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Have a question for your peers?
Email the Lagniappe Listserv at
[email protected]
t
o get input on compliance related issues, share best practices, or share policies, procedures and the latest in fraud awareness.
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ComplySight: FREE Recorded Webinars
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Recorded Webinars - Watch on Demand!
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Upcoming Educational Events
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January 14-15
For a complete listing of educational opportunities available from LCUL and to register, visit the
League website and click on "Education"
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The BSA Officer's Toolkit contains tools to help manage your institution's BSA/AML program. It is designed to help you revamp and revitalize your BSA program before the examiners arrive.
Toolkit is provided by GetTechnical Inc.
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InfoSight Highlight: CUNA updates its website- InfoSight links being updated
Yes, it's true! CUNA has updated their
website
, and all links in InfoSight are in the process of being reviewed and updated. If you are looking for some of the more popular items, they can be found on the CUNA
Compliance Page
.
Please bear with us as we make these changes!
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Payday loan rule published
The Consumer Financial Protection Bureau published its
final rule, "Payday, Vehicle Title, and Certain High-Cost Installment Loans," at
82 FR 54472
in the 11/17/17 Federal Register.
The rule is to become effective January 16, 2018, with most sections carrying a compliance date of August 19, 2019.
This will start the 60-legislative-day period under the Congressional Review Act during which Congress can nullify the rule with a joint resolution approved by the president.
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The 5 most common mistakes NCUA finds during BSA exams
Last month, at the CUNA/NASCUS BSA school, NCUA's Judy Graham described the 5 most common BSA mistakes examiners find during examinations:
- Inadequate Risk Assessment: NCUA recommends that credit unions take the time to review all products and services to determine where BSA risks may exist, such as business accounts and wire transfer activity. Make sure you have adequate internal controls to meet these risks.
- SAR Monitoring: Make sure your SAR procedures and monitoring systems have been updated to keep up with your credit union's growth and sophistication. Ensure that the technology running your products and services is communicating with your SAR monitoring system.
- Training: Ensure your board of directors and supervisory committee are receiving appropriate training that is commensurate with the risk profile of your credit union. Also, training should be individualized to each department of the credit union and occur every 12-18 months.
- Independent Testing: Make sure your independent testing covers ALL AREAS OF YOUR OPERATION and occurs every 12 -18 months.
- Section 314(a): Ensure your credit union is checking FinCEN's Section 314(a) lists as they are coming in - DO NOT FALL BEHIND.
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FinCEN Exchange launched
FinCEN has
announced
the launch of its FinCEN Exchange program to enhance information sharing with financial institutions. As part of this program, FinCEN, in close coordination with law enforcement, will convene regular briefings with financial institutions to exchange information on priority illicit finance threats, including targeted information and broader typologies. The program will enable financial institutions to better identify risks and focus on high priority issues, and will help FinCEN and law enforcement receive critical information in support of their efforts to disrupt money laundering and other financial crimes.
Source: FinCEN
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