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Editor: Lucy H. Griffin

Board of Advisors:
John S. Byrne, Esq.
David Battle
Robert P. Chamness
David Dickinson
Phillips G. Gay, Jr.
Barbara Hurst
Michael D. Maher
Robert G. Rowe, III
Andy Zavoina
Volume 8, Number 4
This issue went to press on April 30, 2003.
Table of Contents

Developing A Successful Bank Secrecy Program: To Catch A Crook, Think Like One (4 Action Steps)
There are two ways to approach an anti-money laundering program. The first is to make sure that all CTRs and SARs are correctly filled out and filed on time. The second way to approach an anti-money laundering program is to think about how to catch a crook.

BSA: FRB's SAR Enforcement (6 Action Steps)
It is significant to see the elements highlighted in an enforcement action for practices that took place before FinCEN's final Customer Identification rule.

Action Audit: Selecting Reasons For Adverse Action (9 Action Steps)
Regulation B tells creditors that they must inform credit applicants of the specific reasons for denial. It has been in place for a quarter of a century. But we still have trouble with it.

Compliance Notes Compliance Calendar

In the Editor's Opinion: Suspecting the Unsuspecting
Banking has entered a new era in which we must be suspicious of unsuspicious-seeming people.

Compliance Q&A Community Development Research: Greenspan on Community Development Research
Late in March, Federal Reserve Board Chairman Alan Greenspan addressed the Federal Reserve System's Community Affairs Research Conference. He delivered a strong, clear message: research is needed but the research must be responsible.

Reg Z: Bounce Protection v. Regulation Z
Bounce protection programs - those products put forward to banks as a significant generator of fee income - have come under the regulator's umbrella of concern.

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