BSA Ropes in Cowboys
by Lucy Griffin, BOL Guru
The Federal Reserve has issued a Cease and Desist Order involving Cowboy State Bank, located in Ranchester, WY. Basically, the C&D strikes the bank on two fronts: safety and soundness, and BSA compliance.
The first point in the order is the responsibility of the board of directors and management for performance of the bank - and for correcting problems. Once again, the regulators deliver the message that being a bank director is a real job with real responsibilities. It is much more than an opportunity to attend an interesting meeting.
One of the concerns - just in case you needed some momentum to get this going in your institution - is loan documentation. Cowboys must bring all loan documentation up to date.
Also on the hit list is BSA. Cowboys must develop a program that fully complies with Regulation H, arrange for an independent review of BSA, and bring adequate information security into the program with appropriate information technologies.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 2, 3/04
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