TOPIC: Compliance

Interactive (virtual) teller - signature

SVP at a bank ($2.2BUSA)
Good morning!

We are in the processing of going live with an interactive (virtual) teller machine. One issue that has come up is that the software does not capture and store an image of the customer's signature when making a withdrawal - it is only displayed for the teller to verify, then it is no longer displayed or saved.  

For those banks who are using this technology - has this posed an issue for you? What have you done to overcome this or mitigated the risks of not having the signature on a withdrawal?

    Enter To Win - Contest Questions & Consent

    AVP at a bank ($3.4BUSA)
    We often hold prize drawings to generate sales leads for various lines of business.  In order to enter the contest, individuals must complete an entry slip, with their contact info, and indicate via check box if they wish to receive or decline solicitations from the bank regarding our products and services.  
    We are planning to modify the entry slip to say by signing and entering the contest, you do agree to be contacted by the bank (so that the contest can generate more leads.)  We plan to check entrant’s names against internal “do not call” customer lists, but do not have clear procedures for handling non-customers. My questions are:
    1. Does anyone see a problem with restructuring the giveaway entry slip to require consent in advance of entering the contest? 2. How do other institutions ensure you do not contact individuals, especially non-customers, who are listed on “do not call” registries?
    Note, bank employees would be contacting sales leads – no robocalling. 

    I would appreciate any feedback from others who have experience with this. Thank you!

      Non-IOLTA Client Trust Accounts

      AVP at a bank ($1.1BUSA)

      What are other Banks requiring when opening up non-IOLTA client trust accounts?

      I have reviewed our state law regarding non-IOLTA client trust accounts with regards to how the Lawyer is to setup the account. We are obtaining business documentation for the Lawyer/Entity, W9 Certification for the owner of the funds, and in some instances, the Lawyer's provide some form of directive from the firm to confirm the account setup. With the exception of the directive regarding the opening of account, the accounts are being opened within State guidelines.

      Is this more of a Bank New Account policy rather than a state or Federal Guideline (have not been able to locate anything)?

      Any thoughts would be greatly appreciated. Thank you,

        10 things you need to do now that your HMDA is filed

        It's that time of year again - your HMDA data has been filed with the federal government. The regulators have your HMDA (and CRA) LAR now, so the time is ripe for you to take a deep breath and think about your goals for the rest of the year.

        Now that you've filed your HMDA data, here are the 10 things you need to do: https://www.trupointpartners.com/blog/10-things-to-do-after-submitting-your-hmda-data

          Infographic - Marijuana-Related Businesses The Risks & Rewards of Banking a Growing Industry

          Marijuana-Related Businesses
          The Risks & Rewards of Banking a Growing Industry

          Download now: https://verafin.com/resource/marijuana-related-businesses/?src=cbanc

          Marijuana-related businesses (MRBs) have been receiving a lot of attention lately. This growing industry is already worth $7 Billion in the U.S., with that number projected to more than quadruple over the next 8 years, creating many questions for financial institutions around banking MRBs.

          This infographic provides a handy introduction to the world of MRBs, quickly mapping marijuana law by state, examining the number of businesses that have been flagged as MRBs in the Verafin Cloud to date, and offering insight into identifying and assessing compliance risk related to MRBs.

          Download now: https://verafin.com/resource/marijuana-related-businesses/?src=cbanc

          Blob

            Using Big Data Intelligence for Big Gains in Fighting Crime - Join us on March 6

            March 6 at 12:30 PM - 01:30 PM EST
            Using Big Data Intelligence for Big Gains in Fighting Crime
            How your Institution Can Leverage Data and Technology in the Cloud for Fraud Detection, AML and High-Risk Customer Management

            Part of a Special Series on The New Future of Fighting Crime

            Register now: https://verafin.com/event/using-big-data-intelligence-for-big-gains-in-fighting-crime/?src=cbanc

            Institutions are facing increased pressure to mitigate the risk of fraud and money laundering, and stay compliant. But as workload and costs increase, false positives can overwhelm already strained resources, so there is significant risk in relying on manual processes or rules-based monitoring systems.

            To effectively fight crime, investigators need to leverage vast amounts of data from numerous sources in their analysis. Verafin imports and analyzes an immense data set from multiple sources, including core data, ancillary data, open-source and third-party data, and consortium data. In fact, before Verafin it would have been unthinkable to analyze that much data. By applying cross-institutional analysis and machine learning technology to analyze a billion transactions every week, our approach reduces false positives and increases the quality of your alerts.

            Join us to learn how Verafin’s Big Data Intelligence approach keeps you ahead of fraud trends and regulatory changes, provides higher-quality, targeted alerts, and gives you a complete view of activity, including crimes that span multiple institutions.

            Highlights of this presentation will include how Verafin’s Big Data Approach helps you fight crime by:

            • Providing a complete picture of activity in a single system ensuring greater visibility of potential risks, while saving you valuable time and money.
            • Leveraging cloud technology and cross-institutional analysis to proactively detect and mitigate risk, reduce costs, and protect your customers and institution.
            • Integrating and analyzing multiple data sources to improve alert quality, such as peer profiling, high-risk customer labeling, payee confidence, and geolocation data.
            • Applying Machine Learning to learn from labeled data, further improving detection and monitoring capabilities.
            • Partnering with you to develop solutions to real-world problems with targeted, expert-driven models for Fraud Detection, AML Transaction Monitoring and High-Risk Customer Management.

            Register now: https://verafin.com/event/using-big-data-intelligence-for-big-gains-in-fighting-crime/?src=cbanc

            Blob

              Reg O Questions - Related Interests, Reporting, Etc.

              AVP at a bank ($3.4BUSA)

              Not getting responses in another group I asked, so hoping this might reach more people! Thanks so much.

              1. Do you report related interest loans on your Call Report, and if so, do you only report the amount of % owned by the insider or do you report the full loan balance?
                1a. Which figure should be used for in-house Reg O reports?

              2. Do you track/report loans that are excluded, such as overdraft lines? Interested in the pros/cons of doing this.

              3. Are loans to related interests of an Executive Officer excluded from the $100,000 limit, and only subject to the 215.4 limitations, as long as the Executive Officer does not personally guarantee the loan?

              4. If an insider’s loan is grandfathered in due to timing of insider election, do you still obtain a demand clause or do you just notate the dates and reason for exclusion?

                Using Big Data Intelligence for Big Gains in Fighting Crime - Join us on March 6

                March 6 at 12:30 PM - 01:30 PM EST
                Using Big Data Intelligence for Big Gains in Fighting Crime
                How your Institution Can Leverage Data and Technology in the Cloud for Fraud Detection, AML and High-Risk Customer Management

                Part of a Special Series on The New Future of Fighting Crime

                Register now: https://verafin.com/event/using-big-data-intelligence-for-big-gains-in-fighting-crime/?src=cbanc

                Institutions are facing increased pressure to mitigate the risk of fraud and money laundering, and stay compliant. But as workload and costs increase, false positives can overwhelm already strained resources, so there is significant risk in relying on manual processes or rules-based monitoring systems.

                To effectively fight crime, investigators need to leverage vast amounts of data from numerous sources in their analysis. Verafin imports and analyzes an immense data set from multiple sources, including core data, ancillary data, open-source and third-party data, and consortium data. In fact, before Verafin it would have been unthinkable to analyze that much data. By applying cross-institutional analysis and machine learning technology to analyze a billion transactions every week, our approach reduces false positives and increases the quality of your alerts.

                Join us to learn how Verafin’s Big Data Intelligence approach keeps you ahead of fraud trends and regulatory changes, provides higher-quality, targeted alerts, and gives you a complete view of activity, including crimes that span multiple institutions.

                Highlights of this presentation will include how Verafin’s Big Data Approach helps you fight crime by:

                • Providing a complete picture of activity in a single system ensuring greater visibility of potential risks, while saving you valuable time and money.
                • Leveraging cloud technology and cross-institutional analysis to proactively detect and mitigate risk, reduce costs, and protect your customers and institution.
                • Integrating and analyzing multiple data sources to improve alert quality, such as peer profiling, high-risk customer labeling, payee confidence, and geolocation data.
                • Applying Machine Learning to learn from labeled data, further improving detection and monitoring capabilities.
                • Partnering with you to develop solutions to real-world problems with targeted, expert-driven models for Fraud Detection, AML Transaction Monitoring and High-Risk Customer Management.

                Register now: https://verafin.com/event/using-big-data-intelligence-for-big-gains-in-fighting-crime/?src=cbanc

                Blob

                  Two updated UDAAP articles

                  Hi all! I wanted to let you know that we updated our most popular UDAAP article from our website and also added another. The first article provides helpful, clear, regulator-approved definitions for unfair, deceptive, and abusive in UDAAP compliance. The second one provides three tips for how to avoid UDAAP compliance risks. Here they are:

                  We also have a free UDAAP resource that provides these definitions, plus 17 best practice tips for UDAAP compliance. You can get that for free here: https://www.trupointpartners.com/udaap-compliance-info-kit

                  Since these have been updated, I thought it might be helpful to share with the group here. Thanks so much!

                    Nonbank Financial Institutions - NBFIs

                    SVP at a bank ($3.3BUSA)

                    Looking to see what others do relative to banking independent loan/finance companies that provide lending services to customers of the independent finance customer. Lately, our bank has been opening several accounts for independent lending companies that provide lending services to help individuals purchase residential real estate for investment purposes or for the real estate to be rehabbed and "flipped." According to FinCEN guidance, these type of companies are considered to be an NBFI and are required to have an AML program in place.

                    Our question is, what are other banks doing? Are you asking and requiring these types of customers to provide evidence that they have an AML program in place?

                    If anyone has an opinion or comments, please share...