principle partner of Dollar Associates, Dennis Dollar, explains how to take advantage of this rule.
The NCUA’s Fixed-Asset rule underwent a change earlier this year, and the change may be in your financial institution’s favor. Who better to tell us about the expected impact of the rule than Dennis Dollar, former chair of the NCUA and now principal partner of Dollar Associates?
Earlier this year, the CFPB’s Office of Servicemember’s Affairs released a report outlining data and trends from complaints submitted by servicemembers, veterans, and their families. In this Risk Watch video AffirmX Analyst Rachel Osborn outlines the major findings and tips on how financial institutions can better work with servicemember.
When it comes to regulatory compliance, what are the best ways to gauge the health of your institution’s regulatory program? Asking the right questions is always a good place to start. What are the main kinds of questions compliance experts get asked? And what are the questions experts suggest you should be asking?
In 2012, an Alabama-based bank voluntarily reimbursed nearly $35 million in wrongful overdraft fees to some 200,000 customers. So what did they do that cost them a $7.5 million fine in 2015, and what can your institution do to avoid the same mistakes? AffirmX senior analyst Coppelia Padgett explains how and when Regions Bank went wrong.
Risk Watch 63: Clarification & Guidance on the Homeownership Counseling Organizations Interpretive Rule
The CFPB has restated guidance on providing mortgage applicants with a list of homeownership counseling organizations. The Bureau has also added further guidance for mortgage lenders in this interpretive rule. What was added? AffirmX Analyst Henry Miles breaks down what the CFPB now expects from mortgage lenders.
The U.S. Treasury Department has just released its National Money Laundering Risk Assessment, which is designed to provide information on the latest emerging channels employed by criminals. In this episode AdvisX analyst Barrett Jones explains some of the money laundering schemes exposed in the Risk Assessment.
This novel report tells us that advances have been made in hindering terrorist funding, but that terrorist are seeking new methods of terrorist financing. What new terrorist financing trends does your organization need to be aware of? AdvisX analyst Cody Knudsen brings an analysis of the report and three emerging trends to watch. (7/24)
The importance of a robust BSA/AML monitoring system is clear. However, an all-encompassing monitoring system often feels beyond the reach of the smaller financial institution. AdvisX analyst Cody Knudsen brings us the second BSA/AML secret weapon in this special two-part Risk Watch episode.
The importance of a robust BSA/AML monitoring system is clear. However, an all-encompassing monitoring system often feels beyond the reach of the smaller financial institution. AdvisX analyst Cody Knudsen brings us the first BSA/AML secret weapon in this special two-part Risk Watch episode. Look above for part II!
The CFPB is turning up the heat on lenders with recently adopted revisions to its Consumer Complaint Database process. AffirmX VP Jane Pannier brings you what you need to know to make sure your financial institution stays ahead of the curve.
When it comes to advertising, the CFPB keeps a sharp eye on financial institutions. And though the bureau searches for all kinds of false claims, there is one in particular that’s been on its radar lately. AffirmX Analysts Rachel Osborn highlights this issue, and how to easily side-step it.
Billions of dollars are transferred out of the country every year. But there is still quite a bit of bewilderment surrounding the roads of remittance transfers. AffirmX Senior Analysts Coppelia Padgett goes over the best way to navigate remittance transfers.
Since receiving stinging reports of racial disparity, the CFPB has been given an audit from the the Office of Inspector General on how to improve its diversity and inclusion efforts. What can financial institutions learn from the report?
A vital part of the AML process is to conduct a periodic validation of your system. AdvisX President, Ken Agle, discusses four common trouble areas to pay attention to. To learn more about the upcoming AdvisX Webinar: The Four Corners of BSA AML Investigation on June 9th, click here.
What are the five steps to take to make sure your BSA Risk Assessment is ready for your next examination? Regulators and board members want to know that financial institutions have taken a good look at their exposure, and have a solid plan in place to address their risks. AffirmX Analyst Rachel Osborn breaks down the five steps in this episode of Risk Watch. (4/10)
The new TILA-RESPA integrated mortgage disclosure rule is shaking things up across the board for financial institutions. How will it impact your organization’s record retention program? Receive a complimentary copy of the AdvisX Record Retention Schedule when you sign up for a free two-week trial to My Risk Inbox. Follow this link and click “Subscription Options” in the top right corner. (3/27)
The regulatory hunt for deceptive advertising is in high season. What can we learn from these big headlines to avoid making the same mistakes? AffirmX Analyst Sydney Caskey walks us through key traps to be aware of. (3/20)
The market share for smaller financial institutions is shrinking at an alarming rate. Are they headed for extinction, or is there something that can be done to counter the trend? In this video, AffirmX analyst Henry Miles discusses a Harvard Kennedy School report titled “The State and Fate of Community Banking.”
Risk Watch 49: PCI Council Updates PIN Security Requirements
Personal identification numbers, or PINs, continue to be a target for criminals. The Payment Card Industry (PCI) Security Standards Council has released an updated version of the PIN Security Requirements to enhance usability and understanding by stating the requirements in a more granular manner. In this video, AffirmX’s CIO Dennis Agle highlights the requirements important to financial institutions. (3/6)
To help address the overlap caused by two different sets of loan disclosures (one for TILA and one for RESPA), the CFPB has finalized a rule with new, integrated disclosures. The implementation date—August 1—is looming. Get ready for the change with AffirmX Senior Analyst Coppelia Padgett. (Ends 2/27)
For more information, or to order a copy of the webinar, click here.
Sometimes the best way to figure out how to make the perfect policy is by hearing what elements contribute to a bad one. Join AffirmX Analyst Quinton Harrison as he describes the four types of flawed policies we see. (Ends 2/20)
Perhaps not surprisingly, the most common questions we receive aren’t broad, general questions having to do with BSA in the abstract, but specific questions about the nitty gritty details. Because let’s face it, BSA can be complicated. Join AffirmX Senior Analyst Coppelia Padgett to get answers to your burning BSA questions. (Ends 2/13)
It’s getting hard to go a week these days without seeing news of another major data security breach. Because of the nature of their business, financial institutions are likely to always be targets of these attacks. In this video, join internationally renowned computer security expert Jay Ranade as he helps you understand what you can do at a personal level as well as at an institutional level to improve your cybersecurity.
The SCRA has garnered a lot of attention recently, due in large part to the CFPB’s aggressive pursuit of violators. Not only are financial institutions being given the option of knowing who is entitled to SCRA protection, there is a growing expectation that they should be proactive in finding their customers and members who qualify by accessing the SCRA database. In this video, AffirmX Analyst Rachel Osborn gives an overview of the SCRA and how to use the database.
Enterprise risk management can seem daunting, because it takes a very complex ecosystem like financial institutions and requires the employees to protect their organization from myriad threats, all the while working to achieve the institution’s goals. In this video, AffirmX EVP and Director of Risk Management Ken Agle explains—by way of the Cold War—one method institutions can use to improve their enterprise risk management.
It’s been nearly half a decade since the FFIEC and FinCEN have released a new update of the BSA/AML Examination Manual. In this video, AffirmX’s senior analyst, Coppelia Padgett, provides an overview of critical changes.
Even though the CFPB only directly regulates financial institutions with assets in excess of 10 billion dollars, every financial institution—regardless of its asset size—is impacted in a big way by the CFPB. In this video, AffirmX Analyst Sydney Caskey explains why you might not want to ignore the newest regulatory agency in town.
Examinations can feel like a power struggle between institution and examiner—and examiners often win. In this video, AdvisX President Ken Agle share with you one way to help tip the scales back in your favor and take control of your examination.
The CFPB has finally allowed financial institutions to step into the 21st century and post their annual privacy notice online, instead of mailing it. But don’t put those stamps away just yet; there are a few caveats. In this video, AffirmX’s SVP and In-House Counsel Jane Pannier discusses those caveats and helps you determine whether they apply to your institution.
With any AML system it can be tempting to look the other way and let things slide, especially when closer inspection can mean nothing but headaches and a ton of more work. However, letting things slide or looking the other way has resulted in more than a few heads rolling at financial institutions over the years. What’s more, the expense of penalties and implementing agency-mandated fixes has spelled the end for many other financial institutions, whether through closure or acquisition. In this video, Analyst Cody Knudsen explains how quality control and quality assurance factor into the AML efforts of a financial institution.
For financial institutions, awash in a sea of regulations, compliance problems are inevitable. Less certain is the matter of deciding which problems rise to a level that requires board of directors involvement and how to present them. In this episode, AdvisX President Ken Agle aims to help institutions understand how to tread this fine line.
While the prohibition against unfair, deceptive, or abusive acts or practices (UDAAP) can often be overly broad. Join AffirmX Analyst Quinton Harrison as he defines what we do know about UDAAP and outlines best practices for institutions to protect themselves from UDAAP violations.
Based on recent compliance news, regulatory scrutiny for discrimination is on the rise, resulting in enforcement action after enforcement action. Join AffirmX Analyst Henry Miles as he reviews the mistakes of others, a far less painful way to learn.
While for most people the impending holiday season brings feelings of joy, for the financial institution’s operations officer, this season means one thing: the deadline for the ACH audit. But perhaps AffirmX Senior Analyst Coppelia Padgett can put a little joy back into the season by helping you avoid these three common ACH problems.
Up until recently, the CFPB has seemingly been satisfied with imperfect compliance with the new mortgage servicing rules, so long as a “good faith effort” to comply with the rules is demonstrated. But the recent actions against Flagstar Bank seem to signify that the good faith effort isn’t enough anymore. In this video, AffirmX’s SVP and In-House Counsel Jane Pannier discusses what has happened and what it means for your institution.
Recently, the FFIEC released last year’s HMDA data. Because HMDA is often a favorite when it comes to regulatory scrutiny, institutions need to perform some self-analysis. In this episode, Ken Agle, AdvisX President, shares with us a few important questions every institution should ask about its HMDA compliance upon the release of new data.
When a financial institution identifies a suspicious activity related to a previously filed SAR and that activity is within a specified timeframe, it needs to file what is called a continuation SAR. The timeframe and what goes in a continuation SAR frequently trip up financial institutions. In this episode, AffirmX Analyst and SAR specialist Rachel Osborn helps us sort out these common trouble spots.
Risk Watch 30: Disaster Recovery and Business Continuity Planning and Testing
If a disaster struck your institution right now, would you be ready to handle it? In this video, find out how to make your plan ready to be put to the test and learn three elements of a robust disaster recovery/business continuity plan with AffirmX’s EVP and Director of Risk Management, Ken Agle.
The federal regulatory agencies recently issued a joint guidance related to the repeal of unfair and deceptive practices rules. What does this mean for your institution? Find out in this episode of Risk Watch featuring AffirmX Analyst Rebecca Drebin.
One of the root causes of problems in a financial institution’s Bank Secrecy Act and anti-money laundering programs is a weak culture of compliance. In this video, AffirmX’s Senior Analyst Coppelia Padgett explains what a compliance culture is and what to do if it is lacking at your financial institution.
In the world of residential lending, loan officers frequently trip up when it comes to knowing when they’re dealing with a full-fledged application. Join Alberto Gamez, AffirmX’s Director of Sales and a 22-year mortgage specialist, to learn a simple trick to knowing when you have a complete loan application.
They say there’s an exception to every rule. In the case of the Secure and Fair Enforcement for Mortgage Licensing Act, or SAFE Act, there are actually TWO major exceptions to keep in mind, especially if yours is a smaller financial institution. In this episode, AffirmX Analyst Abner Rangel shares what those exceptions are and what potential pitfalls they present.
FinCEN’s “By the Numbers” quarterly publication that tracks trends in the nation’s Suspicious Activity Report filings has a new name, “SAR Stats.” But it’s not just the name that’s changed. In this episode of Risk Watch, AdvisX Analyst Cody Knudsen walks us through what’s new in “SAR Stats” and how you can put its information to good use for your financial institution.
Confused or overwhelmed by the volumes of material written about the controversial risk-based capital proposed rule? In the latest episode of Risk Watch, SVP and In-House Counsel Jane Pannier boils it down to what you really need to know in less than 9 minutes.
Nope, it’s not gluttony or greed! In this video, Analyst Rachel Osborn details the seven common errors she sees institutions make in their currency transactions reports.
Recently, NACHA (The Electronic Payments Association that was formerly called the National Automated Clearing House Association) released a new document called the Sound Business Practices for Evaluating Customer Risk. AffirmX’s Senior Analyst Coppelia Padgett gives us an overview of this important new guidance.
The effectiveness of an institution’s Bank Secrecy Act program hinges on the accuracy of its anti-money laundering monitoring system. AdvisX’s President Ken Agle shares three common errors he sees when conducting AML validations for financial institutions across the country.
Because the ESIGN legislature itself is only three pages long, it is relatively easy to follow. However, don’t let its brevity fool you—it still trips up financial institutions even a decade and a half after its implementation. AffirmX Analyst Dustin Stanley delineates three common mistakes with E-SIGN compliance he sees from his reviews for institutions across the country and how to avoid them.
More and more of our daily lives are moving online, and that includes banking, which is where the Electronic Signatures in Global and National Commerce Act (E-SIGN) comes into play. In this episode, AffirmX Analyst Dustin Stanley provides a high-level overview of this increasingly important regulation.
When it comes to fair lending, many institutions fail to compare their performance to the complete contextual picture, neglecting such factors as income, low-/high-minority population, age, gender, etc. In this video, AffirmX EVP and Director of Risk Management Ken Agle gives us an idea of how to complete the fair lending picture to discover potential problems or explain misleading numbers.
Because Know Your Customer (which includes CIP/MIP, CDD/MDD, and EDD) is such a critical part of compliance, we’ve put together a “Director’s Briefing,” a high-level overview of important areas of risk presented in 5 minutes or less. Join AffirmX Analyst Cody Knudsen to gain a better understanding of the history and important elements of KYC.
It’s tough to know where to allocate your attention to complying with the Bank Secrecy Act. That’s why we asked AffirmX Senior Vice President and In-House Counsel Jane Pannier to give us the scoop on what she’s heard examiners will most likely be focusing on during your next BSA exam.
In this era of excessive information sharing, consumer complaints pose a greater risk than ever before. In this video, AffirmX Analyst Rebecca Drebin delineates four key points to developing and maintaining a robust complaint management program.
The FFIEC recently announced the addition of a cybersecurity risk assessment to regular IT examinations. Join Jesse Boyer to learn how your institution can prepare for these exams which are beginning later this year.
Is your website compliant? Find out in this episode of Risk Watch. This video describes the top five website compliance mistakes that AffirmX Analyst Dustin Stanley sees in his reviews for financial institutions throughout the country.
From the best practice for displaying mortgage loan originator (MLO) unique identifiers to third-party MLO due diligence, is your institution compliant with the SAFE Act? Find out in this video, where Analyst Abner Rangel will describe the top five errors with SAFE Act compliance that he’s observed from his reviews.
Many institutions suffer from an overproduction of unnecessary AML alerts. On this episode of Risk Watch, Analyst Cody Knudsen will describe the key to optimizing your AML alert monitoring system: the waterfall model.
Big banks aren’t the only financial organizations targeted by DDoS and now the FFIEC has issued guidance to ensure you’re prepared. In this free DDoS webinar, learn about how DDoS attacks impact your credit union, hear stories of attacks and new research that supports DDoS as a smokescreen for breaches including financial and data theft.
Money services businesses offer a very valuable service to their customers. Unfortunately, these businesses are also a favorite for money launderers. In this episode of Risk Watch, expert Jane Pannier will provide compliance guidelines for financial institutions that offer or maintain accounts for MSBs.
AffirmX’s Senior Analyst Coppelia Padgett takes us on a brief tour of the TILA and RESPA integrated loan disclosures and suggests what institutions should do now to prepare for the August 1, 2015 implementation.
Writing the Suspicious Activity Report narrative is arguably the most challenging part of many financial institution’s BSA programs. From the AffirmX Operations Center, where SARs from financial institutions all across the country are constantly reviewed, Analyst Rachel Osborn presents some examples of bad and good SAR narratives. (Part 2 of 2.)
Writing the Suspicious Activity Report narrative is arguably the most challenging part of many financial institution’s BSA programs. From the AffirmX Operations Center, where SARs from financial institutions all across the country are constantly reviewed, Analyst Rachel Osborn describes the common characteristics of a well-written SAR narrative. (Part 1 of 2.)
Amendments to the Truth in Lending Act may make it appear that small servicers are exempt from the requirements to post their credit card agreements online. AffirmX’s senior analyst, Coppelia Padgett, explains why a closer look is a good idea.
Regulators are moving beyond just checking for accuracy when evaluating anti-money laundering screening rules and considering whether the rules themselves make sense for the institution. AffirmX’s Ken Agle discusses what this means your institution should be doing now to prepare.
While cyber security threats have usually targeted large financial institutions, regulators are anticipating that smaller institutions are next. AffirmX’s SVP and In-House Counsel Jane Pannier explains the risks and what small-to-mid-sized financial institutions should be doing now to prepare accordingly.
What financial institutions should know about their social media presence and recent regulatory guidance on the issue. AffirmX’s EVP and Director of Risk Management Ken Agle explains the risks with getting social in this episode of Risk Watch.
Introducing AffirmX’s Policy Management Tool, an Excel spreadsheet that can help your financial institution track each of its policies through their approval cycle.