Compliance Briefing for Friday, July 31, 2015

To access specific issuances, go to our Top Stories section, where you'll find links to all the relevant documents.
Risk Scoring — The Essential Element of BSA/AML Compliance

PATRIOT OFFICER automatically calculates risk scores for each customer to identify higher-risk customers and monitors them more closely as the regulations mandate. The solution automatically detects check fraud, check kiting, deposit fraud, ACH fraud, wire fraud, Internet banking fraud, credit/debit card fraud, ATM fraud, employee fraud, and financial fraud to prevent losses. PATRIOT OFFICER is the only BSA/AML/FRAUD solution endorsed by American Bankers Association.
— GlobalVision Systems, Inc.

Bureau orders servicer to pay restitution and CMP
The Consumer Financial Protection Bureau has announced it has issued a Consent Order against Residential Credit Solutions, Inc., headquartered in Ft. Worth, Texas, for blocking consumers' attempts to save their homes from foreclosure. The Bureau found the mortgage servicer:
  • Failed to honor in-process modifications
  • Provided incorrect information
  • Misrepresented to consumers that they had extra money in escrow and were due a refund
  • Forced consumers to waive certain rights to get a payment plan

The Consent Order requires Residential Credit Solutions, Inc, to:
  • Pay $1.5 million in redress to victims
  • Engage in efforts to help affected borrowers preserve their homes
  • Honor prior loss mitigation agreements
  • End all mortgage servicing violations
  • Adhere to rigorous servicing transfer requirements
  • Make loss mitigation applications readily available
  • Pay a $100,000 civil money penalty

58 Red Flags for Terrorist Financing
This article provides a detailed list of red flag indicators for terrorist financing. It also discusses highlights from a comprehensive study of terrorism financing which revealed that "simply by using standard anti-money laundering typologies, financial institutions should have been able to identify fourteen instances of terrorism financing as being suspicious, though not on their face to raise suspicion of terrorism financing."
— Verafin

New designations for evasion of Russian and Ukrainian sanctions
OFAC has announced the designation of a number of individuals and entities under four executive orders related to Russia and Ukraine. The designations are designed to counter attempts to circumvent U.S. sanctions, to further align U.S. measures with those of international partners, and to provide additional information to assist the private sector with sanctions compliance. Those designated include thirteen individuals and entities that have supported serious and sustained evasion of existing sanctions; two entities that operate in the arms or related materiel sector of the Russian Federation; four former Ukrainian government officials or close associates for complicity in the misappropriation of public assets and/or undermining of democratic processes or institutions in Ukraine as well as an entity owned or controlled by, or acting for or on behalf of, one of the designated individuals; five Crimean port operators; and one Crimean ferry operator. OFAC also removed the names of five previously designated individuals from the SDN List.

Find Out if Disparities Are Lurking in Your Fair Lending Data
The regulators are analyzing your data for disparities and fair lending risk. Do you know what they're seeing? In this regulatory environment, you can't afford not to know your numbers. Claim your free sample Fair Lending report today!
— TRUPOINT Partners

OFAC adds Crimea Sanctions advisory
OFAC has also issued a Crimea Sanctions Advisory, "Obfuscation of Critical Information in Financial and Trade Transactions Involving the Crimea Region of Ukraine," to highlight some of the practices that have been used to circumvent or evade U.S. sanctions involving Crimea. The evasive practices identified by OFAC include the omission or obfuscation of references to Crimea and locations within Crimea in documentation underlying transactions involving U.S. persons or the United States. These practices apply to a range of activities involving both the financial services and international trade sectors.

[Spreadsheet] Track Credit Exceptions
"Lending exceptions generally either relate to documentation or underwriting. Banks should have systems to analyze and control both types of exceptions," as stated by the Comptroller's Handbook on Loan Portfolio Management. Download a free spreadsheet to track exceptions.
— AccuSystems

Mortgage rates up
The Federal Housing Finance Agency (FHFA) Index for June 2015 has been released, reflecting increases in several benchmark rates over May numbers.

Has Your Loan Policy Passed Its Expiration Date?
Loan policies don't technically expire, but loan portfolios are the largest asset of financial institutions and lending has dramatically changed in recent years. Perhaps it's time to take a fresh look to determine whether changes are necessary to your policy.
Download our recent article to learn more.
— Wipfli

Board appoints Faster Payments Strategy leader
The appointment of Reserve Bank of Chicago Senior Vice President Sean Rodriguez as Faster Payments Strategy Leader has been announced by the Federal Reserve Board. Rodrigez will lead activities to identify effective approaches for implementing a safe, ubiquitous, faster payments capability in the U.S. and chair the Federal Reserve's Faster Payments Task Force, comprising more than 300 payment system stakeholders.

FTC pays scammed consumers
The Federal Trade Commission has announced it is mailing 10,387 checks totaling more than $969,000 to consumers who lost money to a credit card interest rate reduction scam. The refunds are the result of a lawsuit filed by the Commission against Innovative Wealth Builders, a telemarketing operation that falsely promised consumers it could reduce their credit card interest rates and save them thousands of dollars on their debts. The FTC alleged that the defendants made false claims to consumers about their reduction services and refund policies, and billed consumers without their consent.

CFPB Save the Date for Springfield
The Bureau has posted a Save the Date notice for a financial management seminar for seniors to be held in Springfield, Virginia, on August 17. The event is open to the public and will be held in Greenspring, a senior living community.

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